Don't Mess With Taxes

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Did the just-completed main tax-filing season leaving you wanting to give the Internal Revenue Service a piece of your mind? You're in luck.

The Treasury Department's Office of Tax Policy and the IRS formulate an annual Priority Guidance Plan to help the agencies focus their resources on issues that are most important to taxpayers and tax administration.

And each year, Treasury and IRS ask all us taxpayers to let them what we think they should concentrate on during the plan's time frame.

Calling all taxpayers: That invitation was issued today as IRS Notice 2022-21, which will be formally published in the May 16th Internal Revenue Bulletin. But you don't need to wait for your own personal invite to RSVP with your recommendations on what should be at the top of Treasury's and the IRS' 2022-2023 Priority Guidance Plan.

Technically, you can send your suggestions to Uncle Sam's tax personnel for inclusion in its annual guidance plan at any time during the year. But for your ideas to make into this year's plan time period, which runs July 1, 2022, though June 30, 2023, you must submit it by Friday, June 3.

What the IRS is seeking: OK, despite my opening paragraph's implication, this is not an opportunity to simply blast the IRS. (Like angry taxpayers are waiting for an invitation.)

Rather, say government officials, this annual tax to-do list was created to identify and prioritize the issues that Treasury and IRS should focused on in the coming July-to-June year through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance.

The types of published guidance cited, say tax officials, plays an important role in increasing voluntary taxpayer compliance by helping to clarify ambiguous areas of the tax law.

And that guidance is most successful, according to tax officials, when they get the benefit of the experience and knowledge of taxpayers and practitioners who must apply the rules implementing the tax laws.

Seven top areas: The notice says that in reviewing recommendations and selecting additional projects for inclusion in its 2022-2023 Priority Guidance Plan, Treasury Department and the IRS will consider the following:

1. Whether the recommended guidance resolves significant issues relevant to a broad class of taxpayers;
2. Whether the recommended guidance reduces controversy and lessens the burden on taxpayers or the IRS;
3. Whether the recommended guidance relates to recently enacted legislation;
4. Whether the recommendation involves existing regulations or other guidance that is outdated, unnecessary, ineffective, insufficient, or unnecessarily burdensome and that should be modified, streamlined, expanded, replaced, or withdrawn;
5. Whether the recommended guidance promotes sound tax administration;
6. Whether the IRS can administer the recommended guidance on a uniform basis; and
7. Whether the recommended guidance can be drafted in a manner that will enable taxpayers to easily understand and apply the guidance.

Presentation polishing: You don't have to submit guidance recommendations in any particular format. Treasury and the IRS do ask, however, for taxpayers to briefly describe their suggestions, and explain the need for the guidance. In addition, the agencies wouldn't say no to any taxpayer analysis of how the issue should be resolved.  

For recommendations to modify, streamline, or withdraw existing regulations or other guidance, taxpayers should explain how the changes would reduce taxpayer cost and/or burden or benefit tax administration. 

It would be helpful if taxpayers suggesting more than one guidance project prioritize the projects by order of importance.

And if you suggest a large number of projects, Treasury and IRS would greatly appreciate it if the projects were grouped by subject matter, and then in terms of high, medium, or low priority.

How to submit guidance proposals: Again, you have until June 3 to make recommendations for the upcoming Priority Guidance Plan.

Treasury and IRS encourage interested individuals to submit recommendations electronically via the Federal eRulemaking Portal Regulations.gov. Type IRS-2022-0007 in the search field on the portal's homepage to find Notice 2022-21 and submit recommendations.

If you prefer to snail mail your suggestions, send them to:

Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2022-21) Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044

You also might want to keep this admonition I got from my mother in mind: Don't say anything you don't want others to hear. That's because any recommendations submitted for consideration as part of the Priority Guidance Plan will be available for public inspection and copying in their entirety.

You also might find these items of interest:

• IRS issues 2021-2022 priority guidance plan
• IRS plans to end tax backlog by shifting jobs, hiring 10,000 new staff
• IRS Taxpayer Assistance Centers to open for walk-in help on special Saturdays

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