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On June 18, 1999, Tax Executives Institute submitted the following comments to the Internal Revenue Service on Revenue Procedure 98-25, which relates to record retention requirements under section 6001 of the Internal Revenue Code where all or part of the taxpayer's financial or accounting records are maintained within an automatic data processing (ADP) system. The comments were prepared under the aegis of the Institute's IRS Administrative Affairs Committee, whose chair is Stephen W. Boocock of Allegheny Teledyne, Inc., and represents the work of an ad hoe working group chaired by Yasmin R. Seyal of Aerojet General Corporation, a vice chair of the committee. The following individuals also contributed to the Institute's comments, Barbara Barton of EDS Corporation, Robert J. Evans of MCI Worldcom, Sheldon A. Kimel of Brunswick Corporation; and Daniel T Piekarczyk of Frontier Corp.
On March 16, 1998, the Internal Revenue Service (IRS) issued Revenue Procedure 98-25, 1998-11 I.R.B. 7, prescribing the basic record retention requirements under section 6001 of the Internal Revenue Code where all or part of the taxpayer's financial or accounting records are maintained within an automatic data processing (ADP) system. The revenue procedure updates and supersedes Rev. Proc. 9159, 1991-2 C.B. 841.
Background
Tax Executives Institute is the preeminent association of business tax executives in North America. Our more than 5,000 members represent 2,800 of the leading corporations in the United States and Canada. TEI represents a cross-section of the business community, and is dedicated to the development and effective implementation of sound tax policy, to promoting the uniform and equitable enforcement of the tax laws, and to reducing the cost and burden of administration and compliance to the benefit of taxpayers and government alike. As a professional association, TEI is firmly committed to maintaining a tax system that works - one that is administrable and with which taxpayers can comply.
Members of TEI are responsible for managing the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises. We believe that the diversity and professional training of our members enable us to bring an important, balanced, and practical perspective to the issues raised by Rev. Proc. 98-25. Indeed, TEI has had a long...