DATELINE: June 19, 2007, Chicago
From: Jack B. Siegel
As many of you know, last week the IRS issued a revised Form 990 in proposed form. The proposal represents a signficant and major overhaul to the Form 990. By and large, the IRS has made great strides in improving the form and should be commended for its efforts to date.
Over the course of the summer, we can expect to see law, accounting and compensation firms provide the IRS with comments. We will also see comments from trade groups and major charities. These comments should be welcomed, but they will be filtered through the lens of what is good for charitable organizations. Although an erroneous viewpoint, sometimes this results in comments opposing disclosure and transparency.
Some of you were probably English, journalism, or history majors in college. Consequently, you never expected that you might someday make formal comments in response to an Internal Revenue Service proposal. I hope that your longstanding expectations don't stand in the way of your doing so now.
The Form 990 is more than a tax return. It is an important disclosure document. You don't need to file a FOIA request or hope that a prosecutor makes records public. You don't have to ask for an interview or stake out a charity's headquarters. The Form 990 is a treasure trove of informatino that is just a click away.
With that in mind, I hope you will take some time to review the proposal, and if you have something to say, to then submit a comment letter to the IRS. This is your chance to inform the IRS about your own perceptions of past failings in the Form 990 and request new questions that would facilitate your research, investigative work, or commentary. Don't waste this fleeting opportunity. Comments can be sent to Form990Revision@irs.gov. The comment period is open until September 14, 2007. So put down that mystery and take a tax form to the beach (shore for east coasters).