"Regulations provide that a taxpayer must disclose certain transactions know as "listed transactions" by filing a disclosure statement (Form 8886) with its tax return. A "listed transaction" is a transaction that is the same as or substantially similar to one that the IRS has determined to be a tax avoidance transaction and identified by IRS notice or other form of published guidance. The parties who participate in listed transactions may be required to disclose the transaction as required by the regulations, register the transaction with the IRS, or maintain lists of investors in the transactions and provide the list to the IRS on request."
"This guide was developed to support IRS field personnel in the identification and the consistent development of abusive tax shelter and transaction issues. The guide covers transactions engaged in by all types of taxpayers, including "listed transactions" (known abusive), identified transactions that have not been listed, and emerging transactions."
"It is the policy of the Internal Revenue Service to announce at an early date whether it will follow the holdings in certain cases. An Action on Decision is the document making such an announcement. An Action on Decision will be issued at the discretion of the Service only on unappealed issues decided adverse to the government. Generally, an Action on Decision is issued where its guidance would be helpful to Service personnel working with the same or similar issues. Unlike a Treasury Regulation or a Revenue Ruling, an Action on Decision is not an affirmative statement of Service position. It is not intended to serve as public guidance and may not be cited as precedent.
Actions on Decisions shall be relied upon within the Service only as conclusions applying the law to the facts in the particular case at the time the Action on Decision was issued. Caution should be exercised in extending the recommendation of the Action on Decision to similar cases where the facts are different. Moreover, the recommendation in the Action on Decision may be superseded by new legislation, regulations, rulings, cases, or Actions on Decisions."
"Tax shelters that are determined to be abusive are identified as "listed transactions." Listed transactions require disclosure by participating corporations, individuals, partnerships and trusts, in accordance with Treasury Regulation § 1.6011.4T. Listed transactions, with citations of published guidance, regulations or court cases are accessible from the" list on this page.
Includes general information plus links to additional pages providing information for farmers, foreign nationals, household employers, innocent spouses, overseas taxpayers, retirees/senior
citizens, students, and the self-employed.
IRS response "to some of the more common frivolous "legal" arguments made by individuals and groups who oppose compliance with the federal tax laws. The first section groups these arguments under six general categories, with variations within each category. ... The second section responds to some of the more common frivolous arguments made in collection due process cases brought pursuant to sections 6320 or 6330. ... A final section explains the penalties that the courts may impose on those who pursue tax cases on frivolous grounds." 54 pages.
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