Tom Cullinan quoted in Tax Notes Federal article
In an article published in Tax Notes Federal on August 7, 2023, Atlanta-based Shareholder Tom Cullinan was quoted in a roundup of sources discussing monetized installment sales as listed transactions.
During the interview, Cullinan outlined that in the late 1990s and early 2000s the IRS listed many transactions, however, has named far fewer since then, so the proposed listing rules issued over the last year are notable. He further explained that listing transactions raise the issue of available IRS resources.
Cullinan also referenced that it would make sense “from the IRS perspective for it to audit 100 percent of the taxpayers it knows to have engaged in a transaction that it has found to be abusive,” noting the fact that the listing is an acknowledgment that the agency considers the transaction as such.
“But the IRS has limited resources, and that decision carries an opportunity cost,” said Cullinan. “If the IRS intends to audit all of the taxpayers that register their participation in listed transactions, that may act as a cap on the number of the transactions that the IRS can list, unless it finds ways to reduce the resources usage, such as through voluntary compliance initiatives or similar means.”
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