Month: February 2010

Editor's Notebook Transcripts (ABA EO Committee)

EO Tax Journal 2010-33

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1 — Personal Recollections (feel free to skip)

I confess — I read the obituary page of the Baltimore Sun. Octogenarian Louis E. Queral died on February 24. As a kid, I knew Louis was an M.D. from his framed diplomas when I visited his son, Luis. His son enrolled in my grade school in 1959 as a seventh grader, shortly after his family had emigrated from Cuba. Apparently Luis’ family was on good terms with Fidel Castro, despite leaving Cuba. When Castro came to the United States — I recall to speak at the United Nations in 1960 — Luis’ family was there to greet him and Luis came back with a photo of him with a beaming Fidel. At that time the great debate was whether Castro was a Communist. While my grade school classmates were generally apolitical, we had a few big mouths who, finding that Luis defended Castro, would berate him during recess, yelling that Castro was a Communist and that anyone defending him must be a Communist, too. Luis got his revenge a few years later, when all the girls in the neighborhood decided Luis was hot — think a young Ricky Ricardo (Desi Arnaz).

Transcripts (Other)

EO Tax Journal 2010-30

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As promised, here’s a transcript of Sarah Hall Ingram’s February 5 remarks. Sarah continues the tradition of the TE/GE Commissioner (and before that, the AC (EP/EO) being primarily an Employee Plans person. I think that reflects the fact that Exempt Organizations is #2 in the TE/GE hierarchy. I guess that’s better than being #3 (Government Entities).

Current & Quotable Editor's Notebook

EO Tax Journal 2010-29

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God willing and the Creek don’t rise, I should have a transcript of Sarah Hall Ingram’s February 5 remarks in the next day or two. Speaking of Sarah and her domain, I think most people are coming around to the reality that we have a serious problem with charity regulation in this country. Now everyone is trying to come up with solutions, which is good, but most of the proposed solutions seem to me to come with their own problems. In this vein, The Chronicle of Philanthropy had two interesting viewpoint articles in its February 25 issue.

Current News and Developments

EO Tax Journal 2010-28

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1 – Old Business

In regard to Wednesday’s email update item on “Owens Protests Denial of Technical Advice,” Marc reported yesterday that he has received a favorable response to his February 15 letter to Diane Ryan, Chief, IRS Appeals, in which he sought technical advice over the objections of IRS case workers.

Transcripts (Other)

EO Tax Journal 2010-27

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As promised yesterday, here’s Cindy, Bobby, and Rob, with a cameo appearance by Sarah Hall Ingram.

IRS Trio Address Current EO Concerns

What follows are the February 5 remarks of the IRS’ Rob Choi, Director, EO Rulings & Agreements, Washington, Cindy Thomas, Manager, EO Determinations, Cincinnati, and Bobby Zarin, Director, Customer Education & Outreach, Washington, as delivered at the annual Joint Meeting of TE/GE Area Councils in Baltimore.

Focus on IRS and Treasury

EO Tax Journal 2010-26

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Marc Owens, in a recent letter, reprinted below, is protesting a denial by the IRS Office of Appeals of his request for technical advice. Hey, the IRS already did its technical advice for the year (TAM 201005061). Two TAMs in one year? That’s asking a lot.

Editor's Notebook Focus on Courts

EO Tax Journal 2010-25

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1 – Old Business

Eve Borenstein weighs in on retroactive revocations.

2 – On the Road to Certiorari?

For most of us, we just want to know when it’s over. The latest step in the long-running medical residents saga is now a petition for certiorari, reprinted below. Normally I’d call this a slam dunk, as Ted Olson’s pals on the Supreme Court would say come on in, but now that Ted is advocating for same-sex marriages, is he persona non grata? Unfortunately, on such considerations is the law of the land decided.
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Focus on IRS and Treasury

EO Tax Journal 2010-24

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For those of you who live and die the Form 990, you probably spent the weekend studying the revised 2009 Form 990, schedules and instructions, posted last week by the IRS. For the rest of us, it’s more a matter of what we care about. What struck my fancy were two statements in the IRS announcement of significant changes, reprinted in its entirety below.

Current News and Developments Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 201-23

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Monday’s email update on excerpts from Sarah Hall Ingram’s Feb. 5 remarks has drawn comments.

Former EO Branch Chief Connie Rosenberg had this to say:

“I think Sarah’s answer to the question about Service failure to publish formal guidance was quite truthful, if you parse it out carefully. What she said, in effect, was: we can’t figure out how to get publications out because we, collectively, can’t figure out how to stop tripping over each other. As Winston Churchill once said (whenever I’m not sure who said something, I always cite Churchill, and I’m usually right): the way to begin is to begin. The way to stop tripping over each other is to stop tripping over each other. Set up a formal procedure for initiating and clearing a publication; follow that procedure; establish due dates for movement at each stage of the process; appoint a high-ranking management official to monitor the due dates and insist that they be met, and provide consequences for the bureaucrat who fails to meet them; be prepared to deal with the consequences of actually making a decision. Those things are the jobs of management. It ain’t rocket science now, any more than it was 25 years ago, but it does take some guts.”

Transcripts (ABA EO Committee)

EO Tax Journal 2010-22

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William Wilkins, Chief Counsel of the Internal Revenue Service, was the luncheon speaker at the January 22 meeting of the EO Committee of the ABA’s Tax Section. Kudos to Bill for not making any “I hope I don’t give you indigestion” jokes. It was funny the first time I heard an IRS speaker use that line, but it’s getting old. Speaking of getting old, when will the last panel of the day no longer be introduced as “the only thing standing between you and the cash bar?”

Focus on IRS and Treasury Transcripts (ABA EO Committee)

EO Tax Journal 2010-21

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The use of gmail seems to be working. I’ll continue to use it this week and, if successful, get back to replacing the lost emails caused by AOL. The next issue of the print issue of theEO Tax Journal will have all the email updates, so that may be the answer for those who receive it. I’ll keep you posted as we try to get past this latest snafu.

Current & Quotable Editor's Notebook

EO Tax Journal 2010-19

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If this transmission is successful, I have in the wings (sorry for the redundancy) a transcript of the recent ABA panel on supporting organizations ready to go. I suspect a lot of people would like to read what was discussed in Texas with Emily Lam and Phil Hackney, so we’ll see. Hopefully you received the panel discussion on News from the IRS and Treasury, sent on Monday.