Saturday, January 24, 2009

IRC 7216

At a meeting of VITA site coordinators of Santa Clara County held on January 22, 2009 at the offices of United Way of Silicon Valley, we were informed about the disclosure and use consents that need to be discussed with taxpayers whose returns we prepared.

The procedure was well described and laid out, but trying to implement it appeared to be pretty time consuming and subsequent guidance scheduled to be published may make it unnecessary.

Information provided to the IRS is meant to be kept confidential and not be made personally identifiable. This is understandable - since nobody likes their information to be made public. However, it would appear that numbers on AGI, refund amounts, tax credits, etc in aggregate that do not identify people personally should not be a big deal. After all, total revenues coming in to the IRS are compiled and published every year.

Secondly, if the information is to be used for the taxpayer for his or her benefit, the permission to do so needs to be sought at the time of the need with specific permission, and not require a record be kept of the decision at the time of preparing the return.

Third, I personally am wary of signing another piece of paper, and I suspect many others too. So explaining to them what they are signing (namely that they are authorizing us to use the information for statistical purposes, but granting permission in writing to use all of the information, and then telling them that they need to sign that so that we can continue providing service to them in the future - as was suggested during the meeting ) is different frwom what we are telling them that we will only report it is aggregate is bound to cause suspicion.

Fourth, being reasonably proficient with the language, the other site coordinators and I have a hard time accepting that this course of action is reasonable. When we have such doubts about its value, it becomes difficult if not impossible to train volunteers in what this is about, and have them try to convey to taxpayers with a language problem just takes away a lot of time from actually helping them with their returns.

For sites that are open during only the tax season, and are present only for preparing taxes and not providing other services, it would appear that the best course of action would be to not bring it up until the public as a whole is educated on the ramifications of what is going on.

What do other coordinators think? Please express your thoughts here by making comments to this posting.

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