Comments on Revised 2019 Form 1040 Letter

On behalf the members of the National Association of Tax Professionals, we submitted feedback to the IRS and Department of Treasury on the revised 2018 Form 1040. Since our members advise millions of taxpayers on tax-related matters, assist them with compliance responsibilities, and represent them before the IRS, we are uniquely poised to offer practical observations regarding the revised 2018 Form 1040.

The Department of the Treasury fulfilled its promise to deliver a postcard-sized tax return, thus simplifying tax filing for millions of Americans. Clearly, the simple part is solely the decision as to which form to use since the proposed Form 1040 replaces the current Forms 1040-EZ and 1040-A. What is not so simple are the accompanying schedules.

The proposed Form 1040 removes several pertinent lines from the body of the form and moves them to an attached schedule. This change may simplify filling out the form for those taxpayers who don’t need those lines, but conversely it may inadvertently prevent eligible taxpayers from claiming deductions or credits of which they are entitled. When all the applicable lines are contained on one form – only two full sheets of paper – it is much easier for taxpayers to quickly see all potential deductions and credits.

NATP requested feedback from its members regarding the new Form 1040. We received approximately 540 comments that were overwhelmingly unfavorable. Many of the comments focused on the observation that the form is essentially no different than it was previously, with the removed lines simply moved to another sheet of paper as an attached schedule. Many felt this does not accomplish the goal of simplification, but rather it creates confusion.

In our opinion, making the form smaller and removing lines only to move them to other schedules does not equate to simplification.

Review the complete letter submitted

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