Comments on IRS's 1993 Business Plan.

On December 1, 1992, Tax Executives Institute filed the following comments with the Internal Reven Treasury Department on projects that should be included in the IRS's 1993 Business Plan. The Institu on guidance in the domestic tax, international tax, administrative, and employee benefits areas, and Commissioner Shirley D. Peterson and Assistant Treasury Secretary Fred T Goldberg, Jr. The Institute submitted under the aegis of its IRS Administrative Affairs Committee, whose chair is W Remi Taylor its International Tax Committee, whose chair is Lisa Norton of the Ingersoll-Rand Co.; its Federal T is David F. Nitschke of Amerada Hess Corporation; and its Employee Benefits Subcommittee, whose chai of Westinghouse Electric Corp.

Transmittal Letter

On October 29, 1992, the Department of the Treasury and the Internal Revenue Service requested comments on projects that should be included in the IRS's 1993 Business Plan. On behalf of Tax Executives Institute, I am pleased to submit the enclosed list of projects that the Institute believes should be given priority in 1993.

TEI commends Treasury and the IRS for undertaking to outline the IRS's agenda for the upcoming year. Mapping out a plan for 1993 constitutes the exercise of good business sense and will provide taxpayers with needed guidance on the IRS's priorities.

I believe it would be helpful to describe the process TEI used to develop the enclosed list of projects for inclusion in the 1993 Business Plan. The Institute circulated the IRS's announcement and a copy of the 1992 Business Plan for comment to its committees that have substantive responsibility for guidance that emanates from the IRS and the Treasury Department. Our committees were asked not only to identify issues on which guidance was needed but to assign a priority to the projects, taking into account the overall reach of the guidance (i.e., the number of taxpayers affected by the guidance) and the importance of the guidance to individual companies (i.e., the number of transactions affected by the guidance). The list of projects, broken down into "A," "B," and "C" groupings, was then reviewed and approved by the Institute's Executive Committee.

Obviously, what one company or industry segment considers to be important may have little or no effect on another company or industry. There are some projects, however, that cut across a broad range of companies. In particular, the Institute would assign the highest priority to the issuance of the "Accelerated Issue Resolution" revenue procedure, the application of the Indopco decision to repairs and maintenance charges (and to other expenses), the guidance on record retention agreements (in the form of a revision to Rev. Proc. 91-59), the guidance on the application of the alternative minimum tax to consolidated groups, the section 6662(e) penalty regulations, and the section 367(a) and (b) regulations.

Tax Executives Institute appreciates this opportunity to present our views on the IRS's 1993 Business Plan. If you have any questions, please do not hesitate to call me at (408) 765-1202.

Note: The following items are grouped as "A," "B," and "C" according to the priority assigned by TEI's members, with the "A" group having the highest priority. Within each group, the items are listed in random order. An "*" denotes an item as listed in the IRS's 1992 Business Plan.

Administrative

"A" GROUP

Coordinated Examination Program

* Revenue procedure on "Accelerated Issue Resolution."

Taxpayer Identification Number

* *Proposed regulations and revenue procedure to establish

a taxpayer identification number (TIN) matching

program to allow a payor to pre-check whether a

name/TIN combination provided by a payee matches

a name/TIN combination in the IRS's records.

Rev. Proc. 91-59

* Guidance on record retention agreements.

* Guidance on electronic data interchange.

Penalties

* Revision of Rev. Proc. 85-26 on disclosure for Coordinated

Examination Program taxpayers to permit the

IRS and taxpayers to agree on the time frame for

submitting adjustments to income.

* Adoption of a...