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Willard J. De Filipps, CPA
Consultant to Auto Dealer CPAs and Seminar Leader

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8/09/08

 

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The True Identity Revealed ... Part I

From Tax Notes ("Attorneys Seek Parity in Treatment of Reimbursement Plans") ...

      An article appears in the August 22, 2005 issue of Tax Notes about several writers who have submitted comments to the Internal Revenue Service on Tool Reimbursement Plans. In this article, Mr. Joseph DiSciullo (the author) refers to a redacted letter written by an "unidentified writer" that "suggested to the Treasury that some participants in the recent dialogue on Section 62(c) tool reimbursement plans fail to understand the complexity of the topic and should reconsider the issues of technician accountability, recordkeeping, and document retention requirements." 

       Mr. DiSciullo further reports, "The writer warns against sole reliance on 'a per-diem-type of safe harbor approach,' unless it also contains provisions allowing taxpayers to elect a more complete accounting approach to substantiate a larger tax-free reimbursement allowance when justified."  

       This may sound familiar to you.  Good...  It should, especially if you're reading this here.  Want to take a crack at guessing the identity of the "unidentified writer"?  To see some of the research and analysis that underpins the "redacted letter" referred to above, see the June 2005 issue of the Dealer Tax Watch.

       The article and redacted letter are available on the Tax Notes web site - www.tax.org (Doc 2005-1965, 2005 TNT 154-12).

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The True Identity Revealed ... Part II

More From Tax Notes (Letters to the Editor ... "Tool Plan Revenue Ruling Doesn't Say Anything")...

A Letter to the Editor of Tax Notes appears in the September 5, 2005 issue revealing to the readers what we reported here two weeks ago (See "The True Identity Revealed ... Part I").  The Letter (with an attachment) responded to the August 22 article in Tax Notes.  Attached to the letter was an excerpt from the June 2005 issue of the Dealer Tax Watch, which outlined the many areas and questions that the IRS needs to address and/or clarify in order to give taxpayers and their representatives any meaningful guidance with regard to Section 62(c) accountable plans.  

        For more information on the extensive discussion on these plans that appeared in the June 2005 issue of the Dealer Tax Watch, please see here.

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