[quote=ucodegen]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:
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Based on my experience of teaching classes for CPA’s and EAs on on how to report retirement income for the last decade, and preparing somewhere around 12,000 returns over the last 40 years, I’m telling you what the law is.