This portion of the IRSRRA arose out of complaints of IRS treatment presented during Senate hearings under the leadership of Senator Roth, hearings that have been described as biased and unrepresentative of IRS typical standards of practice by former IRS Commissioner Margaret Milner Richardson.
By way of contrast, IRSRRA provides certain rights, as noted previously, including whistleblower protection and extension of professional privilege.
This is with some justification given the contents of TBR1, TBR2, and particularly IRSRRA are not entirely favorable from the IRS's perspective.
In addition to the impact felt from the diversion of collection resources to other work, the collection workload itself was dramatically affected by the IRSRRA.
Beyond the specific process changes brought about by the IRSRRA in general, Section 1203 caused collections to ebb.
When Congress passed the IRSRRA
'98, however, the right to appeal a rejected OIC became law.
The IRSRRA '98 required the IRS to expand its previously existing program of granting simplified installment agreements for small cases.
The "streamlined" installment agreement is an expanded version of an IRS policy that was in place prior to the IRSRRA '98.
The IRSRRA '98 makes changes concerning extensions of the SOL on collection.
IRSRRA '98, Section 6010(m), clarified the allocation of basis to such properties.
The potential capital gain from the future sale of Capital asset 1 is reduced,(10) exactly the result intended by the IRSRRA '98 clarification.
Example 12: The facts are the same as in Example 11, except that the IRSRRA '98 clarification does not apply.