Internal Revenue Bulletin: 2005-24
June 13, 2005
Proposed regulations under section 475 of the Code set forth an elective safe harbor for dealers in securities and/or commodities and traders in securities and commodities that permits these taxpayers to make an election pursuant to which the values of the positions reported on certain financial statements are the fair market values of those positions. The safe harbor is based upon the principle that if the mark-to-market method used for financial reporting is sufficiently consistent with the mark-to-market method required by section 475, then the values used for financial reporting should be acceptable values for purposes of section 475, even if those values are not fair market values under general tax principles. To ensure minimal divergence from fair market values under tax principles, the regulations impose certain restrictions on the financial accounting methods and statements that are eligible for the safe harbor and may require certain adjustments to values used in the safe harbor. This safe harbor attempts to reduce the compliance burden upon taxpayers and to improve the administrability of valuations for the IRS. A public hearing is scheduled for September 15, 2005.
This procedure provides guidance on exhausting administrative remedies prior to seeking a declaratory judgment pursuant to section 7479 of the Code.
This procedure sets forth updated procedures for appeals of proposed trust fund recovery penalty assessments arising under section 6672 of the Code. The procedures apply to trust fund recovery penalty cases relating to employment and excise taxes imposed under the Code, except when collection is in jeopardy. Rev. Proc. 84-78 superseded.
This announcement contains the annual report concerning the Pre-Filing Agreement program of the Large and Mid-Size Business Division of the Service for Calendar Year 2004.
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