Skip to content

IRS Organization Changes and a Hard-Hitting Tax Court Case

June 2, 2017

The IRS has implemented further organizational changes in the examination division. This is particularly true of LB&I (Large Business and International).

Some of the structural changes include the elimination of industry designations and a move to issue-based examinations. LB&I audit examination will now be based on perceived compliance risk. The determination will be based upon the utilization of data analytics and specified staff to “issue spot.” These self-described streamlined audits will quickly target specific areas of IRS enforcement. Agents will move quickly with rapid and focused Information Document Requests or IDR’s. Expect the quick or even preemptive use of IRS summons authority or even quickly closed “unagreed” examinations.

IRS Publication 5125 provides specific information. Taxpayers and their representatives should consult this publication upon receipt of an IRS examination notice as it sets forth the procedural IRS playbook. An important note is that an LB&I examination could have multiple agents with each agent examining a discreet area of examination such as research tax credits, employment taxes, or international issues with each agent issuing separate IDR’s.

Read the article in its entirety: Tax Matters: IRS Organization Changes and a Hard-Hitting Tax Court Case

Sign up to be the first to access our leading legal insights.

The link you have selected will redirect you to a third-party website located on another server. We are offering the link for your convenience. Varnum has no responsibility for any external websites and makes no express or implied warranties about any external websites.

Please be aware that contacting us via e-mail does not create an attorney-client relationship between you and the firm. Do not send confidential information to the firm until you have spoken with one of our attorneys and receive authorization to send such materials.