Internal Revenue Bulletin: 2009-3 |
January 21, 2009 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
- T.D. 9436
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Summary of Comments and Explanation of Revisions
- Furnishing of Copy of the Tax Return and Retaining Copy
- Furnishing Identification Number
- Defining the Preparer Within a Firm
- Reliance on Information Provided
- Use of Estimates
- Income Derived Determination in Computing Penalty Amount
- Firm Liability
- Reasonable to Believe That More Likely Than Not
- Adequate Disclosure
- Reasonable Cause
- Burden of Proof
- Negotiation of Check
- Due Diligence for Earned Income Credit
- Definition of Tax Return Preparer
- List of Returns Subject to Penalty
- Appraisers
- Disclosure Under Section 6103
- Appeal Rights
- Applicability Dates
- Availability of IRS Documents
- Effect on Other Documents
- Special Analyses
- Adoption of Amendments to the Regulations
- PART 1—INCOME TAXES
- PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954
- PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954
- PART 26—GENERATION-SKIPPING TRANSFER TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1986
- PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT THE SOURCE
- PART 40—EXCISE TAX PROCEDURAL REGULATIONS
- PART 41—EXCISE TAX ON USE OF CERTAIN HIGHWAY MOTOR VEHICLES
- PART 44—TAXES ON WAGERING; EFFECTIVE JANUARY 1, 1955
- PART 53—FOUNDATION AND SIMILAR EXCISE TAXES
- PART 54—PENSION EXCISE TAXES
- PART 55—EXCISE TAX ON REAL ESTATE INVESTMENT TRUSTS AND REGULATED INVESTMENT COMPANIES
- PART 56—PUBLIC CHARITY EXCISE TAXES
- PART 156—EXCISE TAX ON GREENMAIL
- PART 157—EXCISE TAX ON STRUCTURED SETTLEMENT FACTORING TRANSACTIONS
- PART 301—PROCEDURE AND ADMINISTRATION
- PART 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
- Drafting Information
- T.D. 9436
- Part III. Administrative, Procedural, and Miscellaneous
- Notice 2009-5
- Notice 2009-6
- Notice 2009-7
- Rev. Proc. 2009-11
- Rev. Proc. 2009-12
- Rev. Proc. 2009-13
- Rev. Proc. 2009-14
- SECTION 1. PURPOSE
- SECTION 2. BACKGROUND
- SECTION 3. SCOPE
- .01 Eligible taxpayers.
- .02 Eligible taxable years.
- .03 Eligible issues generally.
- .04 Relationship of eligible issues to eligible taxable years.
- .05 Eligible domestic and eligible international issues require coordination and consultation with Associate Chief Counsel.
- .06 Eligible international issues requiring Associate Chief Counsel (International) concurrence in execution.
- .07 Special provisions for requests on international issues.
- .08 Excluded issues.
- .10 Definition of taxpayer.
- SECTION 4. REQUESTING A PRE-FILING AGREEMENT
- SECTION 5. SELECTING TAXPAYERS FOR THE PFA PROGRAM
- SECTION 6. PROCESSING A REQUEST FOR A PFA
- SECTION 7. NATURE AND EFFECT OF A PFA
- SECTION 8. WITHDRAWAL
- SECTION 9. NO PFA EXECUTED
- SECTION 10. USER FEE
- SECTION 11. DISCLOSURE
- SECTION 12. EFFECTIVE DATE AND DURATION OF PROCEDURE
- SECTION 13. EFFECT ON OTHER DOCUMENTS
- SECTION 14. RECORDKEEPING REQUIREMENTS
- SECTION 15. PAPERWORK REDUCTION ACT
- SECTION 16. DRAFTING INFORMATION
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
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