The new IDRs for amnesty audits
They really have their act together. One page. Check the box for what you need. Easier. (“IDR” means the Information Document Request — the letter from the IRS which tells you what you need to provide to the person calculating your penalty.)
Yay IRS. You really have the “Ready, Shoot, Aim” thing down. But at least the process is improving.
The one that just came in was from Philadelphia. In true IRS fashion they sent our client two copies of the IDR and didn’t send one to us. 
Yeah – that’s a very clear document. Nice to see.
Do you think when they request “reconciliation of income reflected on your amended returns to your financial account statements” that one needs to do anything more than just submit the amended returns with the income/gains accounted for? Or do you think they want some sort of calculation sheet? Thanks much -
Joseph,
We are soon going to find out exactly what they want here.
Based on prior experience I think the IRS wants us to make life as easy as possible for its employees. Every change on the 1040X should tie out to a specific place in the backup data. Our operational plan is to give them (1) a 1040X, (2) where useful, a summary memo or spreadsheet, and (3) the Giant Pile of Bank Statements. In some cases life is simple and the summary memo isn’t needed. In others, it is going to make it easier for the agent to see exactly why there is a new number on the 1040X.
The IRS may or may not like what we do. This is “learn by doing.” My experience so far is that the agents actually handling the files are normal people behaving normally. They’re not on some kind of disjointed rant against All Things International.
Phil.
Other interesting thing. Every one of these IDRs we’ve seen so far is coming out of Philadelphia. Is the IRS back to Plan A?
Wow – fantastic answer. Thanks!
Though, now that I think about it, I don’t get your “Plan A” reference. Does that refer to an earlier post of yours?
Sorry. Obtuse comment there. The original plan — when the voluntary disclosure program was launched — was that all of these things would be processed in Philadelphia. And that’s how things started. We have some very early cases that indeed ended up there for the civil audit (translation from tax lawyer jargon = when the agent looks at the tax returns to come up with tax liability + penalty + interest).
Then the civil audits started going all over the place. It was as if the IRS Pooh-Bahs in Washington DC said “Ooops OMG WTF we gonnadu?” That I call Plan B — when they started sending out civil audits everywhere they could.
Now the IDRs are coming from Philadelphia again. That means the civil audits are being centralized again after being, ummmm, decentralized. So we’re back (I think) to the original Plan A, which is “Let’s give Philadelphia all of the civil audits.”
Phil.
Another great explanation. Thanks again!