Daily Tax Update - August 11, 2006

IRS UPDATES TEMPORARY FILING PROCEDURE AND MAILING ADDRESS:
This week, the IRS announced that it is updating its temporary procedure for processing requests for certain expedited letter rulings for reorganizations and section 355 distributions. The temporary procedure was put in place because flooding caused the temporary closure of the IRS headquarters.

  • The IRS stated, "For expedited treatment as described in Revenue Procedures 2005-68 and 2006-1, taxpayers should fax their requests to (703) 605-1764. Also requesters no longer need to contact an IRS attorney before making expedited ruling requests, thus the temporary procedure described in IR-2006-105 is withdrawn. Taxpayers should instead follow the normal instructions in Revenue Procedures 2005-68 and 2006-1. However, taxpayers may call the Office of the Associate Chief Counsel (Corporate) at (202) 622-7242 or (202) 622-4038, if they have questions regarding this procedure."
  • The IRS also provided a new temporary address for taxpayer requests for rulings, requests for determination letters, Applications for Change in Accounting Method (Form 3115), and similar requests that are permitted to be hand-delivered to the main IRS building. The IRS stated that these requests and applications should be delivered to: Courier's Desk, Room 105, First Floor, Internal Revenue Service, Attn: CC:PA:LPD:DRU, Crystal Mall 4 Building at 1901 S. Bell St. or 1941 Jeff Davis Highway in Arlington, VA."

INTERNAL REVENUE SERVICE - CIRCULAR 230 DISCLOSURE:
As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this communication (including attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any plan or arrangement addressed herein.

STEPTOE & JOHNSON LLP - TAX PRACTICE
Steptoe & Johnson LLP has one of the largest and most diverse law firm tax practices in the country. The practice covers the entire spectrum of federal taxation, including representation of businesses before the Congress, Treasury and the national office of the IRS; transactional planning for domestic and multinational corporations; complex audit and controversy work for corporations and other business interests contesting IRS adjustments; litigation before the Tax Court, Court of Federal Claims, district courts, courts of appeals and the Supreme Court. The firm's tax practice also encompasses all aspects of employee benefits (ERISA), executive compensation, tax-exempt organizations and charitable giving.  Steptoe has an extensive state and local tax practice, representing an array of business clients on complex sales and use tax, corporate income tax and property tax matters, both advising those clients and handling audits, administrative appeals, and litigation for them.  Read  more information on Steptoe's tax practice