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Abstract: 

The Tax Reform Act of 1986 extensively revised the Internal Revenue Code and, in the process, “thoroughly overhauled” the IRC’s tax-exempt bond provisions.The IRS has raised legitimate questions as to valid tax-exempt status, resulting in the determination of taxability, and ultimately forcing issuers, counsel, underwriters, and conduit borrowers to pay significant amounts in taxes, penalties, and liability claims. Because the IRS is unlikely to reduce its efforts in this area, attorneys who represent issuers and purchasers of tax-exempt bonds must be aware of the general process by which the IRS and its agents approach a tax-exempt bond examination, and they should be able to recognize when expert bond counsel is necessary.This paper provides an agent’s perspective of the basic process by which the IRS examines tax-exempt bond issuances.

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Affiliations:  1: Institute of Government, Tennessee State University.