Understanding the Administrative Record: A Comprehensive Guide
Definition & Meaning
An administrative record refers to a comprehensive collection of documents related to a request for determination made to the Internal Revenue Service (IRS). This includes:
- The initial request for determination
- All documents submitted by the applicant to the IRS regarding that request
- Any protests and related papers submitted to the IRS or between the applicant and the IRS
- Relevant tax returns filed with the IRS
- The notice of determination issued by the Commissioner
Legal Use & context
The term "administrative record" is primarily used in tax law and administrative law. It plays a crucial role in proceedings where an applicant seeks a determination from the IRS regarding tax-exempt status or other tax-related matters. Understanding the contents of the administrative record is essential for individuals or organizations navigating IRS procedures, as it can impact their tax obligations and rights.
Real-world examples
Here are a couple of examples of abatement:
Example 1: A nonprofit organization applies to the IRS for tax-exempt status. The administrative record includes their application, supporting documents, and any communications with the IRS.
Example 2: An individual contests a determination made by the IRS regarding their tax filings. The administrative record will consist of their filed returns, the IRS's response, and any protests they submitted. (hypothetical example)