Here is a question for all of the public and non-profit entities out there.

I am struggling with a retention decision.  We have tax exempt bonds that typically take 30 years to mature.  The regulations I am referencing so far include:

26 USC 6001 - states that records must be kept...I am sure we are all familiar with this one.
26 CFR 1.6001-1(a),(c), and (e) - states that records must be kept
26 CFR 1.148-5(d)(6)(iii)(E) - retain records with the bond documents until 3 years after the last outstanding bond is redeemed

My issue is that the IRS states that all records related to the bond should be kept for the life of the bond + 3 years.  This includes all records related to expenditures.  As you can imagine when we issue a bond to pay for building a new facility there are thousands of invoices that are related to this project.  So according to the IRS guidelines, we need to keep these invoices for possibly 33 years (life of bond + 3 years).

My questions:  

Are other public entities retaining the actual invoices or are you retaining reports that detail the expenditures?
Does anyone have experience with IRS audits in regards to these records?  
How are other public entities addressing this requirement?
Any insight or suggestions that I can use to manage such a burdensome recordkeeping requirement?


Thanks! 
Cheryl Westlund 
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Public Records & Records Retention Administrator     ■     Purdue University     ■     (765) 494-9218 



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