What’s the tax id number of my local Starbucks?

To: Notice.Comments@irscounsel.treas.gov
Subject: Notice 2010-51

Dear Sir or Madam:

I run a small publishing business, and I handle the record-keeping and reporting responsibilities for my business. The new requirement under Section 6041 of the Internal Revenue Code would place impossible burdens on my business.

We often pay for computer equipment, book printing, catalog printing, shipping services, advertising, and other items by check. Those expenditures frequently total more than $600 per vendor to numerous vendors in any given year, and so would be subject to the new reporting requirements. I am familiar with the record-keeping and reporting burden of issuing 1099s, because we have to send 1099s to our authors who receive royalties. Having to issue a Form 1099 to each vendor as well would simply take more time and resources than I can afford.

We use accrual accounting for our business, following IRS rules. The new reporting requirements will force us to do a separate and redundant non-accrual accounting for all of our purchases. This added accounting burden is a serious concern and a significant expense for us.

The preferential treatment of credit cards being exempted from the new reporting requirements will introduce further friction into our economy. We currently pay as much as 5% per transaction in credit card fees. The new rules will put tremendous pressure on businesses to use credit cards for purchases and accept credit cards for payments in order to avoid the new reporting requirements. The costs will be enormous, and the only parties that will benefit will be the merchant account servicers collecting their fees.

I have not seen guidance yet on how the exception for credit cards will interact with the $600 reporting floor, but I am sure that the IRS realizes how confusing this will be for businesses. Will the reporting floor be $600 of non-credit-card purchases, or $600 total if the purchases include any non-credit-card purchases? With the exception for credit cards, should the amount reported include credit card purchases or not? When I purchase items from multiple stores in a chain, how do I know whether to combine them? When totaling my annual purchases, what happens if the vendor has changed ownership or tax structure or otherwise wound up with different tax id numbers for different portions of the year? The potential for confusion and error is enormous.

On a practical level, how do I obtain the tax id number for every vendor from whom I make a purchase? Before this goes into effect, will you require every vendor to put their tax id number on every receipt and invoice? That seems necessary if you are going to realistically expect every business to collect the tax id number of every vendor. Please bear in mind that for small businesses which use the owner's Social Security number as their tax id number, this will dramatically increase the risk of identity theft.

Please change the new reporting requirements so that they apply only to larger business entities, such as persons or entities that employ more than 25 people.

Please change the reporting floor to $5000, so that small purchases do not trigger a requirement to issue a Form 1099.

Thank you for your time and understanding.

Juvenile black-crowned night heron

I’m not certain about the identification as a juvenile black-crowned night heron, but the size and overall appearance are right. Good neck flexibility.




Photos by Michael

Avoid Renewal by Andersen

Renewal by Andersen just wasted 90 minutes of my life. On the bright side, they were finally honest about the fact that the only way they can sell their windows is like a bad timeshare. Informed customers of theirs are unhappy customers, according to the rep I just spoke to.

Renewal by Andersen will only provide pricing if both homeowners sit through the sales pitch, even though we don’t need the sales pitch. It’s infantilizing. We already have some Andersen Woodwright 400-series windows, and we like them. We don’t care if the outside cladding is vinyl like those or the Renewal’s fibrex composite. We’ve looked at glass samples, and wood samples, and we have both types of screen, and we know what windows we want. But we’re not allowed to buy them, because we’re not allowed to know how much they cost.

I’ve seen this sort of high-pressure sales tactic for overpriced timeshares, bad insurance products, and DirectBuy (an incredible scam). And now Renewal by Andersen’s windows. It makes me wonder: What’s so wrong with their windows? Or is it just their pricing that’s bad? Because there’s no way they insist on this if there’s nothing wrong.

Renewal by Andersen has cancelled the appointment they had made for Wednesday morning to measure our windows and give us pricing. So I won’t lose that time as well dealing with Renewal by Andersen.

I’m surprised that this issue didn’t turn up when I searched gardenweb, my usual go-to source for helpful opinions about house products. And the admission that informed customers are unhappy with Renewal by Andersen windows was really startling. If you’re considering replacement insert windows from Renewal by Andersen, I’d reconsider. Take a look at Pella (but not their special low-end Lowes line), Marvin, or Harvey.

Massachusetts primary on Tuesday

For state treasurer, the candidates are Steven Grossman and Stephen Murphy. I’m voting for Steven Grossman, but I won’t be upset if Murphy wins.

For state auditor, I’m voting for Suzanne Bump. She’s got the best chance of beating Glodis, who’s a corruption-prone and racist asshole. Bump also seems like a good person for the job. I’m happy about this vote.

For Governor's Council in the 6th District, there are two candidates on the Democratic side. Terrence Kennedy is campaigning, while Suzanne English-Merullo isn't campaigning. The winner will face Republican Paul Caruccio, who thinks illegal immigration is a major problem in MA. Even though I’m tired of former prosecutors like Kennedy controlling our judiciary, I’m voting for Terrence Kennedy.

For state senate and state rep, nobody’s running against Jehlen, Sciortino, or Garballey. I’m voting for my incumbents for those offices and all others except:

For Attorney General, I’m leaving the ballot blank. Please do not vote for Martha Coakley.