| Document |
Bulletin |
Date of IRB |
 |
| |
| Announcement 2005-87(HTML) |
IRB #2005-50(HTML) |
December 12, 2005 |
| Compliance Assurance Process (CAP) Pilot Program: The purpose of this announcement is to formally announce the Compliance Assurance Process (CAP) pilot program for large business taxpayers. The objective of the program is to reduce taxpayer burden and uncertainty while assuring the Service of the accuracy of tax returns prior to filing, thereby reducing or eliminating the need for post-filing examinations. |
| Announcement 2005-80(HTML) |
IRB #2005-46(HTML) |
November 14, 2005 |
| Settlement Initiative: This announcement provides a settlement initiative under which taxpayers and the Internal Revenue Service may resolve the tax treatment of certain tax transactions. Taxpayers have until January 23, 2006, to file an election indicating their intent to participate in this initiative. |
| Announcement 2005-42(PDF, 169K) |
IRB #2005-24(HTML) |
June 13, 2005 |
| Pre-Filing Agreement Program: This announcement contains the annual report concerning the Pre-Filing Agreement program of the Large and Mid-Size Business Division of the Service for Calendar Year 2004. |
| Announcement 2005-39(PDF, 56K) |
IRB #2005-22(HTML) |
May 31, 2005 |
| Settlement Initiative & Sections 6111 and 6112 of the Code: This announcement provides supplemental information for the settlement initiative described in Announcement 2005-19 to resolve transactions that are the same as or substantially similar to those described in Notice 2003-47. The transaction generally involved executives transferring compensatory stock options or restricted stock to a related person in exchange for a long-term, unsecured deferred payment obligation. It addresses (1) the penalty under the initiative for taxpayers with unexercised options or nonvested stock, (2) the application of section 6654 for a settlement of taxable year 2004, and (3) filing disclosure statements under regulations section 1.6011-4 for taxpayers that settle their transactions under the initiative. Taxpayers have until May 23, 2005, to notify the Service of their intent to participate in the settlement initiative. |
| Announcement 2005-26(PDF, 48K) |
IRB #2005-17(HTML) |
April 25, 2005 |
| TeleFile to be Discontinued: The IRS will discontinue its TeleFile program after August 16, 2005. TeleFile allows taxpayers to file Forms 1040EZ, 4868, and 941 by telephone. Decline in use for most forms, coupled with increasing costs to maintain the system, led to the decision. |
| Announcement 2005-19(PDF, 113K) |
IRB #2005-11(HTML) |
March 14, 2005 |
| Executive Stock Options Settlement Initiative: This document sets forth a settlement initiative to resolve transactions that are the same as or substantially similar to those described in Notice 2003-47, 2003-2 C.B. 132. These transactions generally involved executives transferring compensatory stock options or restricted stock to a related person in exchange for a long-term, unsecured deferred payment obligation. Taxpayers have until May 23, 2005, to notify the Service of their intent to participate in the settlement initiative. |
| Rev. Proc. 2005-75(HTML) |
IRB #2005-50(HTML) |
December 12, 2005 |
| Adequate disclosure for purposes of reducing an understatement of income tax penalty: This procedure provides guidance concerning when information shown on a return in accordance with the applicable forms and instructions will be adequate disclosure for purposes of reducing an understatement of income tax under sections 6662(d) and 6694(a) of the Code. Rev. Proc. 2004-73 updated. |
| Rev. Proc. 2005-63(HTML) |
IRB #2005-36(HTML) |
September 6, 2005 |
| Time periods for requesting consent to change a method of accounting. For a taxpayer desiring consent to change a method of accounting provided for under certain regulations, this procedure waives the requirement to request consent within the time periods prescribed in those regulations provided the taxpayer requests consent in accordance with this procedure. Rev. Proc. 83-77 superseded. |
| Rev. Proc. 2005-60(HTML) |
IRB #2005-35(HTML) |
August 29, 2005 |
| Obligations of authorized IRS e-file providers: The purpose of this procedure is to inform authorized IRS e-file providers of their obligations to the Service and to consolidate existing guidance. The procedure combines the rules governing IRS e-file, including the rules regulating Electronic Return Originators (EROs) that electronically file (1) Form 1040 and 1040A, U.S. Individual Income Tax Return, and Form 1040EZ, Income Tax Return for Single and Joint Filers With No Dependents, contained in Publication 1345, Handbook for Authorized IRS e-file Providers of Individual Income Tax Returns; (2) Form 940, Employer's Annual Federal Unemployment (FUTA) Tax Return, contained in Rev. Proc. 2001-9; and (3) Form 941, Employer's Quarterly Federal Tax Return, contained in Rev. Proc. 99-39. Rev. Procs. 99-39, 2000-31, and 2001-9 superseded. |
| Rev. Proc. 2005-38(PDF, 60K) |
IRB #2005-28(HTML) |
July 11, 2005 |
| Abatement of Interest: This procedure describes how taxpayers may seek administrative relief when the Service has assessed interest for periods during which interest should have been suspended under section 6404(g) of the Code. |
| Rev. Proc. 2005-34(PDF, 81K) |
IRB #2005-24(HTML) |
June 13, 2005 |
| Trust fund recovery penalty assessments under Section 6672: This procedure sets forth updated procedures for appeals of proposed trust fund recovery penalty assessments arising under section 6672 of the Code. The procedures apply to trust fund recovery penalty cases relating to employment and excise taxes imposed under the Code, except when collection is in jeopardy. Rev. Proc. 84-78 superseded. |
| Rev. Proc. 2005-33(PDF, 96K) |
IRB #2005-24(HTML) |
June 13, 2005 |
| Seeking a declaratory judgment pursuant to Section 7479: This procedure provides guidance on exhausting administrative remedies prior to seeking a declaratory judgment pursuant to section 7479 of the Code. |
| Rev. Proc. 2005-32(PDF, 73K) |
IRB #2005-23(HTML) |
June 6, 2005 |
| Reopening of examinations under Section 7605(b): This procedure provides guidance on when an IRS examination is considered closed, when a closed examination may be reopened (to include reinspecting a taxpayer's books of account), and who may approve a reopening. The procedure also describes by category certain IRS contacts with taxpayers and other actions taken as to taxpayers that are not examinations, inspections of books of account, or reopenings. Rev. Proc. 94-68 modified and superseded. |
| Rev. Proc. 2005-26(PDF, 69K) |
IRB #2005-17(HTML) |
April 25, 2005 |
| Limitations period on assessment with respect to an "undisclosed listed transaction": In this procedure, the IRS provides guidance relating to section 6501(c)(10) of the Code, which provides for an extended period of limitations to assess any tax with respect to a listed transaction that a taxpayer failed to disclose as required under section 6011. It sets forth procedures that taxpayers and material advisors may follow to disclose previously undisclosed listed transactions for purposes of section 6501(c)(10) and guidance on the date on which the period of limitations will expire if these procedures are followed. |
| Rev. Proc. 2005-18(PDF, 95K) |
IRB #2005-13(HTML) |
March 28, 2005 |
| Making a deposit to suspend the running of interest under section 6601 on a potential underpayment of tax: This document provides procedures for making, withdrawing, or otherwise identifying deposits under new section 6603 of the Code to suspend the running of interest under section 6601 on potential underpayments of tax. Section 6603 was added to the Code by the American Jobs Creation Act of 2004. The procedure also invites comments from the public regarding rules and standards relating to new section 6603. Rev. Proc. 84-58 superseded. |
| Rev. Proc. 2005-17(PDF, 82K) |
IRB #2005-13(HTML) |
March 28, 2005 |
| Automatic consent to change a method of accounting: This procedure modifies Rev. Proc. 2005-9 to waive the 5-year prior change scope limitation for taxpayers seeking the Commissioner’s automatic consent to change a method of accounting for the costs of acquiring or creating intangibles. Rev. Proc. 2005-9 modified. |
| Rev. Proc. 2005-12(PDF, 117K) |
IRB #2005-2(HTML) |
January 10, 2005 |
| Entering into an LMSB Pre-Filing Agreement (PFA): This procedure permits a taxpayer under the jurisdiction of the Large and Mid-Size Business Division (LMSB) to enter into an LMSB Pre-Filing Agreement (PFA), an agreement that determines certain issues before the taxpayer files any return relating to those issues. This procedure expands the scope of the current PFA program. Rev. Proc. 2001-22 superseded. |
| Rev. Proc. 2005-9(PDF, 74K) |
IRB #2005-2(HTML) |
January 10, 2005 |
| Automatic consent to change to a method of accounting: This document provides administrative procedures under which a taxpayer may obtain automatic consent to change to a method of accounting provided in sections 1.263(a)-4, 1.263(a)-5, and 1.167(a)-3(b) of the regulations for the taxpayer's second taxable year ending on or after December 31, 2003. Rev. Proc. 2002-9 modified and amplified. |
| Rev. Rul. 2005-59(HTML) |
IRB #2005-37(HTML) |
September 12, 2005 |
| Section 6020 of the Code: This ruling clarifies when documents prepared or executed by the Secretary under section 6020 of the Code, or waivers on assessment constitute valid returns under Beard v. Commissioner, 82 T.C. 766 (1984), aff'd, 793 F.2d 139 (6th Cir. 1986), for purposes of the election to file a joint return under section 6013. Rev. Rul. 74-203 revoked. |
| Rev. Rul. 2005-51(HTML) |
IRB #2005-31(HTML) |
August 1, 2005 |
| Math Error - Section 6213(b) of the Code: This ruling clarifies whether the mathematical or clerical error assessment procedures of section 6213(b) of the Code apply when a taxpayer files an income tax return that reports income in an amount different from that reported on a W-2. |
| Rev. Rul. 2005-50(HTML) |
IRB #2005-30(HTML) |
July 25, 2005 |
| Discharge of property; refund action. This ruling clarifies that, in light of amendments to sections 6325 and 7426 of the Code made by the IRS Restructuring and Reform Act of 1998, a person not liable for the underlying tax may not file a refund action under the holding of United States v. Williams, 514 U.S. 527 (1995). |
| Rev. Rul. 2005-49(HTML) |
IRB #2005-30(HTML) |
July 25, 2005 |
| Judicial remedy for wrongful levies. This ruling clarifies that a wrongful levy action under section 7426 of the Code is the only remedy available to a third person whose property was levied to satisfy the tax debt of another. |
| Rev. Rul. 2005-9(PDF, 41K) |
IRB #2005-6(HTML) |
February 7, 2005 |
| Bankruptcy cases; definition of "pending". This ruling discusses the definition of "pending" regarding bankruptcy cases for purposes of the relief from the imposition of certain penalties provided under section 6658 of the Code. |
| Rev. Rul. 2005-4(PDF, 76K) |
IRB #2005-4(HTML) |
January 24, 2005 |
| Interest suspension; time sensitive penalties. Section 6404(g) of the Code suspends interest and time sensitive penalties, additions to tax and additional amounts with respect to an increased tax liability reported on an individual's amended income tax return filed more than 18 months after the date that is the later of (1) the original due date of the return (without regard to extensions) or (2) the date on which the taxpayer timely filed the return. |
