Proposed amendments to the Regulatory Fexibility Act concerning issuance of tax regulations.

October 13, 1999

On October 13, 1999, Tax Executives Institute submitted the following comments to the House of Representatives' Committee on Small Business concerning H.R. 1882, the Small Business Advocacy Review Panel Technical Amendments Act of 1999, which would mandate procedures for the Internal Revenue Service to follow before issuing tax rulings and regulations. The comments, which took the form of a letter from TEI President Charles W. Shewbridge, III to Representatives James M. Talent and Nydia M. Velazquez, respectively the Chairman and Ranking Minority Member of the Committee on Small Business, was prepared under the aegis of the Institute's IRS Administrative Affairs Committee, whose chair is Robert J. McDonough, Jr. of Wang Global, Inc.

Tax Executives Institute is the preeminent association of business tax executives in North America. On behalf of the Institute, I urge Congress to exempt the Internal Revenue Service from the provisions of H.R. 1882, the Small Business Advocacy Review Panel Technical Amendments Act of 1999. After analyzing the legislation, TEI reluctantly concludes that it would adversely affect the rights and interests of taxpayers, including those in the small business community whom the bill is intended to help. More specifically, including the IRS within the scope of H.R. 1882's proposed amendments to the Small Business Regulatory Enforcement Act of 1999 would make government not more but less responsive to the needs of the taxpaying public and hence be counterproductive. Because they would do more harm than good, neither H.R. 1882 nor its Senate counterpart, S. 1156, should be enacted.

Background

Tax Executives Institute was founded in 1944 to provide a voice for the business tax professional -- not the practitioner but the in-house employee who must deal with the intricacies of the tax law and with employees of the Internal Revenue Service on almost a day-to-day basis. Our approximately 5,000 members represent 2,800 of the leading corporations through 52 chapters in the United States, Canada, and Europe. TEI represents a cross-section of the business community, and is dedicated to the development and effective implementation of sound tax policy, to promoting the uniform and equitable enforcement of the tax laws, and to reducing the cost and burden of administration and compliance to the benefit of taxpayers and government alike. To be sure, most members of the Institute work for companies that are too...