TEI responds to OTR notice regarding letter rulings: September 26, 2002.

On September 26, 2002, Tax Executives Institute sent the following letter to the District of Columbia Office of Tax and Revenue regarding their notice on review and revocation of letter rulings. TEI's letter was prepared under the aegis of TEI's State and Local Tax Committee, whose chair is Barbara Barton of Electronic Data Systems Corporation.

**********

On behalf of Tax Executives Institute (TEI), I am writing to request that the Office of Tax and Revenue (OTR) withdraw its notice of July 1, 2002, entitled Recall and Review of OTR Rulings.

As the preeminent association of business tax professionals, TEI has a significant interest in promoting sound tax policy, as well as the fair and efficient administration of the tax laws, at all levels of government. As such, TEI commends OTR for its efforts to "standardize written guidance' and otherwise improve administration of its letter ruling process. OTR's July notice, however, is a step in the wrong direction. A preemptory process requiring all taxpayers to submit to OTR copies of all written guidance by the end of the year or have the guidance revoked is at once overbroad and inconsistent with good tax policy and fair tax administration. Therefore, TEI urges OTR to withdraw the notice.

Background

Tax Executives Institute was established in 1944 to serve the professional needs of business tax professionals. Today, the Institute has 53 chapters in the United States, Canada, and Europe. Our more than 5,300 members are accountants, attorneys, and other business professionals who work for 2,800 of the leading companies in North America and Europe. One of our chapters is located in the Washington, D.C., area, and our membership includes representatives of all major local enterprises. Moreover, many of our non-D.C, based members work for companies with substantial sales or operations in the District of Columbia. As a professional organization, the Institute is firmly dedicated to developing and implementing 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. The Institute is committed to maintaining a system that works--one that builds upon the principle of voluntary compliance and is consistent with sound tax policy, one that taxpayers can comply with, and one in which the state taxing authorities can effectively administer the tax laws without...