American College of Tax Counsel


2604 Elmwood Avenue, #350
Rochester, NY 14618

Government Submissions

The important issues of professionalism and ethics in the tax practice, both in the private and government sectors, are receiving priority attention of the college. The College’s Committee on Professionalism, working with representatives of the Internal Revenue Service and the Department of Justice, is actively studying those important issues and arranging national conferences and other meetings to promote a discussion of ways to improve the practice.

Government Submissions:

Date Submission
08/08/19 Letter to Internal Revenue Service Chief Counsel regarding recommendations relating to the Bright Line Test of United States v. Boyle and e-filed returns

Read the Press Release

10/10/16 Letter to IRS Chief, Appeals, regarding changes relating to Appeals Conference and Settlement Practices
7/13/16 Letter to Congressional Leadership regarding proposed resolution to impeach IRS Commissioner
1/8/13 Comments on Proposed Circular 230 Regulations
7/25/11 Comments on Final Circular 230 Regulations
3/29/11 Letter soliciting support for adequate funding of the IRS for 2011-2012 fiscal years
2/2/11 National Coalition letter in support of regulation of Tax Strategy Patents
6/8/10 Comments on Announcement 2010-9 regarding reporting of uncertain tax positions
2/16/10 Letter to IRS/Treasury questioning the validity of the retroactive effectiveness of T.D. 9466
10/20/09 Coalition letter regarding Tax Strategy Patent Legislation
3/24/09 Letter to members of Senate Finance Committee regarding special tax on bonuses paid to individuals employed by companies that review TARP funds
2/12/04 Comments on proposed amendment to Circular 230
7/23/03 Comments in Response to Department of Treasury Advance Notices of Proposed Rule Making to Amend the Regulations Governing Practice Before the Internal Revenue Service (Treasury Dept. Circular No. 230) REG-122380-02 (December 18, 2002) and Announcement 2003-5, REG-1223804-02 (February 3, 2003)

Tax Policy:

6/21/07 National Conference on the Tax Gap – Summary of Proceedings