2006 Internal Revenue Bulletin Documents Pertaining to IRS Procedures

These are documents issued in IRS's weekly Internal Revenue Bulletin (IRB) that pertain to IRS procedures.

Most documents are in HTML but some may be in the Adobe Acrobat PDF format. Internal Revenue Bulletin Summary pages are in HTML format.

Document	Bulletin	Date of IRB


T.D. 9285(HTML)	IRB #2006-41(HTML)	October 10, 2006
Final regulations under section 448 of the Code provide rules relating to the use of a nonaccrual-experience method of accounting by taxpayers using an accrual method of accounting and performing services. The regulations affect qualifying taxpayers that want to adopt, change to, or change a nonaccrualexperience method of accounting under section 448(d)(5).
Notice 2006-83(HTML)	IRB #2006-40(HTML)	October 2, 2006
This notice provides guidance to individual chapter 11 debtors and their bankruptcy estates regarding the tax treatment of post-petition income as the result of the enactment of section 1115 of the Bankruptcy Code by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. The notice also alerts information return preparers regarding their reporting responsibilities.
T.D. 9284(HTML)	IRB #2006-40(HTML)	October 2, 2006
Final regulations under section 6502 of the Code incorporate changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS's ability to enter into agreements extending the statute of limitations for collection.
Rev. Proc. 2006-37(HTML)	IRB #2006-38(HTML)	Sept. 18, 2006
This procedure modifies Rev. Proc. 2006-12, 2006-3 I.R.B. 310, to allow a taxpayer to utilize the advance consent procedures of Rev. Proc. 97-27, as modified and amplified by Rev. Proc. 2002-19, as amplified and clarified by Rev. Proc. 2002-54, when seeking a change to a method of accounting provided in regulations sections 1.263(a)-4, 1.263(a)-5, or 1.167(a)-3(b) in conjunction with a change for the same item to a method of accounting utilizing the 31/2 month rule authorized by regulations section 1.461-4(d)(6)(ii) or the recurring item exception authorized by regulations section 1.461-5. Rev. Proc. 2006-12 modified.
Rev. Proc. 2006-36(HTML)	IRB #2006-38(HTML)	Sept. 18, 2006
This procedure sets forth the Service's procedures for other government agencies or members of the public to request the creation of special statistical studies and compilations involving return information pursuant to section 6108(b) of the Code, and sets forth the criteria for determining reasonable fees for costs associated with the creation of the special statistical studies and compilations.
Announcement 2006-63(HTML)	IRB #2006-37(HTML)	Sept. 11, 2006
This announcement describes the limited role of private collection agencies (PCAs) in the collection of federal taxes. The announcement includes descriptions of the legal restrictions and administrative procedures in place to ensure PCAs respect taxpayer rights and protections. The announcement also describes what a taxpayer can expect if the IRS assigns the taxpayer's account to a PCA for collection activity.
Announcement 2006-61(HTML)	IRB #2006-36(HTML)	Sept. 5, 2006
This announcement provides an opportunity for small business/ self employed taxpayers to use Fast Track Settlement (FTS) to expedite case resolution within the IRS's Small Business/ Self Employed (SB/SE) organization. The SB/SE FTS will enable SB/SE taxpayers that currently have unagreed issues in at least one open year under examination to work together with SB/SE and the Office of Appeals to resolve outstanding disputed issues while the case is still in SB/SE jurisdiction.
Rev. Rul. 2006-42(HTML)	IRB #2006-35(HTML)	August 28, 2006
Levy on bank account. This ruling explains that a superpriority lien argument is not a defense to a levy. If a bank has such an argument, it must file a wrongful levy suit within nine months of the levy. Otherwise, the statute of limitations bars such a suit.
T.D. 9274(HTML)	IRB #2006-33(HTML)	August 14, 2006
Final regulations under section 6103 of the Code describe the circumstances under which IRS and the Office of Treasury Inspector General for Tax Administration (TIGTA) employees may disclose return information for investigative purposes. The regulations clarify and elaborate on the types of situations and contexts in which investigative disclosures may be made.
Notice 2006-68(HTML)	IRB #2006-31(HTML)	July 31, 2006
This notice alerts taxpayers who submit offers in compromise on or after July 16, 2006, that they must include a nonrefundable down payment with their offers. The notice also waives the down payment requirement for low-income taxpayers and taxpayers who submit offers based solely on doubt as to liability. July 31, 2006 2006-31 I.R.B.
Notice 2006-63(HTML)	IRB #2006-29(HTML)	July 17, 2006
This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the notice seeks comments regarding any burdens associated with the record retention requirements that apply to issuers and other parties to tax-exempt bond transactions in order to substantiate compliance with section 103 of the Code. Comments should be received by October 16, 2006.
T.D. 9264(HTML)	IRB #2006-26(HTML)	June 26, 2006
Final, temporary, and proposed regulations under section 1502 of the Code and others simplify, clarify, or eliminate taxpayer reporting burdens. They also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
Rev. Proc 2006-24(HTML)	IRB #2006-22(HTML)	May 30, 2006
This procedure informs the trustee (or debtor in possession) representing the bankruptcy estate of the debtor of the procedure to be followed in obtaining a prompt determination by the Service of any unpaid tax liability of the estate incurred during the administration of the case. Rev. Proc. 81-17 obsoleted.
Rev. Proc 2006-26(HTML)	IRB #2006-21(HTML)	May 22, 2006
This procedure announces the introduction of user fees for requests submitted to the U.S. competent authority for discretionary determinations under limitation on benefits provisions of U.S. income tax treaties. Rev. Proc. 2002-52 modified.
T.D. 9253(HTML)	IRB #2006-14(HTML)	April 3, 2006
The Treasury Department and the IRS issued comprehensive withholding and reporting regulations (T.D. 8734 and T.D. 8881) that became effective on January 1, 2001. In Notice 2001-4, 2001-1 C.B. 267; Notice 2001-11, 2001-1 C.B. 464; and Notice 2001-43, 2001-2 C.B. 72; the Treasury Department and the IRS announced the intention to amend the final regulations. These final regulations implement certain changes announced in those notices and other changes. In addition, these final regulations provide guidance under section 411 of the American Jobs Act of 2004. Notice 2001-11 and certain sections of Notices 2001-4 and 2001-43 superseded.
T.D. 9245(HTML)	IRB #2006-14(HTML)	April 3, 2006
Final regulations under section 6103(j) of the Code incorporate and clarify the phrase "return information reflected on returns" in conformance with the terms of section 6103(j)(5), which provides for limited disclosures of returns and return information in connection with the census of agriculture.
Rev. Rul. 2006-16(HTML)	IRB #2006-14(HTML)	April 3, 2006
Joint and several liability; relief under section 6015. This ruling discusses the issue of whether a taxpayer is precluded from raising a request for relief from joint and several liability under section 6015 by virtue of a previous Chapter 7 bankruptcy case in which the Service filed a proof of claim, but the bankruptcy court did not make an actual determination of tax liability.
Court Decision 2081(HTML)	IRB #2006-13(HTML)	March 27, 2006
IRA assets; bankruptcy estate. The Supreme Court holds that a taxpayer can exempt IRA assets from the bankruptcy estate because the IRAs fulfill both of the Bankruptcy Code section 522(d)(10)(E) requirements at issue here-they confer a right to receive payment on account of age, and they are similar plans or contracts to those enumerated in section 522(d)(10)(E). Rousey, et ux., v. Jacoway.
Court Decision 2082(HTML)	IRB #2006-14(HTML)	April 3, 2006
Sale of seized real property by IRS; federal tax delinquency. The Supreme Court holds that the national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal-question jurisdiction over the disputed issue on removal. Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing.
T.D. 9252(HTML)	IRB #2006-12(HTML)	March 20, 2006
Temporary and proposed regulations under section 6103 of the code are provided regarding administrative review procedures for certain government agencies and other authorized recipients of tax returns or return information (authorized recipients) whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards. The regulations provide guidance to responsible irs personnel and authorized recipients as to these administrative procedures.
Notice 2006-23(HTML)	IRB #2006-11(HTML)	March 13, 2006
Because Patriot’s Day falls on Monday, April 17, this notice provides individual taxpayers residing in Maine, Maryland, Massachusetts, New Hampshire, New York, Vermont, and the District of Columbia an additional day to file their federal income tax returns and make their payments (until April 18, 2006). This includes the payment of the first installment of estimated tax for 2007.
Notice 2006-13(HTML)	IRB #2006-08(HTML)	February 21, 2006
This notice announces that the IRS and Treasury intend to issue final regulations under section 1503(d) of the Code to provide that a reasonable cause standard similar to proposed regulations section 1.1503(d)-1(c)(1) will apply to cure all late filings under section 1503(d). Prior to issuance of those regulations, taxpayers may rely on the reasonable cause procedure set forth in proposed regulations section 1.1503(d)-1(c)(1), as modified by this notice, to cure late filings under the current regulations. Additionally, until the final regulations are issued, taxpayers may choose to apply for relief for untimely section 1503(d) filings under the provisions of regulations sections 301.9100-1 through 301.9100-3 or elect to use the reasonable cause standard set forth in the proposed regulations as modified by this notice.
Notice 2006-12(HTML)	IRB #2006-07(HTML)	February 13, 2006
This notice supplements the relief previously granted by the IRS with respect to taxpayers affected by Hurricanes Katrina and Rita. It provides relief from certain backup withholding obligations under section 3406 of the Code due to notification that a payee’s taxpayer identification number is incorrect. Pursuant to the authority of section 7508A, the IRS postpones the time for certain payors to send notices to payees, and to begin imposing backup withholding on reportable payments to such payees.
T.D. 9239(HTML)	IRB #2006-06(HTML)	February 6, 2006
Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance Contributions Act (FICA) and returns of income tax withheld. The regulations require employers who receive notification of qualification for the Employers’ Annual Federal Tax Program (Form 944) to file Form 944, Employer’s Annual Federal Tax Return, annually instead of Form 941, Employer’s Quarterly Federal Tax Return, quarterly beginning in the 2006 taxable year. The regulations also permit most employers who file Form 944 to remit accumulated employment taxes annually with their return and modify the lookback period and de minimis deposit rule for these employers. The proposed regulations also provide an additional method for quarterly return filers to determine whether the amount of accumulated employment taxes is considered de minimis. A public hearing on the proposed regulations is scheduled for April 26, 2006.
Announcement 2006-10(HTML)	IRB #2006-05(HTML)	January 30, 2006
This document provides notice of a public hearing on proposed regulations (REG-131739-03, 2005-36 I.R.B. 494) relating to the IRS preparing or executing returns for persons who fail to make required returns. The hearing is scheduled for March 8, 2006.
Rev. Proc. 2006-11(HTML)	IRB #2006-03(HTML)	January 17, 2006
Simplified service cost and simplified production method change procedures. This document provides procedures under which a taxpayer may use either the advance consent procedures of Rev. Proc. 97-27 or the automatic consent procedures of Rev. Proc. 2002-9 to request a change in method of accounting to comply with section 1.263A-1T or 1.263A-2T for the taxpayer’s first taxable year ending on or after August 2, 2005. Rev. Procs. 97-27 and 2002-9 modified.
Rev. Proc. 2006-10(HTML)	IRB #2006-20(HTML)	January 9, 2006
This procedure supersedes Rev. Proc. 96-52, 1996-2 C.B. 372. It describes the qualifications necessary to become an acceptance agent and the procedures that an acceptance agent applicant must follow for purposes of entering into an acceptance agent agreement with the IRS. Rev. Proc. 96-52 superseded.
Rev. Proc. 2006-09(HTML)	IRB #2006-02(HTML)	January 9, 2006
This procedure explains the manner in which taxpayers may request an advance pricing agreement (APA) from the APA Program within the Office of the Associate Chief Counsel (International), the manner in which such a request will be processed by the APA Program, and the effect and administration of APAs. Rev. Proc. 2004-40 superseded.
Rev. Proc. 2006-08(HTML)	IRB #2006-01(HTML)	January 3, 2006
User fees for employee plans and exempt organizations. Up-to-date guidance for complying with the user fee program of the Service as it pertains to requests for letter rulings, determination letters, etc., on matters under the jurisdiction of the Office of the Division Commissioner, Tax Exempt and Government Entities, is provided. Rev. Proc. 2005-8 superseded.
Rev. Proc. 2006-07(HTML)	IRB #2006-01(HTML)	January 3, 2006
Areas in which rulings will not be issued; Associate Chief Counsel (International). This procedure revises the list of those provisions of the Code under the jurisdiction of the Associate Chief Counsel (International) relating to matters where the Service will not issue rulings or determination letters. Rev. Proc. 2005-7 superseded.
Rev. Proc. 2006-06(HTML)	IRB #2006-01(HTML)	January 3, 2006
Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409, and 4975 of the Code. Rev. Proc. 2005-6 superseded.
Rev. Proc. 2006-05(HTML)	IRB #2006-01(HTML)	January 3, 2006
Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals offices by the Office of the Division Commissioner, Tax Exempt and Government Entities, regarding issues in the employee plans area (including actuarial matters) and in the exempt organizations area. Rev. Proc. 2005-5 superseded.
Rev. Proc. 2006-04(HTML)	IRB #2006-01(HTML)	January 3, 2006
Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters related to sections of the Code currently under the jurisdiction of the Office of the Division Commissioner, Tax Exempt and Government Entities. Rev. Proc. 2005-4 superseded.
Rev. Proc. 2006-03(HTML)	IRB #2006-01(HTML)	January 3, 2006
Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of the Associates Chief Counsel (Corporate, Financial Institutions and Products, Income Tax and Accounting, Passthroughs and Special Industries, and Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) relating to matters on which the Service will not issue rulings or determination letters. Rev. Procs. 2005-3, 2005-61, and 2005-68 superseded.
Rev. Proc. 2006-02(HTML)	IRB #2006-01(HTML)	January 3, 2006
Technical advice and technical expedited advice. This procedure explains when and how the Associate Chief Counsel (Corporate), Associate Chief Counsel (Financial Institutions and Products), Associate Chief Counsel (Income Tax and Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs and Special Industries), Associate Chief Counsel (Procedure and Administration), and Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) issue technical advice memoranda (TAMs) and technical expedited advice memoranda (TEAMs) to a director or an appeals area director. It also explains the rights a taxpayer has when a field office requests technical advice or technical expedited advice regarding a tax matter. Rev. Proc 2005-2 superseded.
Rev. Proc. 2006-01(HTML)	IRB #2006-01(HTML)	January 3, 2006
Letter rulings, information letters and determination letters. This procedure contains revised procedures for letter rulings and information letters issued by the Associate Chief Counsel (Corporate), Associate Chief Counsel (Financial Institutions and Products), Associate Chief Counsel (Income Tax and Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs and Special Industries), Associate Chief Counsel (Procedure and Administration), and Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). This procedure also contains revised procedures for determination letters issued by the Large and Mid-Size Business Division, Small Business/Self-Employed Division, Wage and Investment Division, and Tax Exempt and Government Entities Division. Rev. Procs. 2005-1 and 2005-68 superseded. Section 10 of Rev. Proc. 2005-12 modified and superseded.

Regulation	Bulletin	Cross-Ref	Date of IRB

REG-148576-05(HTML)	IRB #2006-40(HTML)	N/A	October 2, 2006
Proposed regulations under 31 USC 9701 increase the amount of the user fees imposed under regulations sections 300.1 and 300.2 for entering into and restructuring or reinstating installment agreements. The regulations bring the fees in line with the actual costs to the IRS. Currently, the IRS charges $43 for entering into an installment agreement and $24 for restructuring or reinstating an installment agreement that is in default. The IRS recently completed a review of the installment agreement program and determined that the full cost of an installment agreement is $105, and the full cost of restructuring or reinstating an installment agreement is $45. The regulations reflect these costs, with one exception; the fee for entering into an installment agreement paid by way of a direct debit from the taxpayer's checking account will be $52, to encourage this type of payment arrangement. A public hearing is scheduled for October 17, 2006.
REG-145154-05(HTML)	IRB #2006-39(HTML)	N/A	Sept. 25, 2006
Proposed regulations under 31 USC 9701 implement new user fees for the Special Enrollment Examination (SEE) for enrolled agents, the application for enrollment of enrolled agents, and the renewal of such enrollment. The user fee that the IRS currently charges applicants in order to take the SEE is being modified to reflect the change in the IRS costs of administering the exam program as a result of the contracting out of the exam. The regulations establish an $11 per applicant user fee for the SEE and separate $125 user fees for the enrollment and renewal of enrollment process. A public hearing is scheduled for September 29, 2006.
REG-134317-05(HTML)	IRB #2006-26(HTML)	T.D. 9264	June 26, 2006
Final, temporary, and proposed regulations under section 1502 of the Code and others simplify, clarify, or eliminate taxpayer reporting burdens. They also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
REG-157271-05(HTML)	IRB #2006-12(HTML)	T.D. 9252	March 20, 2006
Temporary and proposed regulations under section 6103 of the code are provided regarding administrative review procedures for certain government agencies and other authorized recipients of tax returns or return information (authorized recipients) whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards. The regulations provide guidance to responsible irs personnel and authorized recipients as to these administrative procedures.
REG-122380-02(HTML)	IRB #2006-10(HTML)	N/A	March 6, 2006
Proposed regulations under section 330 of title 31 of the U.S. Code provide proposed amendments to the provisions of Circular 230 relating to various non-shelter items. This document proposes amendments reflecting the Treasury Department and the IRS consideration of the comments received in response to the 2002 advance notice of proposed rulemaking and reflecting amendments to section 330 of title 31 made by the American Jobs Creation Act of 2004. The regulations also include conforming amendments to reflect the final regulations relating to best practices, covered opinions and other written advice published as T.D. 9165, 2005-4 I.R.B. 357, and as T.D. 9201, 2005-23 I.R.B. 1153, but do not otherwise address those final regulations. A public hearing is scheduled for June 21, 2006.
REG-148568-04(HTML)	IRB #2006-06(HTML)	T.D. 9239	February 6, 2006
Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance Contributions Act (FICA) and returns of income tax withheld. The regulations require employers who receive notification of qualification for the Employers' Annual Federal Tax Program (Form 944) to file Form 944, Employer's Annual Federal Tax Return, annually instead of Form 941, Employer's Quarterly Federal Tax Return, quarterly beginning in the 2006 taxable year. The regulations also permit most employers who file Form 944 to remit accumulated employment taxes annually with their return and modify the lookback period and de minimis deposit rule for these employers. The proposed regulations also provide an additional method for quarterly return filers to determine whether the amount of accumulated employment taxes is considered de minimis. A public hearing on the proposed regulations is scheduled for April 26, 2006.
REG-137243-02(HTML)	IRB #2006-03(HTML)	N/A	January 17, 2006
Proposed regulations under section 7216 of the Code update the rules regarding the disclosure and use of tax return information by tax return preparers. The regulations announce new and additional rules for taxpayers to consent electronically to the disclosure or use of their tax return information by tax return preparers. The proposed rules provide guidelines for tax return preparers using or disclosing information obtained in the process of preparing income

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2006 IRB Documents Pertaining to IRS Procedures

2006 IRB Documents
Pertaining to IRS Procedures