Requests to interview the taxpayer and return preparer during an otherwise normal IRS examination have become somewhat common. During an examination where the government is in possession of potentially incriminating evidence, such requests are routine

2014 Tax Enforcement Priorities - IRS. The international arena will continue to test the enforcement resources of the IRS for many years. For those with undeclared foreign accounts, now is the time to come into compliance - waiting is simply not a viable option. Other examination priorities...

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the IRS offshore...

The IRS revised the Internal Revenue Manual (IRM) providing guidance and clarification regarding the administrative review of FBAR penalties by the IRS Office of Appeals. The IRM is essentially the operational manual providing guidance and procedures for the various functions carried out by the...

The IRS Large Business & International (LB&I) Division recently issued three recent Directives relating to the issuance and enforcement procedures regarding Information Document Requests (IDRs). All LB&I examiners and specialists have recently completed two mandatory IDR training sessions...

The IRS Audit Techniques Guides (ATGs) focus on developing highly trained examiners for a particular market segment or issue. A market segment may be an industry such as construction or entertainment, a profession like attorneys or real estate agents or an issue like passive activity losses,...

Similar cases and similarly situated taxpayers are to be treated in a similar manner with each having the opportunity to have their interests heard and considered. Penalty relief is to be viewed from the perspective of fair and impartial enforcement of the tax laws in a manner that promotes...

The IRS directly interacts with more Americans than any other public or private organization. The Commissioner of the IRS has been delegated the authority to administer and enforce the Internal Revenue laws and has the final administrative authority concerning substantive interpretation of the...