Daily Tax Update - July 2, 2009

NATIONAL TAXPAYER ADVOCATE SUBMITS MID-YEAR REPORT:  This week, National Taxpayer Advocate Nina Olson submitted a report to Congress that identifies the priority issues that the Office of the Taxpayer Advocate will address in the coming fiscal year. Among the key areas of focus will be working with the IRS to improve taxpayer services, enhancing IRS oversight of federal tax return preparers, improving the accessibility of the offer in compromise program, and working with the IRS to improve its ability to administer refundable tax credits effectively.

  • Olson said, “As TAS enters its tenth year, both TAS and the IRS face a difficult environment for achieving what is, in essence, the same mission – ensuring that the IRS treats taxpayers fairly and identifying ways to increase voluntary compliance while addressing noncompliance.” Olson identified the collection of tax revenue at a time when “increasing numbers of taxpayers have difficulty paying their daily living expenses” as a principal challenge.
  • The report can be accessed here. 

MISCELLANEOUS GUIDANCE ISSUED THIS WEEK:
Revenue Procedure 2009-32 provides reliance criteria to private foundations and sponsoring organizations that maintain donor advised funds in determining whether a potential grantee is a supporting organization described in section 509(a)(3) of the Internal Revenue Code.

Correction to Revenue Procedure 2009-32, issued earlier today:  The title of the document has been changed FROM “Reliance Criteria for Supporting Organizations and Donor Advised Funds” TO “Reliance Criteria for Private Foundations and Sponsoring Organizations.”  

Revenue Procedure 2009-33 provides guidance regarding the ability of corporations to elect not to claim the 50-percent depreciation deduction for certain property (extension property) placed in service before January 1, 2010, and instead increase their business credit limitation and AMT credit limitation.

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.