Are the Principles of Rev. Proc. 64-22 Being Followed Today‪?‬

In Rev. Proc. 64-22 (1) (the Rev. Proc.), then Commissioner Mortimer Caplin set forth some of the principles involved in administering the Internal Revenue Service (Service). In five short paragraphs he succinctly laid out some valid administrative guidelines. Whether the Treasury, the Congress, or even the Internal Revenue Service have paid proper attention to them since that time is open to debate. Of course, just as beauty is in the eyes of the beholder, many broad statements of principle are open to interpretation, perhaps in a manner that justifies the positions being taken in recent years. Thus, the former Chief Counsel for the Service Restructuring Commission stated that the Rev. Proc. summed up the Commission's attitude as to how the Service should operate. He indicated that the Commission wanted the Service to follow the principles and shift from an emphasis on enforcement to one on taxpayer service. Perhaps one can read the Rev. Proc. as having an overarching emphasis on service. On the other hand, it addresses administration of the Internal Revenue Code (Code)and states that the Service should raise meritorious issues and should be relentless in its attack on unreal tax devices and fraud.