Office of Chief Counsel Notice 2007-012 (2007).

Department Internal Office of of the Revenue Chief CounselTreasury Service

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Notice

CC-2007-012

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May 14, 2007

Procedure and Administration Subject: Realignment Cancel Date: May 14, 2008

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Purpose

This notice is intended to advise Chief Counsel employees of the realignment within the office of the Associate Chief Counsel (Procedure and Administration). The realignment eliminates the existing subsidiary divisions within PA and creates seven branches. Procedure & Administration’s subject matter has been realigned into four practice areas.

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Description of Realignment:

Effective May 14, 2007, Procedure and Administration will be realigned. The Office will continue to be led by the Associate Chief Counsel (Procedure and Administration). There will now be three Deputy Associate Chief Counsel (Procedure and Administration). PA’s subsidiary legal divisions, Administrative Provisions and Judicial Practice, Collection, Bankruptcy and Summonses, and Disclosure and Privacy Law, will no longer exist. Instead, PA’s attorney staff will be assigned to one of seven branches. Each branch will be responsible for one of four practice areas and will report to the Associate. The organization and management of the Legal Processing Division will not be affected by this realignment.

The following are brief descriptions of the new branches’ subject matter.

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.

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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 complete lists of subject matter responsibilities and branch contact information are set out in the

- attachments. PA’s entries in the code and subject directory have been revised to reflect the new issue responsibilities and may be accessed on the Chief Counsel intranet at:: —————————————————————————————————- (listed by code section) and for noncode issues at: ————————————————————————————————————————————————————————————————————————-.The organization and management of the Legal Processing Division will not be affected by this realignment.

Every effort is being made to ensure that the transition to the new structure is made as efficiently as possible so that the completion of pending work assignments will not be significantly delayed. Emails regarding pending assignments have been sent (or will shortly be sent) to the offices that have requested the assignment.

Please contact my office with any questions at 622-3400.

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Deborah A. Butler

Associate Chief Counsel

(Procedure & Administration) .

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PA Front Office

Associate Chief Counsel: Deborah A. Butler Deputy Associate Chief Counsel (Guidance): Dominic A. Paris Deputy Associate Chief Counsel (Enforcement): Gary Gray Deputy Associate Chief Counsel (Legislation & Privacy): Margo L. Stevens Special Counsel (Tax Practice and Procedure): Peter Reilly Special Counsel:

George Bowden Richard Goldstein (on detail to Branch 7) Tom Kane Phil Lindenmuth (on detail to Branch 7) Kristine Roth Henry Schneiderman Kathryn Zuba

Front Office Contact Number: 202-622-3400

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FAQ Regarding PA Realignment

Q1. Did PA give up any of its jurisdiction to the other organizations?

No, PA retained the subject matter jurisdiction that was within the three former PA subsidiary legal divisions.

Q2. I deal with a person in LPD when I need documents released to the public. Who do I talk to now?

Your LPD contact will not change. No changes have been made to the organizational structure of LPD. You should expect to conduct business as usual with that organization.

Q3. Before the organizational change I was working with an attorney in APJP Br3 on a particular issue. Who do I talk to now?

You should initially call the same former APJP Br3 attorney. In some cases that attorney will continue to work on the project with you. If that particular project has been reassigned, the attorney will ensure that you get to the right person. You should also receive an email that will notify you of the attorney who is responsible for the assignment in the new branches.

Q4. If I don’t know who to talk to about a particular subject or Code section who should I call?

You should initially consult the Code and Subject Matter directory which will direct you to the correct branch within PA.

Q5. I have an advice request currently pending in a PA branch. How will I know who to contact regarding the request after standup.

A5. On standup, the current PA branches are sending emails to all originators of pending work items in PA advising them as to whom the work item is now assigned and providing contact information. If you did not receive one of these emails, you should contact the original attorney or branch chief, who will be able to provide you with the needed contact information.

Q6. How can I contact the original attorney? Won’t the phone number have changed?

A6. The phone numbers in Outlook and in the CC Phone Directory will be updated immediately upon reorganization. Attorneys’ email addresses will remain unchanged as will their direct phone numbers.

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PA Branch Managers and Contact Numbers

Branch 1:

Chief: James Gibbons STR: Blaise Dusenberry STR: Charles Hall

Contact Telephone Number: 202-622-4910

Branch 2:

Chief: Hap Trice STR: Carol Nachman STR: Brinton Warren

Contact Telephone Number: 202-622-4940

Branch 3:

Chief: Pam Fuller STR: Mitch Hyman STR: Gerry Ryan

Contact Telephone Number: 202-622-3600

Branch 4:

Chief: Peter Devlin STR: Joe Clark STR: Nancy Galib

Contact Telephone Number: 202-622-3630

Branch 5:

Branch chief: Larry Schattner STR: Joe Conley STR: Susan Mosley

Contact Telephone Number: 202-622-3620

Branch 6:

Branch Chief: Richard Goldman STR: Bob Miller STR: Don Squires

Contact Telephone Number: 202-622-7950

Branch 7:

Branch Chief: Charles Christopher STR: Richard Goldstein (Acting for 90 days) STR: Phil Lindenmuth (Acting for 90 days)

Contact Telephone Number: 202-622-4570

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PA Subject Matter by New Branch

Branches 1 & 2

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- 6511-33, except 6532(b)Sanctions 6503, except (b),(c),(e),(f),(h),(j) Suspension of limitations period RRA § 3707 Illegal tax protester designation ,(c), Limitations provisions -

PA Subject Matter by New Branch

Branches 3 & 4

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PA Subject Matter by New Branch

Branch 5

- 11 U.S.C. Bankruptcy 6159 Installment agreements ) 6658 Coordination with title 11 6871-73 Receiverships 7122 Compromises 7526 Low income tax clinics 7528 User fee 31 U.S.C. § 3713 Priority of government claims against decedent’s estates and insolvencies 1398-99 Rules relating to title 11 6036 Notice of qualification as executor or receiver 6408 State escheat laws 6503(b),(h) Suspension of limitations periods (assets in custody of court, cases under title 117121 Closing agreements 7402(a) Jurisdiction of district courts to issues orders 7430 Costs and fees 7432 Civil damages for failure to release lien 7433 Civil damages for unauthorized collection Federal Rules of Bankruptcy Procedure -

PA Subject Matter by New Branch

Branches 6 & 7

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May 14th, 2007 |