- 16 - Section 9781.348.2 of the manual provides: (1) A "return" is any tax return or information return, schedules, and attachments thereto, including any amendment or supplement, which is required or permitted to be filed and is in fact filed by a taxpayer with the Secretary of the Treasury. Examples include: (a) Forms 1040, Schedules A, B, C and Forms W-2. (b) A taxpayer has filed an income tax return and subsequently submits a letter to IRS explaining an item on the original return. The letter is within the definition of return. (2) The statutory definition of "return information" is very broad. It includes any information other than a taxpayer's return itself which IRS has obtained from any source or developed through any means which relates to the potential liability of any person under the Code for any tax, penalty, interest, fine, forfeiture or other imposition or offense. Petitioners' reliance on the above provisions is misplaced in the context of the present case. The intent of both section 6103(b)(2) and section 9781.348.2 of the manual is to require respondent's agents to maintain the confidentiality of taxpayers' information. By its own terms, section 6103(b)(1) limits its definition of the term "return". It is defined only “For purposes of this section”. Sec. 6103(b)(1). Moreover, section 9781.348.2 of the manual defines the terms "return" and "return information" for purposes of the rule in section 9781.348.1, which requires special agents in criminal tax investigations to treat return information as confidential. I.R.M., supra sec. 9781.348.1 at 28,689-5. Although we do not see any inconsistencyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011