2010 in review.

Author:McCormally, Timothy J.
Position:Tax law

One of the advantages to waiting until the last minute to write this column is that I've had a chance to read a wide variety of letters from friends and colleagues about what occurred in 2010. Some of the letters relate every event, large or small, important or wholly insignificant, commonplace or unique. Others seem to dwell on the negative, on who died or divorced, who lost their job, who underwent treatment for one form of cancer or another, etc.

The best letters are the ones that hit the high points, accentuate the positive, and strike a balance between news and whimsy. If you are familiar with The Princess Bride, you may recall that its subtitle is "The Good Parts Version." That's what a good holiday letter should be--a good parts version of the year. To be sure, you should not avoid the transcendent events, even if they are unfortunate. (Think of the R.O.U.S.'s--rodents of unusual size--from The Princess Bride.)

January and February

Perhaps the most significant event that occurred early in 2010--perhaps in all of 2010--was the Internal Revenue Service's "game changing" issuance in January of Announcement 2010-9, relating to the required disclosure of uncertain tax positions. More than a few tax professionals considered the IRS initiative to be an R.O.U.S. While by no means enamored with the concept (far from it), TEI's approach was restrained and deliberate. Members of four different Institute committees--Federal, International, IRS Administrative Affairs, and Financial Reporting--set to work on the project, and in the end more members contacted TEI about what became Schedule UTP than any project since the Tax Reform Act of 1986. (TEI's comments on Announcement 2010-9 were filed in May.)

Pages and pages of The Tax Executive have already been devoted to Schedule UTP. Suffice it here to say that while recognizing the validity of the IRS's goal--to make the issue identification and audit selection process more efficient--TEI documented the soundness of the agency's long-time policy of restraint. "Just because the IRS can," TEI essentially argued, "doesn't mean it should." We offered constructive suggestions to the IRS and, happily, it adopted many of them.

January also found TEI President Neff Traubenberg and me in Paris for a meeting of the EMEA Chapter. It was cold and snowy, but the technical program was excellent and as my wife said, "It's still Paris." Speaking of snow, the shortest month of the year brought the eastern seaboard its...

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