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Phil, are you aware of any specific guidance on these points?

I'm not. My guess would be that if the taxpayer can show a rational basis for the W-4 and is not filing balance due returns without payment in full, there isn't going to be any problem.

Somewhere there are Internal Revenue Manual guidelines for processing W-4 cases. One of these days I'll have to see if I can find them. (Some of the IRM is available online at the IRS site.) While they don't have the force of law, these procedures would at least give us an idea of what the IRS is looking at.

Phil Marti
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