The Treasury Department’s Office of Tax Policy released the 2022-23 Guidance Priority List recommending application of the agency’s funds for the one year period beginning July, 2022.

This list “focuses resources on guidance items that are most important to taxpayers and tax administration,” including 26 specific projects under the header “tax administration.” In addition, on the legislative front, some important new regulations addressing reporting requirements relating to digital assets, regulations under §7602(c)(1) regarding notifications of third-party contacts, additional direction on the BBA partnership audit scheme and clarification of the recent legislative changes addressing mandatory e-filing of certain returns.

There are some items on the list worth noting including, supervisory approval of proposed penalties under § 6751(b), a much needed revision of Circular 230 addressing practice before the IRS, regulations under § 6501 defining what sort of “return” initiates the statute of limitations for assessment and new guidance under § 6662 regarding the accuracy related penalty.

Lastly, with respect to the business taxpayer, there could be new regulations addressing the “last known address” issue for business taxpayers.  This is a procedural area of the law that is in a constant state of disarray and is in need of a complete overhaul.