EO Tax Journal

1 – IRS Phone Numbers

Please toss last Thursday’s list of IRS phone numbers for the enclosed list. A number of the Office of Chief Counsel phone numbers were incorrect, as that office has combined its two former EO branches into one. Now they all have the same phone number, so you can’t possible dial the wrong number!

2 – Section 501(c)(4) Status of Groups Questioned

Will the persistence of Democracy 21 and the Campaign Legal Center pay off? (See their latest letter, reprinted infra.) Will the IRS even look at these suspect 501(c)(4) organizations? Did the regulations make a grievous error in redefining “exclusively” to mean “primarily”? (My answers: probably not, probably not, yes) Continue…

On Tuesday I received a response to my request for a current list of Exempt Organizations (HQ) personnel. If anyone sees any errors or omissions on this list, please let me know. Yesterday I went to the D.C. Bar program on “How the Taxpayer Advocate Can Assist Tax-Exempt Organizations with the IRS,” and I hope to have a transcript of this program in the near future.

IRS National Office Phone Numbers and Email Addresses
September 2011 Continue…

Last week I sent out the EO Subject Matter Directory (Email Update 2010-174) and, before that, the EO Division roster (Email Update 2010-171). In response, I got this missive from an IRS employee:

“Don’t cite my name (just call me T), but your information is outdated. Several of the individuals listed are managers and do not answer questions and others no longer work in EO.”

My response: The roster information is based on a listing of EO Division personnel dated September 7, 2010, sent to me by the IRS in response to a FOIA request. If managers do not answer questions, this is a new development. Unfortunately, my efforts this year to get information from Rob Choi about how the IRS handles practitioner phone calls has been met with overwhelming silence. As far as I can tell, there is no policy. Some folks return phone calls, some don’t. I say call and hope for the best.

Today I’m sending out phone numbers of EO field personnel. Here I’ll agree with T that some percentage of the information is outdated. Getting information out of the IRS about personnel in Determinations and Examinations is very difficult. My choice is to publish nothing or publish what I have. Here I believe something is better than nothing, but don’t expect 100% accuracy — maybe 80% accuracy is what I have. Continue…

Even though the IRS won’t confirm whether or how it will respond to phone calls, the EO Subject Matter Directory is a valuable resource, but those of us who have worked at the IRS know that some practitioners abuse the opportunities presented. Here are six rules of the road that everyone should abide by. Observing these rules might make the IRS folks more willing to return phone calls:

One, don’t call if you haven’t done your homework. It is not the IRS’ job to explain the basic intricacies of a Code section and the accompanying regulations.

Two, don’t expect to get definitive answers. If you’re lucky, someone at the IRS will make suggestions as to how you might proceed or warn you off certain approaches.

Three, do not later tell revenue agents someone at the IRS National Office has approved a course of conduct or a transaction during a telephone call. If you need a ruling, spend the $10,000.

Four, do not shop around among tax law specialists for a better opinion. The folks at the IRS usually become aware of someone going down their phone list.

Five, limit your phone calls. Calling more than once a month is probably too much.

Six, don’t push your weight around if you are a big shot as this often backfires either immediately or in the long run. Continue…

1 – More on EO Compliance

2 – IRS Phone Numbers

Over the next few days, I will be sending out more IRS phone numbers and email addresses, but today I’m resending the EO Division roster that I emailed on October 20. I neglected to add email addresses to go with the phone numbers, so consider this a correction. I’ve also added EO Division Counsel who are located in Washington. Continue…