| When Starting a Government Submission Project |
Submit a COGS
Status Sheet by fax or e-mail Janet In at the Tax Section Headquarters as soon as you have identified
a project which will result in a government submission.
The following
projects will require COGS review: comments on proposed or temporary regulations; comments
on pending legislation; comments in response to a notice; comments on or proposals for
revenue rulings, revenue procedures, forms or publications; legislative proposals;
proposals for regulations, etc. Remember, however, that the quality, not quantity, of
submissions to the Government is most important. It is not necessary to express a view
about every conceivable issue.
Let other committees with an interest in the subject
matter (check the IRC
Responsibility List) know what you are doing.
|
| Once you are Assigned a COGS Reviewer |
Keep your reviewer informed of
the status of the drafting of your submission. If possible,
provide your reviewer with an early draft, so he or she
can become familiar with your project, and work with you
to correct any problems. If you decide to abandon the project,
please inform the reviewer, the responsible COGS Vice-Chair,
and Janet In as soon as possible. |
| While Working on the Project |
Make sure that what you write is courteous, balanced, and
intellectually honest. Objectively consider all sides of an issue. Address issues (not the
draftsperson) with fair, tightly-reasoned argument, not mere opinion. Don't be only
negative; offer alternative solutions. Be practical; think about complexity and
compliance. |
| When Completing the Project |
Include a substantive executive summary with every
submission. Indicate the appropriate person within the government entity to receive your
comments.
Include the Standardized Cover
Sheet as the first page of every government submission.
Please make sure that there is compliance with the Statement
of Policy on Conflicts of Interest.
|
| At All Times |
Keep your Council Director informed and involved. Keep
the status of your government submission projects up-to-date on your semi-annual project
summaries.
Use the COGS Project Number on all correspondence.
If you have a question, contact your reviewer, the responsible COGS Vice-Chair, or
the COGS Chair. |
