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Issue 40163

Form 4549

Issue Statement:

Determine if the Form 5471, Form 4549: Report of Income Tax Examination Changes clearly communicate appropriate guidance to the public.

Goal Statement:

The goal of this project is to review and make recommendations to the IRS that will enhance customer service and improve the taxpayer’s experience.

RECOMMENDATION 1581

RECOMMENDATION TEXT:

Form 4549 – upper right-hand corner of each page

On each page:
Page _____ of _____
Date: MM/DD/YYYY

According to the Taxpayer Bill of Rights, taxpayers are entitled to clear notices and correspondence. Taxpayers also have the right to pay only the amount of tax legally due. When subject to an audit, multiple versions of Form 4549 may be provided to the taxpayer. It could be difficult for a taxpayer to determine which is the current version and/or pages could be mixed together and not provide an accurate representation of the final proposed changes.

The taxpayer is asked to sign and date Form 4549 and send it back in the envelope provided if the taxpayer agrees with the proposed changes. It is possible the taxpayer could unintentionally agree to changes they are not in agreement with or do not fully understand.

Failing to provide basic information, such as the date of the proposed changes/notice, creates confusion during an already complex process for most taxpayers. The date should be displayed in a prominent location that is easy for the taxpayer to locate, such as the top of the form with the page numbers. This will ensure the taxpayer can identify the current proposed changes and can properly match page numbers (that are provided for this purpose) and dates.

IRS Action: Partially adopted

The IRS partially agrees. We will revise page 1 of Form 4549 to include the date in a prominent place and submit this request to the Report Generation Software (RGS) team for implementation. If the requested programming cannot be completed in FY20, we will evaluate other alternatives, such as the feasibility of adding the date manually. The IRS cannot number all pages of the report which includes the actual Form 4549 and supplemental pages in the format you requested due to programming limitations with the report writing software.

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current report

2023 TAP Annual Report

The six core project committees submitted 31 referrals to the IRS for consideration during the 2023 TAP year. These referrals contained 531 recommendations to the IRS.

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