Changing A Bureaucracy One Paragraph At A Time (Improving Written Communication) Document 11345 (rev. 4-2009) Catalog Number 30954V Department of the Treasury Internal Revenue Service publish.no.irs.gov C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Changing a Bureaucracy One Paragraph at a Time Overview This workbook is designed to accompany the interactive video, Changing A Bureaucracy One Paragraph at a Time. The video has six sections where the instructor pauses to give you time to complete the additional exercises in the workbook. The answers follow each group of exercises. The workbook also includes an IRS letter that we edit in stages to show how applying some fundamentals of effective written communication improve the quality of the letter. We revise this letter using one fundamental at a time to show the effect of each change. Some of the things we change will be changed again by the time we get to the end of the letter. For example, we may put the existing sentence in active voice but it still contains wordy phrases or false subjects. We have done it this way to help you see the effect of the technique we are working on in that portion of the video. In practice, you would probably start your editing by looking at the organization of the document. For this exercise, we are working with the writer's original organization. Please allow four hours to watch the video and complete the exercises. http://irweb.irs.gov/AboutIRS/bu/cl/la/lawr/default.aspx Please call the Congressional Correspondence Branch at (202) 622-3730 for more information. C o n g r e s s i o n a l C o r r e s po n d e n c e and Quality Review Branch Contacts 1111 Constitution Ave., NW • CL:LA, Room 3244 • Washington, DC 20224 (202) 622-3730 phone (202) 622-4733 fax C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Changing a Bureaucracy One Paragraph at a Time Introduction A. Congressional Correspondence and Quality Review Branch Contacts Focusing on the Readers A. Identify readers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1. Who will read this? 2. What questions will they want answered? 3. What are their priorities? Concerns? 4. How much explanation do they want? 5. What is the minimum they need to know to do what they need to do? 6. How should we present the information? B. Write for the readers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1. Remember the 15-second rule. 2. Make the document visually interesting. 3. Write like you speak. 4. Answer their questions, but don't overwrite. 5. Write to communicate, not to impress. Six Writing Tips A. Use a positive tone. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1. Use active voice. (Exercises) 2. Use "I" when you can. (Exercises) 3. Apologize when appropriate. (Exercises) B. Organize your document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 1. Pick the right organizing pattern. 2. Have only one main idea. 3. Keep the introduction short. 4. Put the most important idea at the beginning. 5. Be brief. 6. Use parallel construction. C. Format to make the document inviting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 1. Give readers white space. 2. Use headings. 3. Use bold, underlining, italics. 4. Use bullets. (Exercises) D. Choose words carefully. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 1. Avoid gobbledygook. 2. Use specific, concrete words. 3. Use strong verbs. 4. Avoid false subjects. 5. Remove wordy phrases. 6. Avoid redundancies. (Exercises) E. Review common grammar rules. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 1. that/which 2. affect/effect 3. bimonthly 4. principal/principle 5. may/can (Exercises) 6. entitled/titled 7. demonstrative pronoun F. Review common punctuation rules. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101 1. commas 2. conjunction Evaluation Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Play Video Introduction We offer this class on writing to give writers, reviewers, and signers some tools to help lower the frustration level of: • Writers, because reviewers never seem satisfied with their drafts • Reviewers, because writers don’t always know what reviewers want • Signers, who aren’t satisfied but sign because the document is late Our goal is to raise awareness about the things that make many IRS documents difficult to read: passive voice, redundant words, wordy phrases. Writers can eliminate them from their writing, thereby shortening the review process and making reviewers and signers happier. Our agenda for the class: • Discuss the importance of focusing our documents on the reader. • Introduce you to the six groups of most commonly made mistakes in the letters we see and show you how to correct or avoid them. • Work through some exercises to help you become familiar with these concepts. • Apply these concepts to an IRS document. Our readers benefit from good writing and so do we. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 1 Identify The Reader We want to make sure our letter is the one they want to read. If we focus on their needs and present our information in an inviting format, they will be more likely to read our documents. We can’t force anyone to read our documents. Readers have a choice. They can read our documents now, later, or never. We want ours in the now category because the later category usually ends up in the never category. Write For Your Reader When you picture the reader, imagine someone who has too much to do (like most of us) and not enough time. Imagine someone who is looking for concrete, straightforward answers to questions and someone perhaps who thinks of the IRS as a big, bureaucratic, impersonal organization. When you write, think of all the people who may read your document. That list may include IRS employees, taxpayers, members of the Congress, or newspaper reporters. Ask yourself, "What do the readers need to know to do what they need to do?" Think Readers spend an average of 15 seconds reading about their priorities and concerns in general, not just and trying to understand our documents. To help those related to this document. them do this, we use headings, bullets, and as few words as possible. These things combine to make our document visually interesting. We can also help readers get the information they need quickly and easily by writing as we speak. Writing as we speak is also called plain language. Not only does plain language make the information easier for the reader, it also helps us because it is easier to write in plain language. We want to answer all our readers’ questions, giving them what they need to know but not everything we know. Our goal as writers should be Our letters are competing with many other to have our readers read through the document one documents for the short time readers have to give. time and understand it perfectly the first time. 2 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Two tips to help with this: Remember we write to communicate information. If our readers can’t understand our message, we • If we need to cite code, put the plain language have wasted a lot of time and effort. information first, and then cite the code in brackets Use A Positive Tone at the end of the sentence or paragraph if the same citation applies to all the information. • When we cite court cases, put the citations in italics. Don’t underline them. The underline comes from typewriter days when we didn’t have an easy way to use italics. The underlining told the printer to italicize the text. Technology has made it easy for us to do it for ourselves. The acceptable tone in business documents has changed because of the information explosion. We all have too much to read today. We want to read and understand the content quickly. To understand long, complex, technical, legalistic sentences takes time and energy. Plain language - language that sounds like ideal Another important tool that goes hand-in-hand with conversation - keeps the tone more informal, these six tools is collaboration: friendly, and personal. • Ask another person to review your letter for tone, Tone refers to how we make the reader feel by the clarity, and organization. Best of all, ask people words we use. who know nothing about your program area to impersonal, friendly or official, formal or informal. Tone read your letter and make sure your explanation is different from style. Style refers to the words you is clear and not too technical. use, for example, pronouns, contractions, jargon. Our tone may be personal or Your choice of these words creates tone. • Accept their comments with gratitude for the time and effort they put into the review - don’t be defensive. • Help the people reviewing your letter by giving them some guidelines on what you want them to focus on in your letter. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 3 When we think of tone, we want words that sound positive, friendly, personal, and helpful. We want to In normal conversation, we would not use the language communicate the open, straightforward, honest, and on the left. It sounds bureaucratic and pretentious. caring attitudes of the people who write the letters. Readers like the straightforward approach on the right. One more note, readers don’t like legalistic, bureaucratic jargon. Further, we don’t need to use legal sounding terms to make our information accurate and legally appropriate. As Dr. Kimble of the Thomas Cooley Law School and Clarity* said in the Scribes Journal of Legal Writing, "Plain language is not subverted by the need to use technical terms or terms of art. Real terms of art are a tiny part of any legal document…I invite anyone to find a case saying that give won’t do in a will - that it has to be give, devise, and bequeath." *Clarity is an organization working to bring plain language to the legal profession. Often, people tell us that using the active voice or using "we" instead of "I" is simply a matter of style. However, the style of writing we choose is closely linked to tone. Style refers to the choices we make in organizing our document, using certain words, being formal or informal, and deciding the length of sentences and paragraphs. All of these choices affect the tone of our document and, ultimately, the feelings or impressions we leave with the reader. 4 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e throughout the document, however, it becomes wordy, making it difficult to read and understand. Active Voice The Congress passed the bill. Passive Voice The bill (was) passed by the Congress. The tone of the first statement is hostile and angry. The phrase "As you know" is unnecessary. If they know, we don’t need to tell them. If we are not sure Active voice: they know and think it is important enough to mention, An active voice sentence has a subject that does an action to an object. then just tell them in a straightforward, open way. Sometimes saying less is much more effective. The Congress (the subject) passed (did this Active Voice vs. Passive Voice action) the bill (the object). Passive voice: In the passive voice, the subject is the receiver of the action. 1. U se the active voice rather than the passive. The bill (the subject) was passed (was acted upon) by the Congress. When we write in the passive voice, we add some form of the verb to be (am, is, are, was, or were). Doing this makes our sentence wordy. We may feel comfortable writing in the passive voice because so many of our government documents are written that way. We have simply become accustomed to the sound, and passive voice becomes a habit. However, when government documents sound bureaucratic, passive voice is often the reason. In one particular sentence, passive voice may not sound so terrible. When we use passive voice C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 5 Cut Passive Tense vs. Voice Don’t confuse passive voice with past tense. Passive voice can be in any tense: present, past, or future. Cut Passive Voice A c t i v e V o i c e : The bill was passed. We often use another form of voice called the cut passive: Present Tense: The Congress passes the bill. Past Tense: The Congress passed the bill. Future Tense: The Congress will pass the bill. P a s s i v e V o i c e : The bill was passed. Using the cut passive often makes it difficult for our readers to figure out who did the action. When we do this in our letters, we sound vague and make the Present Tense: The bill is passed by the Congress. Past Tense: The bill was passed by the Congress. We Future Tense: reassure the public when we can show we know The bill will be passed by the Congress. reader think we don’t know what happened. exactly what happened to a document entrusted to our care. For example, we should say "Ogden Service Center received your return on April 1, Regardless of the tense, we want to write in the active voice. 1999" instead of "your return was received on April 1, 1999." Two occasions when the passive is appropriate are: • When the doer of the action is unknown • When the doer of the action is unimportant Because of the nature of our work, the organization doing the action is seldom unimportant to the person asking why they did not get their refund. Just a caution - Using the active voice is not about being accusatory; it is simply about sounding responsible. 6 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Which version sounds more natural and sincere? • Active voice uses fewer words. Fewer words are easier to read and understand. Passive: Video Exercises: Your offer in compromise for $1.00 cannot be accepted by the IRS. (12 words) Active: Instructions: Choose the sentences that are written in the active voice. We cannot accept your offer in compromise for $1.00. (9 words) Exercise 1 • Active voice imitates the way we speak. It is A. This letter will be available for public inspection personal and friendly. We use the active voice after identifying information has been deleted automatically when we’re talking. We should under the Freedom of Information Act. train ourselves to use active voice in our writing. B. Under the Freedom of Information Act, we will Passive: The letter was written by me this morning. Active: I wrote the letter this morning. • Active voice shows responsibility. We don’t want to sound accusatory. However, when we avoid showing responsibility, we often don’t give enough make this letter available to the public after deleting identifying information. Answer: B Exercise 2 A. A recommendation was made to initiate actions to collect the potential lost revenue. information to explain the problem and how to fix it. B. TIGTA recommended we collect the potential lost revenue. Passive: Answer: B It was determined that the amount of expenses claimed for the year 1998 was inaccurate. Active: We found you added your expenses incorrectly. Exercise 3 A. IRS records show Mr. Doe defaulted on his installment agreement on December 1, 1997, C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 7 because he filed his 1995 and 1996 returns showing taxes due. B. IRS records show Mr. Doe’s installment agreement was defaulted on December 1, 1997, because his 1995 and 1996 returns were filed showing taxes due. Answer: A Pause Video Pause video here for additional exercises. 8 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on the Active and Passive Voice Instructions: Rewrite each sentence using the active voice. 1.Your examination has been transferred to the Yellow office and assigned to Mr. Joe Doe. 2. If a person does not file a return, a Notice of Deficiency is sent. 3. In recent years, additional emphasis has been placed on providing a higher, more standardized level of Walk-In service to customers. 4. The problems that occurred early in the filing season were identified and corrected. (NOTE: You found that Information Systems fixed the problem.) 5. Any expenses incurred in this matter may be claimed as deductions on your tax return. 6. The letter was sent to the primary taxpayer. 7. An identifying number must be included on all federal income tax returns. 8. Copies of both the forms and the publications are enclosed. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 9 9. An explanation was provided by the revenue agent to show why the audit was conducted on Mr. Doe’s tax return. 10. A response dated August 5, 1999, was received stating she was an American citizen. 11. The 1999 federal tax return filed by the Does was processed at the Blue Service Center. 12. Changes were made that resulted in additional taxes and balances due from you. These assessments were made by the Examination Division. 13. Our records indicate that your deposit was located and applied to your tax year 1999 liability on August 28, 2000. 14. Under the rules governing shareholders’ interests, Mr. Doe’s shares may not be sold or otherwise transferred. 15. Training was provided to data gatherers, and the case record/check sheet was used as a plan for the review. 10 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 11 Suggested Answers 1. I transferred your examination to the Yellow office where they assigned it to Mr. Doe. 2. If a person does not file a return, the IRS sends a Notice of Deficiency. 3. In recent years, we have worked to give quality Walk-In service to customers. 4. Information Systems corrected the problems that occurred early in the filing season. 5. You can deduct your expenses incurred in this matter on your tax return. 6. We (or I if you sent it) sent the letter to the primary taxpayer. 7. You must include an identifying number on all federal income tax returns. 8. I have enclosed copies of the forms and publications. 9. The revenue agent explained why he audited Mr. Doe. 10. She responded to us on August 5, 1999, saying she was an American citizen. 11. The Blue Service Center processed the Doe’s 1999 federal tax return. 12.The Examination Division made assessments that increased your taxes and balances due. 13. We located your deposit and applied it to your tax year 1999 liability on August 28, 2000. 14.The rules governing shareholders’ interest do not allow Mr. Doe to sell or transfer his shares. 15.We trained the data gatherers and used the case record/check sheet as a plan for the review. 12 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 1: Original IRS Letter Applying some fundamentals of effective written communication to our letters improves their quality. We will revise this IRS letter using one fundamental at a time to show the we get to the end of the letter. For example, we may put the existing sentence in active voice but it still contains wordy phrases or false subjects. We have done it this way to help you see the effect of the technique we are working on in that portion of the video. In practice, you would probably start your editing by looking at the organization of the document. For this exercise, we are working with the writer's original organization. The first fundamental we will apply is changing passive voice sentences to the active voice. Many government documents are good examples of why writers should avoid the passive voice. Passive voice is vague, wordy, and, in the case of the cut passive, fails to show responsibility. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 1: Original IRS Letter effect of each change. Some of the things we change will be changed again by the time 13 The Honorable YY ZZ Letter 1 Member, U.S. House of Representatives Local Street Address Suite • The original letter has large blocks of text, lots of passive voice, wordy phrases, and no formatting to make it user friendly. • In this first version of the letter, we highlighted in blue those sentences that have the passive voice. City, State Zip Dear Congressman ZZ: This is in response to your inquiry dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns; namely that he had been subjected to needless audits, and in general, that his case has been mishandled. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. Upon receipt of his request for relief, the case was assigned to Mary YY, a caseworker. This specific relief requested by Mr. Doe was: "...immediate reinstatement of my deductions and exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. A review of the file was completed, as requested, and it was determined that Mr. Doe was unable to substantiate the expenditures he had claimed on his Individual Income Tax Return, Form 1040 for tax year 1995. Specifically, it was determined that he was not entitled to a deduction for mortgage interest, as the mortgage was not held in his name but in the name of a private investor that he was paying. In addition, there were no allowances for contributions to an Individual Retirement Account (IRA) because the financial institution that he said held the IRA did not acknowledge the existence of the IRA. With regard to the exemptions, Mr. Doe was not allowed to deduct the exemptions for the children, A and B Doe, as they were claimed on another party’s return, and he was unable to substantiate that more than half of their support was provided by him. The other exemption, C. Doe, was disallowed because the child was 21, and Mr. Doe could not verify that more than half the support was provided by him. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that information be requested regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. Jim XX, of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was unhappy with the outcome, he understood why the deductions and exemptions were disallowed. The issue of repetitive audits was also raised by Mr. Doe. The files were reviewed and it was determined that we did not contact him for tax years 1991, 1992, and 1993. Additional tax was proposed by the Underreporter Program for tax year 1994. The tax was assessed after we did not receive a response from him. The audit notification for tax year 1995 was sent from Franklin 14 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Service Center because this was Mr. Doe’s last known address and the one the constituent used on the return. When the IRS was contacted and informed of his address change, his request for the transfer to the local IRS office in City, State, was complied with. The continuation of the audit was conducted in City, State, and Mr. Doe was offered the opportunity to provide substantiation for the deductions. He was unable to do so. When an audit is conducted, every effort is made to bring the taxpayer into full compliance. This usually requires that the auditor include subsequent years' returns. In this case, the1995 tax year was closed separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to provide documentation to substantiate deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The option of submitting an Offer-inCompromise to settle the debt was discussed. In the meantime, his account has been placed in currently-not-collectible status. It was explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and any subsequent refunds due him will be applied to the open balance. With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to investigate these complaints. Matters such as these are referred to the Treasury Inspector General for Tax Administration (TIGTA). Generally, the IRS is not notified of the outcome of the investigation and subsequent corrective action because of employee privacy issues. Once again, we want to apologize for any inconvenience or frustration Mr. Doe may have experienced in trying to resolve this matter. If you have any questions or concerns, please contact us at (111) 222-2222. Sincerely, • In the passive voice, the object of the action is the subject of the sentence and the writer uses a form of the verb to be. • In letter 2, we changed the passive voice sentences to the active voice. • The letter still has lots of problems. We will highlight and correct other problems in the letters that follow. Local Office C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 15 16 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e In letter 2, we changed the passive voice examples highlighted in the first letter to the active voice, making the subject the doer of the action and getting rid of the verb to be. The letter still has many problems, but we have taken the first step. In our next segment of the video, we talk about using I instead of we as often as possible. To prepare for the next segment, in the last paragraph of letter 2, we highlighted the words we and us. Writers should use the singular personal pronouns I and me as often as possible in letters to give them a more personal tone even if they are preparing the letter for someone else to sign. Sometimes, we use the plural when talking about a group effort, but we should make an effort to use I instead of we as often as possible. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 2: Passive Voice Changed to Active Voice Letter IRS Letter 2: Passive Voice Changed to Active Voice 17 The Honorable YY ZZ Letter 2 Member, U.S. House of Representatives Local Street Address Suite • To help you review this change in the letter, we underlined the parts of the sentence where we changed the passive voice to the active voice. City, State Zip Dear Congressman ZZ: This is in response to your inquiry dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns; namely that the IRS subjected him to needless audits, and in general, that the IRS mishandled his case. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. Upon receipt of his request for relief, the local office assigned the case to Mary YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my deductions and exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. We completed a review of the file, as requested, and determined that Mr. Doe could not substantiate the expenditures he had claimed on his Individual Income Tax Return, Form 1040 for tax year 1995. Specifically, we determined that he was not entitled to a deduction for mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. In addition, there were no allowances for contributions to an Individual Retirement Account (IRA) because the financial institution that held the IRA did not acknowledge the existence of the IRA. With regard to the exemptions, the IRS did not allow Mr. Doe to deduct the exemptions for the children, A and B Doe, as another party claimed them on a tax return, and he was unable to substantiate that he provided more than half of their support. The IRS disallowed the other exemption, C. Doe, because the child was 21, and Mr. Doe could not verify that he provided more than half the support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. Jim XX of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was unhappy with the outcome, he understood why the IRS 18 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e disallowed the deductions and exemptions. Mr. Doe also raised the issue of repetitive audits. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one the constituent used on the return. When he contacted the IRS and informed us of his address change, we complied with his request for the transfer to the local IRS office in City, State. The IRS continued the audit in City, State, and offered him the opportunity to provide substantiation for the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This usually requires that the auditor include subsequent years’ returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to provide documentation to substantiate deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS has placed his account in currentlynot-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any subsequent refunds due him to the open balance. • The person signing the letter is taking With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to responsibility for the content of the letter investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. so using I or me is appropriate. • We will change these Once again, we want to apologize for any inconvenience or frustration Mr. Doe may words in the next have experienced in trying to resolve this matter. If you have any questions or letter to give it a concerns, please contact us at (111) 222-2222. personal tone. Sincerely, Local Office Play Video C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 19 20 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Using “I” B.I regret the inconvenience this transaction caused Mr. Doe. Answer: B This sentence removes the word ANY and MAY HAVE. We know it did inconvenience the 2. U se “I” instead of “we” as often as possible. reader. And we apologize. Exercise 2 A.I am writing in response to your letter dated May 30, 2000. B. We are writing in response to your letter Use "I" instead of "we" as often as possible so our dated May 30, 2000. Answer: A readers: • Feel IRS letters are personal. The introductory first paragraph is a good • Know we are being accurate. place to use I. • Understand a real person, not a machine, is writing the letter. Exercise 3 A. Should you need to contact my office, you Use "I" instead of "we" when writing unless you are may contact Joe Doe at (111) 222-3333. referring to specific work performed by a group. Using "we" when you could use "I" makes your letter sound anonymous and unresponsive. Using "I" makes the B.Please call me at (111) 222-3333 or Joe Doe at (111) 222-3333. Answer: B reader feel you have read his or her letter, taken it seriously, and made an effort to answer the If your are writing to a congressman, give questions. your telephone number as well as the number of whoever is working the case. To keep a personal tone, use names if you know them. Instead of using "your constituent" or "the taxpayer," Exercise 4 use the name. Instead of "If you or your constituent A. We are sorry we lost your return. have questions" use "If you or Mr. Doe have questions." B. I am sorry we lost your return. Answer: B Video Exercises: Instructions: Choose the sentence that uses I/We Even when we personally were not responsible, we apologize. appropriately. Pause Video Exercise 1 A.We regret any inconvenience this transaction Pause video here for additional exercises. may have caused Mr. Doe. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 21 22 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises Using I and We Instructions: Change we to I whenever you can to give our letters a more personal tone. Also use we instead of the IRS when you can. 1. We apologize for the IRS’s error. 2. We are sorry your check did not arrive on time. 3. The IRS addressed the response to Mr. Joe Doe instead of Ms. Jane Doe. 4. On November 10, 1999, the IRS submitted an unauthorized disclosure report. 5. If we can do anything else to help you in this matter, please call me or Joe Doe at (111) 222-3333. 6. We are enclosing a price list, page count, and a separate publication. Instructions: Use I and we as often as possible in the following paragraphs to make the tone conversational. 7. This letter responds to your request of June 6, 2000, endorsing City as a location for an Offer-in-Compromise (OIC) processing site. The IRS has not made a decision regarding the location of the site but expects to do so soon. 8. The IRS appreciates your taking the time to express your support for having the OIC site in City. The information you have enclosed will be taken into consideration as a determination is made concerning the site. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 23 24 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 25 Suggested Answers 1. I apologize for our error. 2. I am sorry your check did not arrive on time. 3. We addressed our response to Mr. Joe Doe instead of Ms. Jane Doe. (You didn’t do it yourself, so we is fine.) 4.On November 10, 1999, we submitted an unauthorized disclosure report. (Again, you didn’t do it yourself.) 5. If I can do anything else to help you in this matter, please call me or Joe Doe at (111) 222‑3333. 6. I am enclosing a price list, page count, and a separate publication. 7. Thank you for your letter of June 6, 2000, suggesting City as a location for an Offer-inCompromise (OIC) processing site. We have not made a decision yet but expect to do so soon. 8. I appreciate your taking time to express your support for having the OIC site in City. We will use your information as we decide where to put the new site. 26 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e In letter 2, we highlighted two words, we and us. Changing two words may seem insignificant, but this small change contributes to giving the letter a more personal, friendly tone. We made another change using I to give the opening of our letter more personal tone. We frequently see the following opening in IRS letters: Not this: This is in response to your inquiry dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. We don't want to use this opening because This is in response uses an undefined demonstrative pronoun*, a pronoun that does not tell the reader what this refers to. A way to improve this opening is to say: This: This letter is in response to your inquiry dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Even better, we could personalize the letter with I and say: Or this: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. As a general rule, when this refers to something that might not be obvious to the reader, put the noun it refers to right after it. * We included information on demonstrative pronouns in the grammar section of this workbook. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 3: Using I instead of We when Appropriate IRS Letter 3: Using I instead of We when Appropriate 27 Letter 3 The Honorable YY ZZ Member, U.S. House of Representatives Local Street Address Suite City, State Zip Dear Congressman ZZ: • We changed this opening using I to I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns; namely that the IRS subjected him make our letter more to needless audits, and in general, that the IRS mishandled his case. On December 14, personal. 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. Upon receipt of his request for relief, the local office assigned the case to Mary YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my deductions and exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This request required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. We completed a review of the file, as requested, and determined that Mr. Doe could not substantiate the expenditures he had claimed on his Individual Income Tax Return, Form 1040 for tax year 1995. Specifically, we determined that he was not entitled to a deduction for mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. In addition, there was no allowance for contributions made to an Individual Retirement Account (IRA) because the financial institution that held the IRA did not acknowledge the existence of the IRA. With regard to the exemptions, the IRS did not allow Mr. Doe to deduct the exemptions for the children, A and B Doe, as another party claimed them on a tax return, and he could not substantiate that he provided more than half of their support. The IRS disallowed the other exemption, C. Doe, because the child was 21, and Mr. Doe could not verify that he provided more than half the support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. Jim XX, of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was 28 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. Mr. Doe also raised the issue of repetitive audits. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one he used on the return. When he contacted the IRS and informed us of his address change, we complied with his request for the transfer to the local IRS office in City, State. The IRS continued the audit in City, and offered him the opportunity to provide substantiation for the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This effort usually requires that the auditor include subsequent years' returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and • The letter still has 1997 tax years remained open to allow Mr. Doe to have the opportunity to provide lots of problems but documentation to substantiate deductions claimed on these returns. Mr. Doe informed using I instead of we Mr. XX that due to his financial circumstances he could not pay the balance due. A helps. review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the • In letter 3, we meantime, the IRS has placed his account in currently-not-collectible status. We highlighted the explained to Mr. Doe that while the account is in currently-not-collectible status, interest apology. The writer continues to accrue, and we will apply any subsequent refunds due him to the open of the letter decided balance. an apology is With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. needed. We will make changes to improve the apology in letter 4 after the next segment of the video. Once again, I want to apologize for any inconvenience or frustration Mr. Doe may have experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. Sincerely, Local Office Play Video C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 29 30 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e A Few Tips On Apologies: 3. Apologize when appropriate. Don’t build "wiggle room" in your apology. Avoid terms that imply we aren’t sure we did anything wrong like, "any inconvenience we may have caused." If we need to apologize for a mistake we made, we must do • If we made an error, apologize. it in a straightforward, open manner: "I am sorry for the We don’t want to sound defensive. If an IRS employee inconvenience we caused you." Also, don’t "like to made a mistake, we should apologize even though we apologize." Just do it: "I apologize…" ourselves did not cause the problem. When we respond to a letter written to the IRS, our response If we decide an apology is appropriate for our letter, speaks for the entire organization. make the apology in a open and straightforward manner. For example, "I apologize for the poor service • If we provided a service, don’t apologize. Mr. Doe received." If we have simply answered a question about tax law or sent the reader a publication or form, we do not need to apologize. Use instead a sentence like, "I hope this information is useful in responding to Mr. Doe." • If we should apologize, make a sincere apology appropriate for the situation. Instead of "I am sorry for the inconvenience," be more specific with "I am sorry we applied your payment to the wrong account." C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 31 Video Exercises: Instructions: Choose the apology you would like to caused. His patience and cooperation are appreciated. receive if you were in a similar B. Please tell Mr. Doe I am sorry for the inconvenience situation. we caused him and appreciate his patience and cooperation. Exercise 1 A. Please apologize to your constituent for the poor Answer: B service that was provided to him and ensure him that this incident is not an example of the service we strive to insure taxpayers. Pause Video B. Please apologize to Mr. Doe for the poor service he Pause video here for additional exercises. received. Answer: B Exercise 2 A. We are so sorry Mr. Doe received such poor service in his 5 attempts to contact the IRS. Our goal is to provide optimal service world wide, and we hope his contacts in the future meet his high expectations. B. I am sorry Mr. Doe received such poor service. Our goal is to provide good customer service, and I hope his contacts with us in the future are positive. Answer: B Exercise 3 A. We certainly want to apologize for any delay and frustration experienced by you in trying to get your refund. B. I apologize for the delay and frustration you experienced in trying to get your refund. Answer: B Exercise 4 A. Please extend our sincere apologies to your constituent for any inconvenience we may have 32 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercise on Apologies Instructions: In Letters 1 and 2, assume you need an apology. Write an apology, keeping the tone conversational; and fix any other problems you find. Letter 1 (Our response was late.) This letter is in response to your inquiry dated June 1, 2000 on behalf of your constituent, Ms. Jane Doe. She is concerned that she still has not received her $4,653.98 refund for 1999. We have found that the Red Service Center processed your constituent’s return in March, and through an oversight the check was not mailed to her. When she spoke with Mr. Smith, he could find no record of her refund. We discovered the problem was in his database. We have resolved the problem and are sending the check to her today. It will include the interest due as well. If I can help in any way, please call me at (111) 222-3333. Letter 2 (Our response was late.) I am responding to your letter of November 3, 1999, on behalf of your constituent Mr. John Doe. Mr. Doe, an IRS employee, contacted your office about personnel problems he was having. We resolved Mr. Doe’s problems to his satisfaction in July. He was selected for a temporary promotion into a higher graded position, and he was retroactively promoted for the period prior to his selection. I hope this information is helpful. If you have any questions, please call me at (111) 222-3333. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 33 34 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 35 Suggested Answers Letter 1 I apologize for the delay in responding to your inquiry dated June 1, 2000 on behalf of your constituent, Ms. Jane Doe. She is concerned that she still has not received her $4,653.98 refund for 1999. We found the Red Service Center processed Ms. Doe’s return in March, and through an oversight did not mail the check to her. When she spoke with Mr. Smith, he could find no record of her refund. We discovered the problem was in his database. We have resolved the problem and are sending the check to her today. It will include the interest due as well. I am very sorry Ms. Doe had to wait six months for her check. I am also sorry for the inconvenience the incorrect information caused. If I can help in any way, please call me at (111) 222-333. Letter 2 I apologize for the delay in responding to your letter of November 3, 1999, on behalf of your constituent Mr. John Doe. Mr. Doe, an IRS employee, contacted your office about personnel problems he was having. We resolved Mr. Doe’s problems to his satisfaction in July. His manager selected him for a temporary promotion into a higher graded position and retroactively promoted him for the period prior to his selection. I hope this information is helpful. If you have any questions, please call me at (111) 222-3333. 36 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e In this letter, we changed phrases like I would like to apologize, any inconvenience, and might have caused. Also, if we should apologize, let’s just do it and not want to do it. If we can identify a specific error we made or a delay in responding, we should make our apology as specific as possible to the situation. For example, if we believe the individual did not receive good customer service, we can use a more specific apology such as: I am sorry Mr. Doe received poor customer service from an IRS employee. We will follow-up on his complaints so that other taxpayers do not experience similar problems. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 4: Apology Improved By Removing Wiggle Room IRS Letter 4: Apology Improved by Removing Wiggle Room 37 The Honorable YY ZZ Letter 4 Member, U.S. House of Representatives Local Street Address • In letter 4, we highlighted three topics we can use as headings in letter 5. In the next segment of the video, we will talk about the value of headings in our letters. Suite City, State Zip Dear Congressman ZZ: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns; namely that the IRS subjected him to needless audits, and in general, that the IRS mishandled his case. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. Upon receipt of his request for relief, the local office assigned the case to Mary YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my deductions and exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This request required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. We completed a review of the file, as requested, and determined that Mr. Doe could not substantiate the expenditures he had claimed on his Individual Income Tax Return, Form 1040 for tax year 1995. Specifically, we determined that he was not entitled to a deduction for mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. In addition, there was no allowance for contributions made to an Individual Retirement Account (IRA) because the financial institution that held the IRA did not acknowledge the existence of the IRA. With regard to the exemptions, the IRS did not allow Mr. Doe to deduct the exemptions for the children, A and B Doe, as another party claimed them on a tax return, and he could not substantiate that he provided more than half of their support. The IRS disallowed the other exemption, C. Doe, because the child was 21, and Mr. Doe could not verify that he provided more than half the support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. Jim XX, of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was 38 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. Mr. Doe also raised the issue of repetitive audits. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one the constituent used on the return. When he contacted the IRS and informed us of his address change, we complied with his request for the transfer to the local IRS office in City, State. The IRS continued the audit in City, and offered him the opportunity to provide substantiation for the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This effort usually requires that the auditor include subsequent years' returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to provide documentation to substantiate deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS has placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any subsequent refunds due him to the open balance. With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. Once again, I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. • We took out words like any and might. Once we decide an apology is appropriate we should avoid words that imply, “I’m not sure I really want to apologize” Sincerely, Local Office Play Video C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 39 40 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Organize Your Document To help us remember, we use Joe Florian’s analogy Readers want to read the main idea followed by the from his book on writing: supporting details, stacked in neat layers. Each layer supports the layer above it. The way you organize your document determines how easily your reader will be able to follow the logic of your message. Bottom Line Up Front We don’t want to lose our readers by making them wait too long for the main idea. Writers write differently than readers read. Writers will meander through a maze of information until they reach the conclusion. The reader doesn’t want to go down that path with the writer. Because readers don’t have a lot of time, they want the bottom line up front. That means after we have done our research and analysis, we should turn our document upside down and put the answer at the top. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 41 Use Format To Make Documents Inviting Use as few words as possible, and put the code citations in brackets at the end of the sentence or paragraph. Parallel construction means we use the same grammatical construction for all the items in a set. For We use format to get the reader’s attention. example, "I came, I saw, I conquered" uses the grammatical construction of noun/verb. In the example above, the bulleted statements are in a question format and are complete sentences. 42 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Using bolded headings, bullets, and short paragraphs adds white space. White space invites the reader to LIKE WE ARE YELLING. Bulleted lists are easier to read than lists embedded in a paragraph. Keep punctuation for bullets simple: read now, not later. • Put a period at the end of each complete sentence. Headings summarize a section of our document. They let the reader skim the document quickly and • Put no punctuation at the end of incomplete sentences. find the parts they want to read. They also help the A set of bullets will be either all complete sentences or all incomplete sentences. Keep bullets parallel by using the same grammatical construction. reader follow the logic of our information. Bold, underlining, and italics draw our reader’s attention to the parts of the document we don’t want them to miss. One emphatic technique we never want to use is all Pause Video Pause video here for additional exercises. caps. USING ALL CAPS MAKES THE READER FEEL C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 43 44 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Bullets and Headings Instructions: Put a general sentence as the first line of each paragraph, and then: •Add the supporting sentences as bulleted lists. •Begin each bullet with a capital letter. •Put a period at the end if the bulleted words form a sentence. (To decide if the words are a sentence, when it’s not obvious, look only at the bulleted words, not the tag line. If the bulleted statement gives a command or makes a request, it is called an imperative sentence and you would put a period at the end of it.) •Put nothing at the end if the words don’t form a sentence. •Use a verb, when possible, to begin each bullet. Example A: (incomplete sentences) The law allows you to file by: •Using a tax professional •Filing through a personal computer •Calling taxes in over the phone •Submitting a paper return Example B: (complete sentences) The law allows you to: •Use a tax professional. •File through a personal computer. •Call taxes in over the phone. •Submit a paper return. 1.Compliance for transfer pricing is based on several principles. The appropriateness of taxpayers’ transfer pricing practices must be verified along with the reasonableness of the transfer pricing practice. Contemporaneous documentation must show the reasonableness of their transfer prices and be available to the IRS. (topic sentence) • • • • C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 45 2.The 1993 amendments to the Act made the net adjustment penalty apply where a taxpayer did not try to comply with the arms length standard. Also the penalty applied if contemporaneous documentation was not written or if a taxpayer failed to provide that documentation to the IRS within 30 days of the request. (topic sentence) ___________________________________________________________________________________________________ • • • 3.Distributions from a qualified plan must begin by the 60th day after the close of the plan year in which the latest of certain events occurs: When the participant attains the earlier of age 65 or the normal retirement age under the plan, or the 10th anniversary of the year the participant began to participate in the plan, or the date the participant terminates service with the employer [section 401(a)(14) of the Code]. (topic sentence) • • • 4. The ABC specialists offer both case-related experience and tax law expertise. Memoranda are issued to provide guidance of specific issues. The ABC specialists teach training classes and participate in writing and reviewing training materials in their areas of expertise in cooperation with the IRS Corporate Education International Institute. Finally, the ABC specialists act as liaisons among local, area, and national office counsels. (topic sentence) • • • • • 46 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 47 Suggested Answers 1. A. Compliance for transfer pricing is based on four principles. Taxpayers can do this by: •Verifying the appropriateness of their transfer pricing practices • Using reasonable transfer pricing practices •Keeping contemporaneous documentation showing their transfer pricing is reasonable •Making their contemporaneous documentation available to the IRS or B. Compliance for transfer pricing is based on four principles. Taxpayers must: •Verify the appropriateness of their transfer pricing practices. •Use reasonable transfer pricing practices. •Keep contemporaneous documentation showing their transfer pricing is reasonable. •Make their contemporaneous documentation available to the IRS. 2.The 1993 amendments to the Act made the net adjustment penalty apply if taxpayers did not: •Try to comply with the arms length standard. •Write contemporaneous documentation. • Give the documentation to the IRS within 30 days of the request. 3.Distributions from a qualified plan must begin by the 60th day after the close of the plan year in which the latest of three events occurs: •The participant attains the earlier of age 65 or the normal retirement age under the plan. •The participant reaches the 10th anniversary of the year he/she began to participate in the plan. •The participant terminates service with the employer [section 401(a)(14) of the Code]. 4. The ABC specialists do the following things: •Offer both case-related experience and tax law expertise. •Issue guidance on specific issues. •Teach training classes. •Participate in writing and reviewing training materials in their areas of expertise with the IRS Corporate Education International Institute. •Act as liaisons among local, area, and national office counsels. 48 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Headings Instructions: This exercise has two letters, each with several paragraphs. Read the paragraph under the line, and then write a heading that summarizes it. Letter 1 I am responding to your letter of August 18, 2000 to Charles Rossotti, Commissioner of Internal Revenue about section 457 of the Internal Revenue Code (the Code). (heading 1) _________________________________________________________________________ Section 457 is a deferred compensation plan, an arrangement between an employer and employees in which the payment of compensation is postponed. The section regulates the income tax treatment of compensation for services deferred by an individual under an eligible deferred compensation plan of an eligible employer, such as a state or local government entity or a tax-exempt organization. The section also says the IRS taxes the compensation deferred under an eligible plan and the income assigned to this deferred compensation only for the year the deferred amounts are "paid or made available" to the participant or beneficiary, not for the year deferred. (heading 2) _________________________________________________________________________ The Constructive Receipt Doctrine shown in section 451 of the Code and shown, for public and tax-exempt employers, in section 457 governs the tax consequences of the deferred compensation plans. Under the Constructive Receipt Doctrine of income, taxpayers pay tax on an item of income if they have an unrestricted right to decide when that item of income is paid. This principle was expressed in a 1930 Supreme Court case, Corliss v. Bowers, 281 U.S. 376 (1930) in a statement by Justice Holmes that "[i]ncome that is subject to a man’s unfettered command and that he is free to enjoy at his own option may be taxed to him as his income, whether he sees fit to enjoy it or not." Taxpayers constructively receive income in the year it is available even though they do not actually receive it. But they could receive it any time they ask for it. Letter 2 I am responding to your letter dated August 22, 2000, on behalf of your constituent, Mr. John Doe. Mr. Doe questions the legality of the tax Form W-9, Request for Taxpayer Identification Number (TIN) and certification. He also asks us to investigate ABC, a collection agency in State. (heading 1) _________________________________________________________________________ Individuals or businesses (payors) file a Tax Form W-9 with the IRS to give us the following information: • Verification the TIN given to the payor is correct • Certification the payee is not subject to backup withholding • Certification the payee is an exempt recipient The payor can change the Form W-9 as long as the substitution is similar and still gives the above information. Also, the payor does not have to send the form to us. For your information and convenience, I have enclosed our form for you. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 49 (heading 2) _________________________________________________________________________ Usually we do not investigate a business unless we have firm evidence of noncompliance with the federal tax laws. We welcome information that may show noncompliance; however, Mr. Doe would have to give us additional information showing noncompliance. Once we received information from him, we would review it. But because of IRS disclosure restrictions, we then could not tell him whether or not we would investigate the company (section 6103 of the Internal Revenue Code). 50 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 51 Suggested Answers Letter 1 Heading 1: Explanation of Section 457 of the Code Heading 2: Explanation of the Constructive Receipt Doctrine Letter 2 Heading 1: The Legality of Tax Form W-9 Heading 2: The IRS Policy on Investigating a Business 52 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e IRS Letter 5: Headings Added to Help the Reader Follow the Information paragraphs throughout the letter, which tell the reader the three major topics we planned to answer in this letter. Using headings helps our readers skim through the document to find the information they need. The headings also bring to our attention the fact that some of the paragraphs have more than one idea. To avoid ambiguity, we want to make sure we have only one idea in each: • Letter • Paragraph • Sentence • Word The heading should be an umbrella statement that covers all the information that follows. Or, in other words, everything in the paragraph following the heading should support that one idea. Also, all of our headings should use parallel construction. In other words, use the same grammatical construction. For example, each heading below begins with a noun. • Denial of Deductions and Exemptions on 1995 Tax Return • Audits Yearly Since 1990 • Allegations of Harassment Because headings stand out on their own, we did not underline the change in letter 5. We added the headings, but now we can see the information in the paragraphs that follow the headings do not always support our main idea. Headings help us see places where our message does not flow logically. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 5: Headings Added to Help the Reader Follow the Information In letter 5, we added headings taken from the introductory paragraph and other 53 The Honorable YY ZZ Letter 5 Member, U.S. House of Representatives Local Street Address Suite • We will work on organizing the information in letter 6 and later versions. • In this letter we highlighted some ideas we can format City, State Zip Dear Congressman ZZ: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns; namely that the IRS subjected him to needless audits, and in general, that the IRS mishandled his case. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. as bullets in letter 6. Upon receipt of his request for relief, the local office assigned the case to Mary YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my deductions and exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This request required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. We completed a review of the file, as requested and determined that Mr. Doe could not substantiate the expenditures he had claimed on his Individual Income Tax Return, Form 1040 for tax year 1995. Specifically, we determined that he was not entitled to a deduction for mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. In addition, there was no allowance for contributions made to an Individual Retirement Account (IRA) because the financial institution that held the IRA did not acknowledge the existence of the IRA. • Headings help us identify information that does not belong in this paragraph. Denial of Deductions and Exemptions on 1995 Tax Return With regard to the exemptions, the IRS did not allow Mr. Doe to deduct the exemptions for the children, A and B Doe, as another party claimed them on a tax return, and he could not substantiate that he provided more than half of their support. The IRS disallowed the other exemption, C. Doe, because the child was 21, and Mr. Doe could not verify that he provided more than half the support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. Audits Yearly Since 1990 Jim XX, of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was unhappy with the outcome, he understood why the IRS disallowed the deductions and 54 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e exemptions. Mr. Doe also raised the issue of repetitive audits. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one the constituent used on the return. When he contacted the IRS and informed us of his address change, we complied with his request for the transfer to the local IRS office in City, State. The IRS continued the audit in City and offered him the opportunity to provide substantiation for the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This effort usually requires that the auditor include subsequent years' returns. In this • Headings help us see places where are information does not flow logically. case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to provide documentation to substantiate deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS has placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any subsequent refunds due him to the open balance. Allegations of Harassment With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. Once again, I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. Sincerely, Local Office C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 55 56 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e IRS Letter 6: Use Bullets to Highlight Information technique highlights the information and makes it easier and faster to read. When using bullets and headings, we want to make sure we use parallel construction for all the items in the set. Using parallel construction means we use the same grammatical construction in each bullet. We use a tag line to introduce our bullets: We began a number of improvements last year that have continued this year by: Then, each bullet begins with an ing form of the verb: • Expanding our telephone service to 24 hours a day, 7 days a week • Hiring and training additional staff • Introducing new technology that allows us to direct calls to the next available assistor in any of our call sites Again, because our bullets draw attention to the information, we did not underline that change in the letter. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 6: Use Bullets to Highlight Information In letter 6, we formatted some of the information using bullets and hanging indents. This 57 Letter 6 The Honorable YY ZZ Member, U.S. House of Representatives Local Street Address Suite City, State Zip Dear Congressman ZZ: • In the first paragraph, we expanded on our headings from letter 5 and put them into 3 bullets to help organize the I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns; namely that: • The Internal Revenue Service (IRS) denied deductions and exemptions on his 1995 return. • The IRS has subjected him to annual audits since 1990. • An IRS auditor harassed him. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. information. THis preview helps the reader by telling him or her what they can expect in this letter. • In letter 6, we highlighted some wordy phrases where we can substitute strong verbs in letter 7. 58 Upon receipt of his request for relief, the local office assigned the case to Mary YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally. I order the IRS to cease its abuse and persecution of me." This request required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. Denial of Deductions and Exemptions on 1995 Tax Return Ms. YY asked the Examination Division to review Mr. Doe’s case. It found that Mr. Doe could not substantiate the deductions and exemptions he claimed on his Individual Income Tax Return for tax year 1995: • He could not take a deduction for mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. • He could not claim contributions made to an Individual Retirement Account (IRA) because there was no record of his IRA with the financial institution. • He could not deduct the exemptions for the children A and B, as another party had claimed them on a return, and he could not verify that he provided more than half of their support. • He could not claim C. Doe because the child was 21, and Mr. Doe could not verify that he provided more than half of his support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Jim XX, of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. Audits Yearly Since 1990 Mr. Doe also raised the issue of repetitive audit. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one the constituent used on the return. When he contacted the IRS and informed us of his address change, we complied with his request for the transfer to the local IRS office in City, State. The IRS continued the audit in City and offered him the opportunity to provide substantiation for the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This usually requires that the auditor include subsequent years' returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to provide documentation to substantiate deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS has placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any subsequent refunds due him to the open balance. Allegations of Harassment With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. Once again, I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. Sincerely, Local Office Play Video C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 59 60 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Choose Words Carefully Gobbledygook is unclear, wordy jargon that makes readers uncomfortable. This type of writing takes time and energy. Our Which version is easier and more likely to get the Choice Of Words sets the tone. results we want? "By copy of agreement, we are requesting that our XX Service Center effect corrections on records. To ensure proper distribution of future notification regarding your tax information, please return the enclosed request card to the address stated therein." Or Words are symbols that represent things, people, actions, and ideas. They also represent us when we "Please update your answers to the questions on the choose them for our documents. Sometimes, using the enclosed card so we will have the correct address if wrong word can confuse our reader or misrepresent us. we need to contact you about your return." We want our writing to be open, straightforward, and honest so that our readers will have confidence in the Here is another example of gobbledygook taken service we give. from an IRS letter: We can improve our choice of words when we do the "The current Protection Program processes provide following: statistics valuable to improving the program and •Avoid gobbledygook. measuring levels of success within the currently •Use specific, concrete words. known universe of fraud as well as direction toward •Use strong verbs. emerging areas. Based on the additional data derived •Avoid false subjects. by your methodology and capabilities, we cannot •Eliminate wordy phrases. make a quantitative determination of the value-added •Avoid redundancies. prospect toward improvement in the Protection Program. Our current processes deal with resubmission Avoid Gobbledygook of rejected forms, whether through electronic filing or paper, to the same fraud detection criteria as the original submission. These criteria are tested and supported quantitatively, and they are regularly reviewed and adjusted, as necessary." What does this mean? It's so full of buzzwords and jargon that it has lost its meaning. We need to make our writing work for us; this type of writing does not work for anyone. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 61 We want our writing to be as clear and unambiguous We should use words that help us get our message across in the most effective way possible. as possible. Below in the left column are some commonly used words we should replace with the concrete ones in the right column. Don’t Use: Use: Correspondence Letter Necessitate Need Proceed Go Render Give Ramification Results Demonstrate Show Use Specific, Concrete Words Apprise Tell Additional More Provide Give, Says (The law says) Determine Decide Activate Start Aggregate Whole Formulate Make Effectuate Cause Requisite Needed Financial resource Money Utilization Use Commence Begin Component Part Fabricate Lie, Build 62 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Use Strong Verbs Maybe the first sentence means, "We wanted to emphasize customer service first and compliance Verbs are the power words in English. The more we second." use verbs that show action, the clearer we make our writing. Below are some examples of strong verbs. Maybe the second means, "Employees weren’t working because something interrupted their tasks." Not This: This: Has applicability to Applies to But we are only guessing. We don’t want our readers Make improvements to Improve Give emphasis to Emphasize Make an assessment Assess Make a suggestion Suggest Avoid False Subjects to have to guess at our meaning. We would never remember the first version of this proverb. We remember the second version because it is simple, construction. straightforward, and uses parallel False subjects usually begin with one of the examples above. They often occur at the beginning of a C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 63 sentence and displace the true subject. example: For There is a part of your return that is illegible. Subsequent to After Get Rid Of Wordy Phases It’s better to say: Owing to the fact that Because Part of your return is illegible. False subjects can also appear within sentences: We decided that there were some deductions that we could not allow. The false subject there weakens the sentence and adds unnecessary words. The sentence is stronger this way: We could not allow some deductions. Avoid Redundancies Redundant words add no value to our documents. Try to eliminate them from your documents. Here are some more examples: This: Not This: Problem Unsolved problem Ten Total of ten Circumstances Surrounding circumstances Result Resultant effect Separate, Distinct Separate and distinct Essentials Important essentials Combine Unnecessary words get in the way of good Combine together communication. Here are some more examples of Planning Advance planning how you can eliminate wordy phrases. Attached Attached hereto Not This: This: Afford an opportunity Let, Allow Results Consequent results Eight, 8 Eight (8) Based on the fact Based on Due to the fact that Due to During which time When For the purpose of For, To Involves the necessity of Needs to Since the time when Since Making a purchase Buy 64 Pause Video Pause video here for additional exercises. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Gobbledygook Instructions: Rewrite these sentences in plain language. 1. The persons in charge must provide for the expenditure of the funds in a manner consistent with charitable purposes. 2. Sufficient documentation must be gathered by the applying organization to allow a determination that the applying organization meets all of the statutory requirements for recognition of tax-exempt status. 3. I have reviewed this situation with Mr. Doe today and have conveyed to him the substance of the correspondence. 4. Upon receipt of your inquiry, our research indicated that on May 22, 2000, a refund in the amount of $541.35 should have been scheduled to be issued to you. 5. Our records demonstrate that your constituent has rendered his quarterly deposits as overdue four times in the last three years. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 65 66 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 67 Suggested Answers 1.The people in charge must spend the funds for charitable purposes. (NOTE: Persons is seen in legal documents, but we don’t have to use it even when we are explaining the law. In conversational English, use person in the singular only. You could also just say "Those in charge . . ." and get rid of the problem.) 2. The applying organization must have enough documentation to show it meets the requirements for tax-exempt status. 3. I talked with Mr. Doe today and told him what the letter said. 4. We should have refunded $541.35 to you on May 22, 2000. 5. Our records show Mr. Doe paid his quarterly deposits late four times in the last three years. 68 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Specific, Concrete Words Instructions: Rewrite the sentences using simple, specific, concrete (not abstract, vague) words. 1.We will apprise you of the commission’s determination on or before December 1, 2000. 2. The law provides that you must satisfy certain requirements. 3. I trust that this information will be of assistance to you in addressing your concerns. 4. To secure this waiver, IRS Form 5329 must be filed by the taxpayer. 5. The State Program is described as a taxpayer if it issues or receives bonds that purport to be tax-exempt. 6. We must receive your payments in a timely manner if you desire to abstain from penalties. 7. You are permitted to deduct a certain amount for your vehicular conveyance when it is used for occupational purposes. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 69 70 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 71 Suggested Answers 1. We will tell you the commission’s decision by December 1, 2000. 2. The law says you must meet certain requirements. 3. I hope this information is helpful. 4. To get the waiver, you (or Mr. Doe) must file Form 5329. (NOTE: Secure can mean many things. Use a word that means exactly what you want to say.) 5. The State Program is considered a taxpayer if it issues or receives tax-exempt bonds. 6.We must receive your monthly payments by the 15th of each month if you want to avoid penalties. 7. You can deduct a certain amount for your automobile when you use it for work. 72 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Strong Verbs Instructions: Rewrite the sentences using strong verbs and plain language. 1. I cannot make a comment on matters involving specific organizations. 2. Mr. Doe asked when the IRS would make the decision to accept or deny his Offer in Compromise. 3. The allowable deductions for medical expenses are different from the ones for business expenses. ______________________________________________________________________________________________________ __________________________________________________________________________________ 4. We provided an issuance of the prepayment regulations under section 148. 5. He sent a request for a private letter ruling. 6. He must make a report of any disability pension he may secure from any source. 7. An individual can have a deduction for the cost and upkeep of work clothes. 8. I will make the suggestion that the example be clearer in the next printing. 9. Mr. Doe has inquired as to whether these vouchers would be available to all taxpayers. 10.We will give a summary of our report on the topic. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 73 74 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 75 Suggested Answers 1. I cannot comment on matters involving specific organizations. 2.Mr. Doe asked when the IRS would accept or deny his Offer in Compromise. 3.The allowable deductions for medical expenses differ from the ones for business expenses. 4.We issued the prepayment regulations under section 148. 5. He requested a private letter ruling. 6.He must report any disability pension he receives from any source. 7.An individual can deduct the cost and upkeep of work clothes. 8. I will suggest the example be clearer in the next printing. 9.Mr. Doe asked if these vouchers would be available to all taxpayers. 10.We will summarize our report on the topic. 76 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on False Subjects Instructions: Rewrite the sentences below, removing the false subjects (subjects that carry no meaning, like There was/It is) and using plain language. 1. There are times when the IRS is obligated to contact third parties. 2. It should be understood, however, that the persons owning the remainder interest in the property cannot claim a deduction. 3. There is the possibility that the partnership has other options. 4. There are additional limitations applicable to both defined benefit plans. 5. It has been discovered that Mr. Doe’s application is not on file. 6. There are several revenue rulings that allow you a deduction the cost of the program. 7. There was a penalty charged for the underpayment when the second installment was posted to the wrong account. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 77 78 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 79 Suggested Answers 1. The IRS must contact third parties in some situations. 2.The people owning the remainder interest in the property cannot claim a deduction. 3. The partnership may have other options. 4.Additional limitations apply to both defined benefit plans. 5. Mr. Doe’s application is not on file. 6.Revenue rulings allow you to deduct the cost of the program. 7.We charged a penalty for the underpayment when we posted the second installment to the wrong account. 80 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Wordy Phrases Instructions: Rewrite the sentences below removing the wordy phrases. 1.The newly issued final regulation augments currently existing guidance with respect to the taxability of taxexempt organizations offering tours. 2. We are still in the process of gathering information from the non-requesting spouse. 3.It would appear from the Internal Revenue Service’s administrative file that the Does’ 1992 and 1993 federal income tax returns were selected for audit in November 1994. 4.After the exchange of a large amount of information and several attempts at resolution, the parties were unable to reach a mutually agreeable settlement. 5.A review of the evaluation reflects that Mr.Doe’s supervisor used a variety of techniques, none of which are mandated or precluded if they assist her to credibly determine the level of performance by Mr. Doe. 6.I assure you that throughout this matter, it has been this office’s goal to collect only the proper amount of tax from Mr. and Mrs. Doe. Just as important, it is also the government’s goal to do this with the highest degree of integrity, efficiency, and fairness. 7.We do possess the Tax Year (TY) 1997 state individual income tax return data that was used to tabulate income revenue collection contributions. (NOTE: Avoid lists of nouns strung together.) C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 81 8.According to the law, scholarships or grants received by individuals who accept these gifts for the purpose of a program for qualified tuition in conjunction with other expenses at an institution of higher education are excluded from the gross income of the recipient. 9.As regards the payment of interest by the IRS on estimated payments, there are no provisions in the federal tax law that provide the means for the IRS to make a payment of interest on estimated payments prior to the due date of the federal tax return; however, interest will be paid on a taxpayer’s overpayment of tax if the refund is not processed within 45 days from the date the return was filed. 82 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 83 Suggested Answers 1.The final regulation gives more guidance on the taxability of tax-exempt organizations offering tours. 2.We are getting information from the non-requesting spouse. 3.We selected the Does’ 1992 and 1993 federal income tax returns for audit in November 1994. 4.After several attempts to resolve the case, the parties were unable to agree. 5.Mr. Doe’s supervisor used several allowed techniques to help her decide Mr. Doe’s performance level. 6.Our goal is to collect the proper amount of tax from Mr. and Mrs. Doe with integrity, efficiency, and fairness. 7.We have the 1997 tax data we used to tabulate revenue collections by state. 8.Mr. Doe can exclude from his gross income the amount of his scholarship or grant from a program for qualified tuition and expenses at an institution of higher education. 9.The law does not let the IRS pay interest on estimated payments received before the due date of the federal tax return; however, we pay interest on tax overpayments if we do not process the refund within 45 days from the due date of the tax return. 84 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Redundancies Instructions: Remove the redundant words. 1.It is absolutely essential that the Code define the contribution plans clearly. 2.Mr. Doe’s subchapter S corporation now currently provides services in the capacity of an independent contractor. 3.If Ms. Doe does not send the information in the period of time designated above, she will incur penalties. 4.We found five (5) returns with the same error. 5.In our advanced preplanning, we started with the idea of checking 500 returns from that center. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 85 86 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 87 Suggested Answers 1. The Code must define the contribution plans clearly. 2. Mr. Doe’s subchapter S corporation provides services as an independent contractor. 3. If Ms. Doe does not send the information by the above date, she will incur penalties. 4. We found five returns with the same error. 5. We started with the idea of checking 500 returns from that center. (NOTE: We can only plan, not preplan.) 88 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e IRS Letter 7: Use Strong Verbs Using strong verbs in our documents: • Reduces the number of words in our sentences • Avoids a bureaucratic tone • Improves clarity • Saves time for our readers Weak use of verb Strong verb made improvements in improved conduct further studies study give emphasis to the result emphasize the result made use of used has application to our program applies to our program We underlined the strong verbs we used to replace the wordy phrases we highlighted in letter 6. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 7: Use Strong Verbs For example: 89 Letter 7 • To prepare for the next segment of the video, in letter 7, we highlighted some examples of false subjects. The Honorable YY ZZ Member, U.S. House of Representatives Local Street Address Suite City, State Zip Dear Congressman ZZ: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns, namely that: • The Internal Revenue Service (IRS) denied deductions and exemptions on his 1995 return. • The IRS has subjected him to annual audits since 1990. • An IRS auditor harassed him. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. Upon receipt of his request for relief, the local office assigned the case to Mary YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This required that the Examination Division review the file. Mr. Doe requested that Examination begin the process immediately. Denial of Deductions and Exemptions on 1995 Tax Return Ms. YY asked the Examination Division to review Mr. Doe’s case. It found that Mr. Doe could not substantiate the expenses he claimed on his Individual Income Tax Return for tax year 1995: •H e could not deduct the mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. • He could not claim contributions made to an Individual Retirement Account (IRA) because there was no record of his IRA with the financial institution. • He could not deduct the exemptions for the children A and B Doe, as another party had claimed them on a return, and he could not verify that he provided more than half of his support. • He could not claim C. Doe because the child was 21, and Mr. Doe could not verify that he provided more than half of his support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. 90 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Jim XX, of my staff, contacted Mr. Doe and explained the above. Although Mr. Doe was unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. Audits Yearly Since 1990 Mr. Doe also raised the issue of repetitive audits. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one the constituent used on the return. When he contacted the IRS and informed us of his address change, we complied with his request and transferred his case to the local IRS office in City, State. The IRS continued the audit in City and offered him the opportunity to substantiate the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This usually requires that the auditor include subsequent years' returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to substantiate the deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS has placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any subsequent refunds due him to the open balance. Allegations of Harassment With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. There is an independent organization to investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. Once again, I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. Sincerely, Local Office C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 91 92 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e IRS Letter 8: With False Subjects Removed There is There are There was There were It is It was In letter 8, we rewrote the sentences to get rid of false subjects. We underlined the replacements for the false subjects. In letter 8, we also highlighted wordy phrases; extraneous words; long, complicated words; and the word that, an overused word. If the sentence is clear without using the word that, please leave it out. For example: We researched his accounts and found that Mr. XX had non-employee compensation for tax years 1998 and 1999. Instead use: We researched his accounts and found Mr. XX had non-employee compensation for tax years 1998 and 1999. Another example: Our records show that the IRS sent a letter to the taxpayer on June 15, 1998. Instead use: Our records show the IRS sent a letter to the taxpayer on June 15, 1998. We will remove or replace these words in letter 9. Also, the Commissioner's Secretariat recently sent out a memo saying we no longer need Letter 8: With False Subjects Removed False subjects carry no meaning. We should avoid using: to spell out the Internal Revenue Service the first time we use it in a letter. We will also make that change in letter 9. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 93 The Honorable YY ZZ Letter 8 Member, U.S. House of Representatives Local Street Address Suite City, State Zip Dear Congressman ZZ: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe has raised a number of concerns, namely that: • The Internal Revenue Service (IRS) denied deductions and exemptions on his 1995 return. • The IRS has subjected him to annual audits since 1990. • An IRS auditor harassed him. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting relief from the hardship he was experiencing. The National Office transferred his request to the local office in State to better serve your constituent. Upon receipt of his request for relief, the local office assigned the case to YY, a caseworker. Mr. Doe requested "...immediate reinstatement of my exemptions for 1995 and withdrawal of the Notice of Deficiency and its interest and penalty in its entirety for 1995. Additionally, I order the IRS to cease its abuse and persecution of me." This request required that the Examination Division review the file. Mr. Doe immediately requested that Examination begin the process. Denial of Deductions and Exemptions on 1995 Tax Return Ms. YY asked the Examination Division to review Mr. Doe’s case. It found that Mr. Doe could not substantiate the expenses he claimed on his Individual Income Tax Return for tax year 1995: • He could not deduct the mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. • He could not claim contributions made to an Individual Retirement Account (IRA) because the financial institution had no record of his IRA. • He could not deduct the exemptions for the children A and B Doe, as another party had claimed them on a return, and he could not verify that he provided more than half of their support. 94 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e • He could not claim C. Doe because the child was 21, and Mr. Doe could not verify that he provided more than half of his support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require that we request information regarding all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. Jim XX, of my staff, contacted Mr. Doe and explained the above. Although he was unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. Audits Yearly Since 1990 Mr. Doe also raised the issue of repetitive audits. We reviewed our files and found that we did not contact him for tax years 1991, 1992, and 1993. The Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent an audit notification for tax year 1995 because this was Mr. Doe’s last known address and the one he used on the return. When he contacted the IRS and informed us of his address change, we complied with his request and transferred his case to the local IRS office in City, State. The IRS continued the audit in City and offered him the opportunity to substantiate the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. This effort usually requires that the auditor include subsequent years' returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe to have the opportunity to substantiate deductions claimed on these returns. Mr. Doe informed Mr. XX that due to his financial circumstances he could not pay the balance due. A review of his financial statement indicated that this was accurate. The IRS discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS has placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any subsequent refunds due him to the open balance. Allegations of Harassment With regard to Mr. Doe’s allegations of harassment, please be assured that the IRS takes these matters very seriously. The Congress established an independent C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 95 organization to investigate these complaints. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and subsequent corrective action because of employee privacy issues. Once again, I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. Sincerely, Local Office Play Video 96 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Basic Grammar Rules for Editing Your Document C. The Congress passed a law today, which will permit new deductions. Answer: A After writing your first draft, allow the document to cool for a while. Take a break from the document to clear your mind. Then, apply some basic grammar Exercise 2 rules. We will look at the following commonly confused A. Your refund, which remains unclaimed from your 1990 return, is the one we wrote about. words: That and Which Affect and Effect Bi-words, such as bimonthly, biweekly Principal and Principle May and Can Entitled and Titled B. Your refund that remains unclaimed from your 1990 return is the one we wrote about. Answer: B Exercise 3 A. We follow the laws that have a lot of history We will also look at demonstrative pronouns. That and Which around them. B. We follow the laws, which have a lot of history around them. Answer: B We use this sentence to help us remember when to use that and which: People that live in glass houses shouldn’t throw stones. If we took out "that live in glass houses," we would change the meaning of the sentence. The sentence doesn’t mean "people shouldn’t throw stones." Only Video Exercises: a special category of people, those that live in glass Instructions: Choose the sentence that correctly houses shouldn’t throw stones. Therefore, the clause uses that or which. "that live in glass houses is essential.” (Note: The sentence should read, "People who live in glass Exercise 1 houses," but the example is an easy way to remember A. The Congress passed a law today that will permit the rule.) new deductions. B. The Congress passed a law today which will permit new deductions. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 97 In general, we overuse the word that. If the clause makes sense without that, please leave it out. Some examples: Unnecessary that: The IRS records showed that we reviewed and closed out tax years 1995, 1996, and 1997 as satisfied. That removed: The IRS records showed we reviewed and closed out tax years 1995, 1996, and 1997 With affect and effect, there are actually four words, as satisfied. which is why there is so much confusion around them. Two of them are the common ones we use everyday. Here’s how to tell them apart: Unnecessary that: What documentation is needed to show that the debtor cannot pay the debt? Affect = verb The new law affected the Earned Income Tax Credit. That removed: What documentation is needed to show the debtor cannot pay the debt? Effect = noun The new law will have an effect on the number of people who qualify for the Earned Income Tax Credit. Affect and Effect Use this rule for the commonly used affect and effect, Video Exercise: and you will be right 99% of the time. Instructions: Choose the sentence that correctly uses effect/affect. A. The new law also affected the Earned Income Tax Credit. B. The new law also effected the Earned Income Tax Credit. Answer: A The other two uses of effect and affect are rarely used in our everyday correspondence. 98 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Principal and Principle They are the use of effect as a verb – as in effect a change. It means to bring about. The other use of affect is as a noun. It is used in psychology and refers to our ability to feel emotions. The word affection comes from it. Bi-Words Video Exercise: Instructions: Choose the sentence that correctly uses principal/principle. A. The principal reason for the lien was nonpayment of back taxes. Video Exercise: B. The principle reason for the lien was nonpayment of back taxes. Instructions: Choose the correct sentence. Answer: A A. You must send your payments bimonthly. The word principal confuses some writers because it also means the person who is the head of a school. B. You must send your payments biweekly. The principal is our pal. Teachers used this technique C. You must send your payments semimonthly. to help us spell the word. It may help to remember that the principal of a school is the main teacher. Over Answer: ? Don’t use bi-words; they are too confusing. the years we dropped teacher and were left with principal, which means main. Don’t use the bi-words. We don’t want our readers to Principle with the "le" is a noun meaning "belief, moral wonder whether they have to do something twice a standard, or law governing the operation of month or every other month. something." C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 99 Can and May Do not use it to mean titled as in the title of a book or report. Correct use of entitled: She was entitled to the deductions. Correct use of titled: Thank you for the opportunity to respond to your report titled "The IRS Needs to Improve Customer Service." Or you could just say: Thank you for the opportunity to respond to your report, "The IRS Needs to Improve Video Exercises: Customer Service." Instructions: Choose the sentence that correctly Demonstrative Pronouns uses can/may. RULE 6 Demonstrative Pronouns A. Mr. Doe may pay the money he owes in monthly installments. The demonstrative pronouns are: This These That Those B. Mr. Doe can pay the money he owes in monthly installments. Answer: B void using a demonstrative pronoun without A defining the noun it refers to. When referring to what the law allows, it is better to say, "The taxpayer can pay electronically or send in a paper copy." Using may sounds like we are granting them permission. Try to avoid vague uses of demonstrative pronouns An example of an appropriate use of may is: (usually when the pronoun is used without the noun it "A taxpayer may be eligible for penalty abatement in is describing). In letters we review, we often see the certain circumstances." pronoun this used to refer to the complete sense or meaning of the previous sentence. Unfortunately, the (These next two sections on entitled and titled and word isn’t strong enough to carry the full meaning and demonstrative pronouns are not covered in the video, leaves our readers confused about what we are but we thought you might find them helpful.) referring to. Entitled and Titled Below is an example of the vague use of a demonstrative pronoun we often see in our letters: Entitled and titled are also commonly confused words. Use entitled to mean a right to do or have something. 100 This is in reply to your letter dated… C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e This what? This letter, this report, this discussion, this Exercise 1 answer, this argument… A. Because of disclosure restrictions we cannot comment on specific actions we take regarding A much better opening to a letter is: This letter is in reply to your inquiry dated… your constituent. B. Because of disclosure restrictions, we cannot comment on specific actions we take regarding your constituent. An even better and more personal opening is: Answer: B I am responding to your letter dated… Put in a comma to separate an introductory phrase from the main sentence. Another example of the vague use of a demonstrative Exercise 2 pronoun: A. Mr.Doe retired but he is working as a contractor for This is a nationwide scheme, which has the company. resulted in false claims totaling millions of dollars. B. Mr. Doe retired, but he is working as a contractor for the company. It’s better to say: Answer: B This nationwide scheme has resulted in Separate two sentences joined by a coordinating false claims totaling millions of dollars. conjunction with a comma. What are coordinating conjunctions? We use a memory device to help keep them straight. We call them the BOYFANS. Basic Punctuation Rules for Editing Your Document The final step in preparing your document is to review common punctuation rules. Punctuation supports structure, logic, and meaning. It makes our writing easier to follow. Punctuation shows the pauses and stresses of everyday speech. Let’s look at the rules for some commas that give us so much trouble. Using Commas Video Exercises: Coordinating conjunctions often join two independent Instructions: Choose the sentence with the correct clauses. When you use them to join two independent use of the comma. clauses, put a comma before the conjunction unless C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 101 the clauses are short and closely related. You can also You should use the comma before the and to prevent use a semi-colon in place of the coordinating the reader from misunderstanding the document. conjunction. Exercise 5 Exercise 3 A. The 401(k) plans were then "frozen," and the receiver A. To deduct the ordinary expenses which they are terminated the plans. entitled to they must keep records. B. 401(k) plans were than "frozen", and the receiver B. To deduct the ordinary expenses, which they are terminated the plans. entitled to, they must keep records. Answer: A Answer: B Put commas inside quotation marks. That rule is the Just as we learned in the exercise on that and which, put same for periods too. This convention is now standard commas around nonessential information. in the United States. British usage places commas and periods inside or outside the quotation marks, depending Exercise 4 on whether or not they are part of the quotation. A. To deduct the ordinary expenses, they must keep records of the cost, date, place and purpose of each Semicolons and colons are always placed outside of trip. closing quotation marks. B. To deduct the ordinary expenses, they must keep Place dashes, question marks, and exclamation marks records of the cost, date, place, and purpose of each inside of the quotation marks if they are part of the trip. quotation. Otherwise, place them outside of the quotation marks. Answer: B In a list or series of items, put a comma before the and. Some of you may have learned the comma before the and in a series of items is optional. Some punctuation rules have changed over time, and this is one of those rules. A court case in Washington, DC, emphasized the importance of that comma before the and. A woman died and left her property to her four children: Joan, Eric, Jenny and Joseph with no comma before the and. The Court ruled the property should be split three ways: one portion to Joan; one portion to Eric; and one portion split between Jenny and Joseph. The judge used the analogy of toast, bacon and eggs. He said toast, bacon, Pause Video and eggs are three items on a plate. While toast, bacon and eggs are two items, toast and an omelet. 102 Pause video here for additional exercises. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on That and Which Instructions: Circle the correct word. Then, if you choose which, put in the commas. 1. A. It was part of a law that/which the Congress passed last year to help small businesses. (You are giving them "nice to know but not necessary to know" information.) B. It was part of a law that/which the Congress passed last year to help small businesses. (You are referring to a law the Congress passed last year, as opposed to a law the Congress passed three years ago.) 2. Employers can choose the calculations that/which work best for their situations. 3. The adjustments that/which Mr. Doe made to the return, may be incorrect. 4. "Some people believe with great fervor preposterous things that/which just happen to coincide with their selfinterest." 5.The Code sets minimum funding standards that/which qualified retirement plans must meet. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 103 104 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 105 Suggested Answers 1. A. It was part of a law, which the Congress passed last year, to help small businesses. B. It was part of a law that the Congress passed last year to help small businesses. (NOTE: You can just drop that so the sentence reads "It was part of a law the Congress passed last year to help small businesses.") 2. Employers can choose the calculations that work best for their situations. (The phrase explains what calculation to choose.) 3. The adjustments that Mr. Doe made to the return may be incorrect. (The clause explains what adjustments may be incorrect.) 4. "Some people believe with great fervor preposterous things that just happen to coincide with their self-interest." (The phrase explains what things.) 5.The Code sets minimum funding standards that qualified retirement plans must meet. (The phrase defines what minimum funding standards.) 106 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Affect and Effect Instructions: Circle the correct word. 1. The law will not affect/effect your case. 2. We don’t know the long-term affect/effect of the law on our objectives. 3. The bill will affect/effect a change in school construction bonds. 4. Affect/effect is a feeling or emotion, not a thought or action. 5. The law had an unexpected affect/effect on the tax credits available to working mothers. 6. They tried to pass the bill for the affect/effect it would have on elections. 7. They tried to pass the bill in time to affect/effect the elections. 8. The affect/effect of the debate was to show the benefits and disadvantages of the bill. 9. The new regulations will take affect/effect January 1. 10. The controversial section would affect/effect health care providers. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 107 108 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 109 Suggested Answers 1. The law will not affect your case. 2. We don’t know the long-term effect of the law on our objectives. 3.The bill will effect a change in school construction bonds. (In your letter, you would just say “The bill will change school construction bonds.”) 4. Affect, in psychological jargon, is a feeling or emotion, not a thought or action (with the accent on the first syllable). 5. The law had an unexpected effect on the tax credits available to working mothers. 6. They tried to pass the bill for the effect it would have on elections. 7. They tried to pass the bill in time to affect the elections. 8. The effect of the debate was to show the benefits and disadvantages of the bill. 9. The new regulations will take effect January 1. 10. The controversial section would affect health care providers. 110 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Bi-Words Instructions: Rewrite these sentences so you don’t have to use the bi-word. 1. We have arranged for Mr. Doe to make bimonthly payments. 2. We spend over a month collecting information for the biannual report. 3. We will send out email notices biweekly. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 111 112 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 113 Suggested Answers 1.A. We have arranged for Mr. Doe to pay twice a month (or on the 1st and 15th of each month, if you need to be specific). B. We have arranged for Mr. Doe to pay every two months (or on the first of January, March, May, July, September, and November, if you need to be specific). 2. We spend over a month collecting information for the January and July reports. 3. We will send out the email notices twice a week (or every two weeks) 114 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Principal and Principle Instructions: Circle the correct word. 1.The principal/principle behind the provision is taxpayer privacy. 2. Closing the tax loophole is the principal/principle reason for our decision. 3. One of the principals/principles behind the modernization effort is to give taxpayers better customer service. 4. Doe is doing the principal/principle work on the bill. 5. He wants this payment to go toward the principal/principle, not toward the interest of the loan. 6. They agreed with him in principal/principle. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 115 116 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 117 Suggested Answers 1. The principle behind the provision is taxpayer privacy. 2. Closing the tax loophole is the principal reason for our decision. 3. One of the principles behind the modernization effort is to give taxpayers better customer service. 4. Senator Doe is doing the principal work on the bill. 5. He wants this payment to go toward the principal, not toward the interest of the loan. 6. They agreed with him in principle. 118 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on May and Can Instructions: Circle the appropriate word. 1.A taxpayer can/may give up to $10,000 a year to an individual. 2. He can/may leave his entire estate to his wife with no estate tax due as long as the value does not exceed $675,000. 3. You can/may find additional information in the enclosed pamphlet. 4. They can/ may file early if the accountant is available. 5. You can/may apply for an installment agreement. 6. Depending on your circumstances, you can/may qualify for an installment agreement. 7. You can/may call me at (111) 222-3333. 8.You can/may have to leave the money in the account until the case is settled. 9. The law can/may change before the end of the year. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 119 120 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 121 Suggested Answers 1.A taxpayer can give up to $10,000 a year to an individual. (A taxpayer has the right to.) 2.He can leave his entire estate to his wife with no estate tax due as long as the value does not exceed $675,000. (He has the right to.) 3. You can find additional information in the enclosed pamphlet. (You are mentally, physically able to. You could also use will here.) 4. A. They can file early if the accountant is available. (They have the right to.) B. They may file early if the accountant is available. (They might decide to.) 5. You can apply for an installment agreement. (You have the right to.) 6. Depending on your circumstances, you may qualify for an installment agreement. (You may or may not qualify.) 7. You can call me at (111) 222-3333. (You have the right to.) 8.You may have to leave the money in the account until the court settles the case. (You perhaps will have to.) 9. The law may change before the end of the year. (It possibly will change.) 122 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Additional Exercises on Punctuation Instructions: Insert punctuation where it is needed. 1.At 8:00 a.m. we will meet with the taxpayer in Room 214. 2. You filed your 1996 return on time and we credited your overpayment to your account for the 1994 tax year. 3. I apologize for the delay however we wanted to be thorough in our investigation. 4. We adjusted Mr. Doe’s liabilities for 1992, 1993, 1994 and 1995. 5. Although the courts have already ruled on this issue Mr. Doe and others continue to dispute it. 6. We want to comply with the disclosure provisions of section 6103 which prohibit our disclosing tax information to third parties without proper authorization. 7. If a second person tries to electronically file a return using the same SSN the computer will reject it. 8. The computer will reject the return if a second person tries to electronically file using the same SSN. 9. We sent the official rejection letter detailing the appeal process to the last address we had for Mr. Doe. 10."Shall" as used in section 6001 means "must" "must" means "to be required to" and the courts have upheld this definition. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 123 124 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Suggested Answers C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 125 Suggested Answers 1. At 8:00 a.m., we will meet with the taxpayer in Room 214. (NOTE: The comma is optional for three words or less, unless the reader could misread it.) 2. You filed your 1996 return on time, and we credited your overpayment to your account for the 1994 tax year. 3. I apologize for the delay; however, we wanted to be thorough in our investigation. 4. We adjusted Mr. Doe’s liabilities for 1992, 1993, 1994, and 1995. 5. Although the courts have already ruled on this issue, Mr. Doe and others continue to dispute it. 6. We want to comply with the disclosure provisions of section 6103, which prohibit our disclosing tax information to third parties without proper authorization. 7. If a second person tries to electronically file a return using the same SSN, the computer will reject it. 8. The computer will reject the return if a second person tries to electronically file using the same SSN. (NOTE: Sentence #7 contains an introductory clause, but #8 doesn’t.) 9. We sent the official rejection letter, detailing the appeal process, to the last address we had for Mr. Doe. (NOTE: Put commas around information that is not essential.) 10. A. "Shall" as used in section 6001 means "must," "must" means "to be required to," and the courts have upheld this definition. B."Shall" as used in section 6001 means "must." "Must" means "to be required to," and the courts have upheld this definition. C. "Shall" as used in section 6001 means "must"; "must" means "to be required to," and the courts have upheld this definition. (NOTE: If you used a comma or period to separate the two "musts," put it inside the quotes. If you use a semicolon between them, put it outside the quotes.) 126 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e We avoid wordy phrases that add no value to our written communication. Unnecessary words take time and often make our documents difficult to read. In letter 9 we removed wordy phrases; extraneous words; long, complicated words; and the word that. In letter 9, we also highlighted the long paragraph under the heading, Audits Yearly Since 1990. Because this paragraph has more than one idea, we broke it into 4 paragraphs on different topics. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 9: Use Plain Language to Make Your Message Clear Letter 9 – Use Plain Language to Make Your Message Clear 127 The Honorable YY ZZ Letter 9 Member, U.S. House of Representatives Local Street Address Suite City, State Zip Dear Congressman ZZ: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe raised several concerns that: • The IRS denied deductions and exemptions on 1995 return. • The IRS has subjected him to annual audits since 1990. • An IRS auditor harassed him. On December 14, 1999, Mr. Doe filed an Application for Taxpayer Assistance Order, Form 911, with the National Office, requesting hardship relief. The National Office transferred his request to the local office in State. The local office assigned the case to Mary YY, a caseworker. Denial of Deductions and Exemptions on 1995 Tax Return Ms. YY asked the Examination Division to review Mr. Doe’s case. It found Mr. Doe could not substantiate the expenses he claimed on his Individual Income Tax Return for tax year 1995: • He could not deduct the mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. • He could not claim contributions made to an Individual Retirement Account (IRA) because the financial institution had no record of his IRA. • He could not deduct the exemptions for the children A and B Doe, as another party had claimed them on a return, and he could not verify that he provided more than half of their support. • He could not claim C. Doe because the child was 21, and Mr. Doe could not verify that he provided more than half of his support. While IRS realizes that C. Doe is handicapped, normal examination procedures require us to ask for information on all sources of support including items such as Social Security benefits, payments from social service agencies, as well as the taxable sources of income. 128 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Jim XX, of my staff, contacted Mr. Doe and explained these procedures. Although Mr. Doe was unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. Audits Yearly Since 1990 Mr. Doe also complained of repetitive audits. We reviewed our files and found we did not contact him for tax years 1991, 1992, and 1993. For tax year 1994, the Underreporter Program proposed additional tax. We assessed the tax after we received no response from him. For tax year 1995, the Franklin Service Center sent an audit notification because this was Mr. Doe’s last known address and the one used on the return. When he contacted the IRS with his address change, we complied with his request and transferred his case to the local IRS office in City, State. The IRS continued the audit in City and offered him the opportunity to substantiate the deductions. He could not do so. When the IRS conducts an audit, we make every effort to bring the taxpayer into full compliance. Normally, the auditor will examine subsequent years' returns. In this case, the IRS closed the 1995 tax year separately due to statute concerns while the 1996 and 1997 tax years remained open to allow Mr. Doe time to substantiate deductions claimed on these returns. Mr. Doe told Mr. XX that he could not pay the balance due. A review of his financial statement confirmed this claim. Mr. XX discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. In the meantime, the IRS placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any future refunds due him to the open balance. Allegations of Harassment As for Mr. Doe’s allegations of harassment, please be assured the IRS takes these matters very seriously. We refer matters such as these to the Treasury Inspector General for Tax Administration (TIGTA). Generally, TIGTA does not notify us of the outcome of the investigation and any corrective action because of employee privacy issues. I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have any questions or concerns, please contact me at (111) 222-2222. Sincerely, Local Office C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 129 130 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Letter 10: Final IRS Letter In the final version of our IRS letter, we broke up the large block of text under the Audits Yearly Since 1990 heading, removed redundancies, added a few personal pronouns, and used concrete words. We hope you think this letter is an improvement over the Letter 10: Final IRS Letter original one. We will count on you to tell us ways we can make it even better. C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 131 The Honorable YY ZZ Letter 10: Final IRS Letter • Almost final. We can always make improvements. Member, U.S. House of Representatives Local Street Address Suite City, State Zip Dear Congressman ZZ: I am responding to your letter dated March 15, 2000, on behalf of your constituent, Mr. J. Doe. Mr. Doe raised the following issues: • The IRS denied deductions and exemptions on his 1995 return. • The IRS has subjected him to annual audits since 1990. • An IRS auditor harassed him. On December 14, 1999, Mr. Doe requested hardship relief by filing an Application for Taxpayer Assistance Order, Form 911. The National Office transferred his request to the local office in State, which assigned the case to Mary YY, a caseworker. Denial of Deductions and Exemptions on 1995 Tax Return Ms. YY asked the Examination Division to review Mr. Doe’s case. It found Mr. Doe could not support the expenses he claimed on his Individual Income Tax Return for 1995. Without supporting information, he could not: •Deduct mortgage interest, as he was paying a private investor who was holding the mortgage he claimed. • Claim contributions made to an Individual Retirement Account (IRA) because the financial institution had no record of his IRA. •Deduct the exemptions for the children A and B Doe, as another party had claimed them on a return, and he could not verify that he provided more than half of their support. •Claim C. Doe because the child was 21, and Mr. Doe could not verify he provided more than half of his support. While the IRS realizes that C. Doe is handicapped, normal examination procedures require us to ask for information on all sources of income including Social Security benefits, payments from social service agencies, and taxable sources of income. Jim XX, of my staff, contacted Mr. Doe and explained these procedures. Although Mr. Doe was unhappy with the outcome, he understood why the IRS disallowed the deductions and exemptions. 132 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Audits Yearly Since 1990 Mr. Doe also complained of repetitive audits. We reviewed our files and found we did not contact him for tax years 1991, 1992, and 1993. Our Underreporter Program proposed additional tax for tax year 1994. We assessed the tax after we received no response from him. The Franklin Service Center sent the audit notification for tax year 1995 to Mr. Doe’s last known address, which he used on his return. When he contacted the IRS with his address change, we complied with his request and transferred his case to the local IRS office in City, State. The IRS continued the audit in City and offered him the opportunity to verify his deductions. He could not do so. When the IRS conducts an audit, we work to bring the taxpayer into full compliance. This effort usually requires the auditor to examine previous years' returns. In Mr. Doe's case, the IRS closed the 1995 tax year separately due to statute concerns and left the 1996 and 1997 tax years open to allow him time to support the deductions claimed on these returns. Mr. Doe told Mr. XX he could not pay the balance due. Our review of his financial statement confirmed his claim. Mr. XX discussed with Mr. Doe the option of submitting an Offer-in-Compromise to settle the debt. I am enclosing information on offers-incompromise. In the meantime, the IRS placed his account in currently-not-collectible status. We explained to Mr. Doe that while the account is in currently-not-collectible status, interest continues to accrue; and we will apply any refunds due him to the open balance. Allegations of Harassment As for Mr. Doe’s allegations of harassment, the IRS takes these matters very seriously. We referred his allegations to the Treasury Inspector General for Tax Administration. We cannot disclose the results of the investigation or any corrective actions because of employee privacy issues. I apologize for the inconvenience and frustration Mr. Doe experienced in trying to resolve this matter. If you have questions, please contact me at (111) 222-2222. Sincerely, Local Office Enclosure C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e 133 134 C h a n g i n g a B u r e au c r a c y O n e P a r a g r a p h at a T i m e Video Evaluation Form Please take a minute to give us feedback on the video. Please circle your response and/or write in comments. We appreciate your input to help us improve our program. Please fax your form to 202-622-4733 or mail to: Internal Revenue Service, Attention: Mary Dash, CL:LA Room 3236, 1111 Constitution Ave., N.W., Washington, DC 20224 1. 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