Jeffrey C. and Kelly O. Stone - Page 7

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          individuals who are to inspect or receive the returns or return             
          information; and (c) not designate as a representative any person           
          who is the chief executive officer of the State or is not an                
          employee or a legal representative of the tax agency.  Id.                  
               The IRS has coordination and implementation agreements with            
          each State and the District of Columbia.  The Implementation                
          Agreement between the Department of Revenue and the IRS satisfies           
          section 6103(d) because it (a) is signed by the head of the State           
          tax agency, (b) designates the individuals who are to inspect or            
          to receive the returns or return information on behalf of the               
          agency, and (c) does not designate as a representative the chief            
          executive officer of the State or any person who is not an                  
          employee of the tax agency.  Taylor v. United States, 106 F.3d              
          833, 836 (8th Cir. 1997) (agreements between Iowa and the IRS               
          satisfy section 6103(d)); Long v. United States, 972 F.2d 1174,             
          1179 (10th Cir. 1992) (agreements between Colorado and the IRS              
          satisfy section 6103(d)); Smith v. United States, 964 F.2d 630,             
          633-634 (7th Cir. 1992) (agreements between Illinois and the IRS            
          satisfy section 6103(d)).  In Taylor v. United States, supra at             
          836 the Court of Appeals for the Eighth Circuit stated:                     
               Congress clearly recognized the need for disclosure of                 
               such information in certain carefully delineated                       
               circumstances.  Disclosure of individual taxpayer                      
               information by the IRS to a state taxing authority via                 
               a standing written agreement that is carefully crafted                 
               to satisfy concerns for confidentiality implements                     
               rather than "eviscerates" the will of Congress.                        






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