Recommended Citation
Jeffery M. Kadet, Letter from Jeffrey Kadet to the Internal Revenue Service Re: Notice 2025-19, 2025-2026 Priority Guidance Plan (2025), https://digitalcommons.law.uw.edu/faculty-articles/1135
Document Type
Article
Abstract
Based on my working experience with numerous clients that spanned over thirty years and my studies over the past twenty-three years both as an academic and in connection with my published articles and governmental submissions, I have identified a number of projects that should be considered a high priority for the Treasury and the IRS. These projects, which are attached as appendices to this letter, cover a number of areas. Importantly, I have not been a paid advisor for over a decade and a half. As such, my recommendations are free of any influence from potentially affected taxpayers. I do not have any “agenda” to benefit any particular taxpayer or category of taxpayers. Rather, my only “agenda” is desiring a system that works better and is fairer for both the government and taxpayers alike.
Notice 2025-19 lists factors that the Treasury and the IRS consider in selecting projects for inclusion in its 2025-2026 Priority Guidance Plan. They include, for example, whether a project (i) involves significant issues relevant to a broad class of taxpayers, (ii) will reduce controversy and lessen the burden on taxpayers or the IRS, (iii) promotes sound tax administration, and (iv) involves existing regulations or other guidance that is outdated, ineffective, or insufficient and that should be modified or expanded. All of the suggestions for projects covered in this submission more than satisfy these factors.