February 26, 1996
TO: OPERATIONS COMMITTEE No. 3-96
TAX COMMITTEE No. 6-96
TRANSFER AGENT ADVISORY COMMITTEE No. 9-96
RE: PROPOSED IRS GUIDANCE ON IMAGING SYSTEMS
______________________________________________________________________________
The Internal Revenue Service ("IRS") has released the attached proposed revenue
procedure that would provide guidance to taxpayers that use imaging systems to maintain
their books and records. Section 4 of the proposed revenue procedure sets forth various
requirements regarding reliability and access controls, inspection and quality assurance
programs, retrieval systems, the ability to reproduce legible hard copies and written procedures
that a taxpayer’s imaging system would need to meet. Taxpayers would be permitted by the
proposed revenue procedure to destroy hard copies of imaged documents after the taxpayer (1)
tested the imaging system and ensured that hardcopy documents were being imaged in
compliance with the revenue procedures requirements and (2) instituted procedures ensuring
continued compliance with these requirements.
The IRS has requested that any comments on the proposed revenue procedure be
submitted by March 28, 1996. Please contact the undersigned by March 21 (at 202/326-5832)
with any comments that you would like the Institute to submit.
We will keep you informed of developments.
Keith D. Lawson
Associate Counsel - Tax
Attachment
Note: Not all recipients of this memo will receive an attachment. If you wish to obtain a copy
of the attachment referred to in this memo, please call the Institute’s Information Resource
Center at (202) 326-8304 and ask for this memo’s attachment number: 7659.