n-05-25.pdf

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Part III – Administrative, Procedural, and Miscellaneous

Public Comment Invited on Recommendations for 2005-2006 Guidance Priority List

Notice 2005-25
The Department of Treasury and Internal Revenue Service invite public comment
on recommendations for items that should be included on the 2005-2006 Guidance
Priority List.
Treasury's Office of Tax Policy and the Service use the Guidance Priority List each
year to identify and prioritize the tax issues that should be addressed through
regulations, revenue rulings, revenue procedures, notices, and other published
administrative guidance. The 2005-2006 Guidance Priority List will establish the
guidance that the Treasury Department and the Service intend to issue from July 1,
2005, through June 30, 2006. The Treasury Department and the Service recognize the
importance of public input to formulate a Guidance Priority List that focuses resources
on guidance items that are most important to taxpayers and tax administration.
As is the case whenever significant legislation is enacted, the Treasury
Department and the Service have dedicated substantial resources to published
guidance projects necessary to implement the provisions in the American Jobs Creation
Act of 2004, Pub. L. No. 108-357, 118 Stat. 1418 (“AJCA”), enacted on October 22,
2004. As a consequence, new guidance projects were added to the Guidance Priority
List , as updated on December 21, 2004. The Treasury Department and the Service will
continue to evaluate the priority of each guidance project in light of the AJCA and other

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developments during the 2005-2006 plan year.
In reviewing recommendations and selecting projects for inclusion on the
2005-2006 Guidance Priority List, the Treasury Department and the Service will
consider the following:
1. Whether the recommended guidance resolves significant issues relevant to many
taxpayers;
2. Whether the recommended guidance promotes sound tax administration;
3. Whether the recommended guidance can be drafted in a manner so that taxpayers
can easily understand and apply the guidance;
4. Whether the Service can administer the recommended guidance on a uniform basis;
and
5. Whether the recommended guidance reduces controversy and lessens the burden
on taxpayers or the Service.
Taxpayers may submit recommendations for guidance at any time during the year.
Please submit recommendations by April 30, 2005, for possible inclusion on the original
2005-2006 Guidance Priority List. The Service plans to update the 2005-2006
Guidance Priority List periodically to reflect additional guidance that the Treasury
Department and the Service intend to publish during the plan year. The periodic
updates allow the Treasury Department and the Service to respond to the need for
additional guidance that may arise during the plan year. Recommendations for
guidance received after April 30, 2005, will be reviewed for inclusion in the next periodic
update.
Taxpayers are not required to submit recommendations for guidance in any

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particular format. Taxpayers should, however, briefly describe the recommended
guidance and explain the need for the guidance. In addition, taxpayers may include an
analysis of how the issue should be resolved. It would be helpful if taxpayers
suggesting more than one guidance project would prioritize the projects by order of
importance. If a large number of projects are being suggested, it would be helpful if the
projects were grouped in terms of high, medium or low priority.
Taxpayers should send written comments to:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2005-25)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
or hand deliver comments Monday through Friday between the hours of 8 a.m. and
4 p.m. to:
Courier's Desk
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2005-25)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224

Alternatively, taxpayers may submit comments electronically via e-mail to the
following address: Notice.Comments@irscounsel.treas.gov. Taxpayers should include
“Notice 2005-25” in the subject line. All comments will be available for public inspection
and copying in their entirety.
For further information regarding this notice, contact Crystal Foster of the Office of
Associate Chief Counsel (Procedure and Administration) at (202) 622-7326 (not a
toll-free call).