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Rules Governing Practice before IRS

IIR Issue Selected 12-29-2015

The Internal Revenue Service and the Treasury Department accepted mortgage related requests in December 2015 for guidance under the IRS' Industry Issue Resolution (IIR) program.

Two requests for guidance were received and will be worked together:

  • The first submitted by the Mortgage Bankers Association on reporting requirements under IRC 6050H following a significant modification of a mortgage where the principal amount of the modified mortgage exceeds the principal amount of the pre-modified mortgage.

  • The second submitted by the American Bankers Association on reporting required on a mortgage where accrued but unpaid interest is added to the principal.

The objective of the IIR program is to resolve business tax issues common to significant numbers of taxpayers through new and improved guidance. In past years, issues have been submitted by associations and others representing both small and large business taxpayers, resulting in tax guidance that has affected thousands of taxpayers.

For each issue selected, an IIR team of IRS and Treasury personnel gather relevant facts from taxpayers or other interested parties affected by the issue. The goal is to recommend guidance to resolve the issue. This benefits both taxpayers and the IRS by saving time and expense that would otherwise be expended on resolving the issue through examinations.

At any time, business associations and taxpayers may submit tax issues that they believe could be resolved through the IIR program to IIR selection criteria and submission procedures are outlined in Revenue Procedure 2003-36, available at