IRS Form 1095-C

IRS Form 1095-C

Monday, July 27, 2015

Lowered Expectations from the IRS

In a recent article, "IRS Scales Back to Absorb Funding Cuts",  the author describes how the budget cutbacks in 2014 and 2015 are affecting the ability of the IRS to respond to taxpayer's questions and request for assistance.

If you are the one asking the question, this may be a bad thing, but if you are the one not getting audited, then that could be a very good thing.  One thing is clear, don't expect too much assistance from the IRS.

Here's a perfect example.  After watching a webinar regarding the Affordable Care Act Information Returns filing process, I submitted an email to the AIR mailbox regarding inconsistencies and other issues that I discovered in the presentation material.  In all, there were six questions submitted.  The email was sent on June 23, 2015.  On June 29th, I received a reply where they answered 4 of my questions.

On July 22, they answered one of the remaining two unanswered questions.  Actually, they didn't answer a question as much as agreed to an inconsistency that existed in one of the draft publications and stated that it would be corrected before the publication was finalized.  They also acknowledged the remaining unanswered question would require more research.

So what is the remaining unanswered question that requires so much research?

The question concerned the AIR Submission and Composition and Reference Guide, that is supposed to provide software developers and other transmitters with specifics regarding how to send e-filed ACA data files to the IRS.  Yes, the information is very specific because failure to follow these guidelines will result in your submission being rejected.

One section has to do with the naming of the data files that are submitted through the e-file system.  They did a very good job of explaining the pertinent parts of the file naming convention except for the last 4 digits in the filename which were "000Z".

We could assume that this is an indication that the time stamp that is part of the filename is to be the local time on the user's computer, and the "000Z" is an hour and minute offset to zulu time in the format of HHMM.  However, with the IRS, you never make assumptions, this I asked the following question.

3.  Section 3.2 has a filename format and two sample file names.  However, the timestamp in both of the examples is shown as 010102000Z.  The time portion of a timestamp is normally HHMMSS which relates to the 010102, so what is the 000Z that is added to the end of it?

Evidently, this was a much more complicated question than I thought because two days before e-file testing starts (July 29th, 2015) for the voluntary 2014 year, we are still waiting for a reply to this question.  

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