TEI Submits Comments on the IRS Form Being Developed to Standardize Rev. Proc. 94-69 Disclosures

On June 1, 2022, TEI submitted comments on draft IRS Form 15307, which the IRS is developing to standardize the process for making Rev. Proc. 94-69 disclosures so eligible taxpayers and revenue agents will have consistent guidelines around what constitutes adequate disclosure. TEI’s comments expressed fundamental concerns surrounding the proposed consequences of a deemed failure to provide adequate disclosures and provided a number of detailed suggestions intended to eliminate confusion and uncertainty when describing adjustments in the form.

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