Mr. Chris Workman
Small Business Affairs
Internal Revenue Service
1211 ICC Bldg
Washington, DC 20224
re: Comments on Proposed IRS Publication #334: "Tax Guide for Small Business"
Dear Chris:
Thank you for this opportunity to comment on changes which are being made to IRS Publication 334. The most important observation I have is that the IRS is no longer providing a single source of comprehensive information to the small business owner. Publication 334 to me served as a guide to help any small businessman walk through the complexities of the tax code. Business owners who do everything, including their own tax research, reports and returns, at least had access to a book that would see them through from start to finish.
Since the new book applies mainly to sole proprietors, other books will be targeted to s-corps, partnerships and small corporations. Perhaps you should make that more clear on the title page.
Also, the proposed publication deals so lightly with nuts and bolts issues, I fear it will not be as helpful as the old Publication 334. A good example if the explanation of the self employment tax. The IRS' targeted audience is self-employed. The treatment in the 1995 Publication 334 is 5 pages long. For your average customer, this would have provided enough instruction to do the work. (I say this with some confidence since I used to file as a sole proprietor and use Publication 334.) The new publication provides only one paragraph on the self-employment tax and refers the business to another publication. If the taxpayer had not read that cross reference while standing at the post office or the IRS office where he picked up the publication, he will now have to make another trip. It might be helpful to list on the cover issue areas which are now to be covered in depth elsewhere so that someone scanning the cover has a chance to figure out that he needs more books.
I like the "Tips" idea. It would be wonderful if the "Tips" were actually cued each year by the frequency of mistakes on a given form in the previous year. For example, if your scanners detect that a certain deduction is being overlooked, it would cue that as deserving a "Tip" in the next publication. In this way, the IRS could help the taxpayer to correct mistakes and learn.
You need a more comprehensive index which I am sure you will include. I always like the order form page of Publication 334, I hope you are intending to keep that. The "Important Changes for 19XX" section of the old Publication 334 was another section that was helpful to me and alerted me to things I should be watching for.
I concur with you that we need to be thinking about giving the customer what he needs and not drowning him (and the federal treasury) in mountains of unneeded paper. I suspect someday, we will just fire up our home PC, answer a series of questions, tap a modem and be done with it. But an extended publication 334 did have some useful purposes. I hope you will forward this to whomever is working on the project and I would like a copy as soon as they are available.
Good luck on your project!
Russ Orban
Asst. Chief Counsel