| N(39)1(10)3-1 |
Nov. 09, 1999 |
| Powers of Attorney and Tax Information Authorizations Received by FAX |
| The Office of Chief Counsel will accept the original, a photocopy or FAX copy of Powers of Attorney (Forms 2848) and Tax Information Authorizations (Forms 8821) without requiring taxpayers to follow-up with an original. |
| N(36)000-3 |
April 26, 1999 |
| Change In Litigating Position |
| This Notice announces a change in the Service's litigating position on whether agricultural cooperative "value-added" payments to retired farmers are subject to self-employment tax under Section 1402. |
| N(36)000-2 |
Jan. 26, 1999 |
| Change In Litigating Position |
| This Notice announces a change in the Service's litigating position with respect to the assessment of I.R.C. § 72(t) tax on early distributions from qualified plans made to satisfy levies under Section 6331. |
| N(35)851-1 |
March 08, 1999 |
| Processing Small Tax Cases and Other Small Cases |
| This Notice addresses the potential impact on the administration of the Internal Revenue laws caused by the increase in the jurisdictional amount for cases eligible for treatment under the "small tax case" procedures prescribed by I.R.C. § 7463. |
| N(35)4(16)(12)-0 |
Dec. 04, 1999 |
| Qualified Offer Rule for Recovery of Reasonable Administrative and Litigation Costs - Section 7430 |
| Provide guidance on Section 7430(c)(4)(E) and (g) regarding the qualified offer rule for the recovery by taxpayers of reasonable administrative and litigation costs. |
| N(35)000-169 |
Nov. 18, 1999 |
| Application of Failure to Pay Addition to Tax to Returns Prepared Under I.R.C. § 6020(b) |
| This Notice focuses on the application of the Section 6651(a)(2) failure to pay addition to tax to returns prepared pursuant to Section 6020(b). The Notice defines a Section 6020(b) return, and discusses whether the addition to tax imposed in the context of a Section 6020(b) return is subject to deficiency procedures and whether the Tax Court has jurisdiction to re-determine the addition to tax. The Notice also describes how the amount of the addition to tax should be expressed in a notice of deficiency and answer, and provides model paragraphs for use in decision documents. |
| N(35)000-168 |
Nov. 18, 1999 |
| Change In Litigating Position |
| The purpose of this notice is to announce a change in the Service's litigating position with respect to when interest begins to accrue on a deficiency in tax if, pursuant to the taxpayer's election, the Service credited the reported overpayment against the taxpayer's estimated tax liability for the succeeding taxable year. |
| N(35)000-167 |
Nov. 09, 1999 |
| Update of Service and Computing Center Contacts |
| The purpose of this Notice is to transmit an updated list of district counsel personnel who act as primary legal contacts to the Service and Computing Centers. |
| N(35)000-166 |
Nov. 09, 1999 |
| Discovery of Unrelated Third Party Information |
| This Notice establishes procedures to be followed by field and national office Chief Counsel attorneys whenever the tax returns and return information of unrelated third parties are the subject of a discovery request or demand in connection with a disparate treatment claim raised by an unrelated taxpayer in a judicial tax administration proceeding. |
| N(35)000-165 |
Nov. 18, 1999 |
| Change In Litigating Position |
| The purpose of this notice is to announce a change in the Service's litigating position with respect to when interest begins to accrue on a deficiency in tax if, pursuant to the taxpayer's election, the Service credited the reported overpayment against the taxpayer's estimated tax liability for the succeeding taxable year. |
| N(35)000-162 |
Aug. 11, 1999 |
| Change In Litigating Position |
| This Notice announces a change in the Service's litigating position regarding whether a bankruptcy estate may take advantage of the Section 121 exclusion of gain on the sale of a personal residence. The Service now agrees that the bankruptcy estate may use the Section 121 exclusion. |
| N(35)000-161 |
May 26, 1999 |
| Internal Use Computer Software Research Credit Cases |
| This Notice assists field attorneys in the development and coordination of cases involving research credit claims under irc § 41 for internal use software and to request notification of the National Office coordinator of all cases and issues involving such claims. |
| N(35)000-160 |
Jan. 26, 1999 |
| Application of I.R.C. § 7602(c) to Counsel Employees |
| This notice reminds Chief Counsel employees that new subsection (c) of I.R.C. § 7602, as enacted by Sec. 3417 of the RRA, may apply to third party contacts made by Counsel employees in certain situations, and to provide guidance on recording and reporting such contacts. |
| N(35)000-159 |
Jan. 26, 1999 |
| IRS Restructuring and Reform Act of 1998 Section 3464 Implementation |
| Per Section 3464 of the IRS RRA of 1998, this Notice provides district counsel and appeals with processing instructions for issuing refunds or credits of undisputed overpayments while an appeal is pending. |
| N(35)000-150(C) |
Aug. 10, 1999 |
| Pilot Program for Coordination of FedState Matters |
| This Notice provides procedures for all field and National Office Chief Counsel functions for coordinating requests for advice from the Service regarding FedState matters. |
| N(35)000-143A |
Feb. 17, 1999 |
| Revisions to Service Center Advice Procedures to Conform Dissemination of Chief Counsel Advice |
| Section 3509 of the RRA 98 amended Section 6110 of the Code by adding "Chief Counsel Advice" (CCA) to the definition of written determinations open to public inspection. This Notice conforms the previous Service Center advice procedures to the processing procedures of CCA. |
| N(35)(12)43-1 |
March 01, 1999 |
| Revised AOD Language |
| The purpose of this notice is to provide standard language to be used in most nonacquiescing Actions on Decision regarding appellate cases. It has long been the general approach of the Chief Counsel’s Office to follow the adverse court of appeals opinion in cases appealable to that court even when we conclude that the opinion is erroneous. This approach provides respect for that court’s opinion, maximizes certainty and encourages resolution of cases in that circuit without undue and costly litigation. |
| N(34)700-2 |
Feb. 17, 1999 |
| Judicial Approval for Principal Residence Seizures |
| This Notices instructs District Counsel attorneys on the new requirements for judicial approval of principal residence seizures, pursuant to Section 3445 of the Internal Revenue Service Restructuring and Reform Act of 1998. |
| N(34)600-2 |
Feb. 04, 1999 |
| Coordination with National Office of Assertions of Confidentiality Privilege Relating to Tax Advice Under I.R.C. § 7525 |
| Section 3411 of RRA98 adds new I.R.C. § 7525, extending protections of confidentiality to tax practitioners. Suit and defense letters discussing the applicability of the tax advice privilege in summons enforcement proceedings and Tax Court and refund litigation cases involving these issues should be coordinated with the National Office. |
| N(34)000-52 |
April 26, 1999 |
| Coordination with Department of Justice for all Attorneys Involved in the Special Assistant United States Attorneys Program |
| The Executive Office for the United States Attorneys requests that all attorneys who work with the United States Attorneys' offices under the Special Assistant United States Attorneys (SAUSA) program contact their respective United States Attorneys to arrange to receive guidance as it becomes available regarding changes in federal legal practice that will affect attorneys appearing for the government in federal courts as a result of 28 U.S.C. § 530B, |
| N(34)000-51 |
March 16, 1999 |
| Transfer of General Litigation Coordination Responsibility to Northeast Region |
| Primary responsibility for the review and coordination of certain General Litigation matters is transferred to the Regional Counsel, Northeast Region. |
| N(33)620-1A |
May 26, 1999 |
| National Office and Field Coordination of Significant Cases |
| Uniform procedures are established to identify GLS issues and cases that must be brought to the attention of the National Office. Likewise, the National Office will notify the field of GLS issues and cases affecting matters handled by the field. |
| N(30)487-1B |
April 02, 1999 |
| Extension of Uniform To Procedures In Conduct Matters Bargaining Unit Employees |
| This Notice extends the coverage of N(30)487-1a to Bargaining Unit Employees. |
| N(30)487-1A |
March 10, 1999 |
| Standards of Ethical and Professional Conduct |
| Uniform procedures must assure consistent treatment of allegations of employee misconduct and build public and internal confidence in the investigative processes. For Non-Bargaining Unit Employees Only. |
| N(30)211-3 |
Aug. 10, 1999 |
| Extension of CCDM Notice Life |
| Future Chief Counsel Directives Manual (ccdm) Notices may be given a cancellation date of "Upon Incorporation into the CCDM" and certain previously issued Notices will remain in effect until their incorporation into the CCDM. |
| N(30)000-324 |
Oct. 21, 1999 |
| Classification of Documents as “Official Use Only” |
| This Notice (1) provides procedures for use of the "Official Use Only" administrative classification, and (2) declassifies documents which are inappropriately, or no longer need to be, classified Official Use Only. |
| N(30)000-320 |
May 26, 1999 |
| Section 3468 of the RRA |
| This Notice provides guidance on Section 3468 of the RRA, which prohibits United States officers and employees from requesting taxpayers to waive rights to file suit against the Government or Government employees for actions taken in connection with the internal revenue laws, except under specified conditions. |
| N(30)000-318 |
March 18, 1999 |
| Counsel to the National Taxpayer Advocate Status Report |
| Stuart L. Brown, the Chief Counsel, has signed a memorandum providing information on legal services to the National Taxpayer Advocate. |
| N(30)000-317 |
Feb. 04, 1999 |
| Application of RRA Section 3705(a) to Counsel Employees |
| This Notice is to inform Chief Counsel employees that Restructuring and Reform Act of 1998 (RRA) Section 3705(a) applies to correspondence by Chief Counsel employees and to provide guidance on complying with the requirements of this new off-Code provision. |
