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Recognizing the potential inequity of punishing an entire organization for the transgressions of one or just a few persons, Congress struck a compromise in the TBOR2 by creating an excise tax in Sec.
"The result is what's called a TBOR2 letter that discusses the total compensation package of the executive and how it compares to that of the CEOs of the peer organizations.
27, 71 (1997) (discussing the enactment of TBOR2 and the accompanying new procedural rights of taxpayers).
The substantive role of the taxpayer advocate is the result of the more recent expansion of the powers and responsibilities of the NTA by the 1996 passage of TBOR2 and the 1998 TBOR3.
Changes in TBOR2, providing that District Counsel now only has to review offers with liabilities exceeding $50,000, will also decrease the amount of processing time.
TBOR2 requires that the IRS establish new procedures for independent administrative review of terminated installment agreements.
TBOR2 requires that the Department of Treasury analyze changes in the "joint and several liability" standard and recommend specific legislative and administrative remedies.
7430 changes made by the TBOR2, which shifts the burden of proof of whether the Service's position was substantially justified from the taxpayer to the IRS.
The TBOR2 also gave the Tax Court the jurisdiction to consider the issue of the IRS's failure to use its discretionary authority to abate interest, effective for requests for abatement after July 30, 1996.
After Cozean initiated this Tax Court proceeding, the rate of fees was increased to $110 per hour by the TBOR2, effective for proceedings commenced after July 30, 1996.
The TBOR2 House Committee Report(2) incorporates a rebuttable presumption of reasonableness for a compensation arrangement approved by an independent board or committee that (1) was composed entirely of individuals unrelated to A not subject to the control of the disqualified person, (2) relied on independent, comparable data in approving the transaction and (3) adequately documented its determination.
A follow-up Taxpayer Bill of Rights 2 (TBOR2) was enacted on July 30, 1996.
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