[quote=SK in CV][quote=ucodegen]Oh yes, a nit to pick –
[quote=SK in CV]Those cumulative non-deductible contributions are supposed to be reported on tax returns every year (on form 8606), even if no new non-deductible contributions have been made for the tax year.[/quote]
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Pick away. You’re wrong, irrespective of your limited reading of the instructions. Basis of non-deductible IRA’s, net of prior year cost recovery, is reported on line 2 of form 8606. It is practically the only proof that the IRS will accept that you’ve maintained the records. They (The form 8606) can, in fact, be filed as a stand alone form. You can file them late all the way back to 1995, though it’s conceivably possible for failure to file penalties to be assessed. I’ve never seen that penalty assessed for a late filed 8606. I have prepared dozens for clients, in order to fix their improperly prepared returns.[/quote]
Then you are saying that the form wording disagrees or is in dispute with the actual laws governing the reporting? Are you saying that the form instructions are in disagreement with the actual laws governing reporting? The reason why they only want changes is because it (the amounts you report) is being tracked by the IRS. I don’t see how it proves that you have maintained the records – though maybe I am a weird case since I have all my tax records back to at least 1987. If the forms and instructions effectively state file ‘only’ on change, the IRS is on a weak foot legally should they expect more. Are most of the people you are filing for in a position where they are drawing down IRAs? Maybe you are just being more thorough, but I don’t see any ‘requirement’ for the every year filing unless changes – conversely I see support for the argument for filing only on change:
