IRS tightens abusive tax shelter settlement terms.

• Position: National

Tightened guidelines may make it more difficult for taxpayers involved in abusive transactions to settle with the IRS.

In September, the IRS Appeals Division and the Large and Mid-Size Business Division began sending letters to taxpayers involved in three abusive transactions, advising them that the settlement terms available to resolve these transactions have changed. Certain taxpayers who reported losses and deductions from lease strips, inflated-basis assets derived from lease strips, and in intermediary transactions are being notified that the Appeals position has tightened.

Under the new guidelines, the IRS will not settle unless taxpayers concede 100 percent of the claimed losses or deductions, reduced by only the amount of...