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George Hani Comments on New IRS Directive for Tax Audit Information Gathering in Law360

Subtitle
"Federal Tax Regulations to Watch in 2014"

Law360

George Hani commented on changing federal tax regulations for 2014, specifically the Internal Revenue Service (IRS) directive, scheduled to go live on January 2, seeking to streamline the information-gathering process in tax audits. According to Hani, information document requests (IDRs) became ineffective as taxpayers would often miss their deadlines with little consequence. Under the new directive, taxpayers will likely receive summons faster than they would have under the old regime and will have to strictly abide by deadlines. "I think taxpayers are skeptical that tigers will change their stripes and that taxpayers and exam teams will have fruitful discussions before the IDR is issued," he said, adding that the new program could fail under its own weight if a pattern arises where taxpayers are delinquent with their IDRs but submit their documents prior to the summons process being completed. The U.S. Department of Justice will likely not want to file summons for IDRs that will ultimately be fulfilled.