Section I: Taxpayer Data
Items 1 to 13: name, identification number, address, telephone and fax, examination or Appeals status, TEFRA partnership questions, notices received, power of attorney and amended returns.
13750
Election to Participate in Announcement 2005-80 Settlement Initiative
Form 13750 is the Election to Participate in Announcement 2005-80 Settlement Initiative, dated October 2005. A taxpayer used it to elect into the settlement initiative described in Announcement 2005-80, as contained in Internal Revenue Bulletin 2005-46 dated November 14, 2005. The note at the top of the form gives January 23, 2006 as the date for providing all the information required under the election to be eligible for the settlement, or as otherwise stipulated in later IRS requests for more information.
The four-page form has Section I for taxpayer data, Section II for the transactions elected, Section III for an ineligible taxpayer's special request for inclusion and Section IV for penalties, followed by the taxpayer attestation and short instructions. Schedule A gives details of each elected transaction. Schedule B gives details of tax advice when a written tax opinion was obtained.
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Items 1 to 13: name, identification number, address, telephone and fax, examination or Appeals status, TEFRA partnership questions, notices received, power of attorney and amended returns.
Checkboxes for the listed notices, revenue rulings and other transactions, each with its penalty printed, such as Notice 2002-21 (20% penalty) and Notice 2003-77 (5% penalty).
Boxes for the three ineligibility reasons and space for the reasons the taxpayer gives for asking to be included despite that ineligibility.
Two boxes on a possible 0% penalty under IRC § 6662, a disclosure under Announcement 2002-2 or a written tax opinion by an independent tax advisor, then signatures under penalties of perjury.
Details of each elected transaction: a description, any Tax Shelter Registration or Material Advisor number, tax years and amounts, transaction costs, other parties, and litigation and bankruptcy questions.
Details of tax advice: whether and when a written tax opinion was received, how the transaction was implemented, any appraisal, and the advisor relationship and fees.
Enter the taxpayer name or names, identification number, address, telephone and fax numbers, and answer items 6 through 13. Item 6 says a No answer means providing copies of all relevant tax returns with the election.
Item 12 says to attach a copy of the Power of Attorney if there is one. Item 13 says to attach copies of any amended returns for the years in which the transaction took place.
Check each transaction elected. The form says to complete a separate Schedule A for each box checked and attach it to the election.
Used only by a taxpayer who checks one of the ineligibility boxes. The space below asks for the reasons for requesting that the IRS permit settlement anyway.
Check box 1 or 2 if either applies. Box 2 calls for a separate Schedule B for each issue the written tax opinion covers. Schedule B item 1 says leaving out a copy of a written opinion that was received disqualifies the taxpayer from relief under that section.
Sign and date the Taxpayer Attestation, which is made under penalties of perjury. There are two taxpayer signature lines.
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The instructions give INTERNAL REVENUE SERVICE, Attn: Announcement 2005-80, MS1505, 24000 Avila Road, Laguna Niguel, CA 92677.
If the taxpayer or a TEFRA partnership they are a partner in is under examination or in Appeals, the instructions ask that a copy of the election go to the IRS examiner or Appeals Officer.
The note at the top gives January 23, 2006, or as otherwise stipulated in later IRS requests for more information.
The Paperwork Reduction Act Notice gives an estimated average time of 300 minutes. The OMB number is 1545-1970.
13751
7 fields, 1 page
2848
92 fields, 2 pages
13748
17 fields, 1 page
The form is completed and signed by the taxpayer electing into the settlement initiative. Line 2 takes either an EIN or an SSN.
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It is the election to participate in the Announcement 2005-80 settlement initiative, as contained in Internal Revenue Bulletin 2005-46 dated November 14, 2005.
The note at the top gives January 23, 2006 for providing all the information required under the election, or as otherwise stipulated in later IRS requests.
The form says a separate Schedule A for each transaction checked in Section II.
When a written tax opinion was obtained and box 2 in Section IV is checked. The form asks for a separate Schedule B for each issue to which the opinion applies.
The instructions give INTERNAL REVENUE SERVICE, Attn: Announcement 2005-80, MS1505, 24000 Avila Road, Laguna Niguel, CA 92677.
The taxpayer signs the Taxpayer Attestation under penalties of perjury. There is a second taxpayer signature line, and line 1 includes the spouse's name on a joint return.