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May 16, 2007

IRS Tax Attorneys Realign Organization Structure

Tax Litigation

Houston Tax Attorney

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The IRS Office of Chief Counsel employs the IRS’s own tax attorneys.  These attorneys handle most of the civil tax court matters for the IRS. 

The IRS released IRS Office of Chief Counsel Notice CC-2007-012 which says that the Procedure and Administration Section of the Office of Chief Counsel subsidiary legal divisions have been reorganized into seven new branches.

The notice lists these branches and their subject matter as:

Branches 1 and 2

Subject areas: Returns, information returns, withholding, statutes of limitations, interest, penalties, sanctions, ethics, practice before the IRS, Circular 230, innocent spouse, electronic tax administration, powers of attorney.

Branches 3 and 4

Subject areas: Payment, assessment, collection, liens, levies, collection due process, period of limitations on collections, trust fund recovery penalty, jeopardy and termination assessments, refunds, erroneous refunds, joint committee.

Branch 5

Subject Areas: Bankruptcy, installment agreements, offers in compromise, receiverships, closing agreements, attorney fees, low income tax clinics, user fees.

Branches 6 and 7

Subject Areas: Court procedure, confidentiality of return information, privacy act, FOIA, summonses, burden of proof, disaster relief, combat zone, examinations, informants, arbitration, mediation and alternative dispute resolution, Appeals, rules of evidence, mitigation and equitable doctrines, discover, Fed/State issues, judicial doctrines, privileges, Religious Freedom Restoration Act, Right to Financial Privacy Act.

The Notice goes on to provide new contact information for each branch.

Taxpayers should take note of this new contact information, as contacting IRS tax attorneys directly is probably the most overlooked avenue for addressing the more challenging procedural tax issues.

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