On-line source for comments submitted to IRS

[J2D2]

Does anyone know if the IRS posts on its website the comments that it receives on proposed regs, notices, etc? BenefitsLink does a great job of posting comments from ASPPA and others, but I suspect that Dave isn't able to "capture" everything that's sent to the IRS. For the moment, I'm especially interested in seeing comments being submitted in response to Notice 2005-1.

Thanks for any info or leads.

[Kirk Maldonado]

I don't think that they are posted on the IRS website. Some of them get published in the BNA Daily Tax Reporter. I think that you can get all of those comments from BNA, but it might require an annual subscription.

You should make the suggestion to the IRS that the comments on section 409A be posted on their website as they come in. That will help the IRS because it may eliminate the amount of duplicative submissions that they get.

[WDIK]

That will help the IRS because it may eliminate the amount of duplicative submissions that they get.

Another possibility is that fewer submissions with similar comments may lead to the conclusion that an issue is not as important to or as supported by the taxpayer community as is actually the case.

[Kirk Maldonado]

WDIK:

Point well taken.

What I was focusing upon, but didn't mention in my post, are where service providers get each one of their clients to send the identical letter to the IRS. Gettting hundreds or even thousands of identical letters has extremely little impact.

On the other hand, as you implicitly suggest, people preparing original and thoughtful analyses of the same issue will help to demonstrate that the problem affects a lot of employers.

[WDIK]

Your point is also well taken.