| CC-2003-031 |
Sept. 11, 2003 |
| Face-to-Face Conferences with Appeals in Collection Due Process Cases |
| This Notice provides guidance concerning when the Internal Revenue Service Office of Appeals will offer a taxpayer a face-to-face conference in a lien and levy case arising under I.R.C. ' 6320 or ' 6330. |
| CC-2003-030 |
Sept. 10, 2003 |
| Son of Boss Loan Premium Tax Shelters |
| The purpose of this Notice is to assist Chief Counsel attorneys in advising field personnel in the development of cases involving the type of transaction described in the first fact pattern of Notice 2000-44, 2000-2 C.B. 255, and substantially similar transactions (referred to herein as Son of Boss loan premium transactions). |
| CC-2003-029 |
Aug. 28, 2003 |
| Urgent Reminder Concerning Elimination of Tax Court Calendar Status Report |
| This Notice provides an urgent reminder that, effective immediately, field offices must not send Calendar Status Reports (also known as the 10-day Report, or CATS Report TL-830) to the U.S. Tax Court in connection with trial calendars. The Tax Court’s Standing Pretrial Order eliminated this ex parte report and adopted a new format for the Pretrial Memorandum for calendared cases. |
| CC-2003-028 |
Aug. 15, 2003 |
| Motions to Strike |
| This Notice clarifies existing CCDM procedures with respect to the filing of motions to strike when petitions are partly defective. |
| CC-2003-027a |
Sept. 30, 2003 |
| Revision to Notification of Tax Court Regarding Potentially Dangerous Persons |
| This notice reemphasizes and clarifies uniform procedures for the notification of the Tax Court regarding the possible attendance of potentially dangerous persons at trial sessions. Current procedures for notification of the Tax Court are described in CCDM 35.9.3.3 |
| CC-2003-027 |
Aug. 15, 2003 |
| Notification of Tax Court Regarding Potentially Dangerous Taxpayers |
| To reemphasize and clarify uniform procedures for the notification of the Tax Court regarding the possible attendance of potentially dangerous taxpayers at trial sessions. Existing procedures with respect to potentially dangerous taxpayers are described in CCDM 35.9.3.3 |
| CC-2003-026 |
Aug. 15, 2003 |
| Treatment of Petitions Filed During Automatic Stay |
| To reemphasize procedures for handling petitions filed during the pendency of an automatic stay in bankruptcy. Current CCDM procedures for handling these petitions are located in CCDM 35.4.8. |
| CC-2003-025 |
Aug. 11, 2003 |
| Standup of Legal Processing Division |
| This Notice announces the creation of the Legal Processing Division, a new division reporting to the Associate Chief Counsel (Procedure & Administration), effective August 10, 2003. |
| CC-2003-024 |
Aug. 01, 2003 |
| Chief Counsel Signature Block |
| The purpose of this Notice is to advise all Chief Counsel employees of a necessary modification to the signature block on all documents signed and filed with the United States Tax Court, correspondence sent to the Department of Justice, and other documents prepared on behalf of the Chief Counsel, effective August 1, 2003. |
| CC-2003-023 |
July 03, 2003 |
| The Role of the Joint Committee on Taxation Under Section 6405 |
| This Notice explains the role of the Joint Committee on Taxation regarding refunds and credits of federal tax under I.R.C. § 6405, and clarifies the procedures the Service uses to comply with this section. Additionally, this Notice provides guidance on the respective responsibilities and roles of the Service, Counsel, and the Joint Committee in cases subject to section 6405. |
| CC-2003-022 |
July 01, 2003 |
| Procedures for Processing Taxpayer Specific Chief Counsel Advice that will be Withheld in Full from Public Disclosure |
| The purpose of this Notice is to apprise all Chief Counsel employees of the procedures for processing taxpayer specific Chief Counsel Advice (CCA) when it is determined that no portion of a particular CCA need be disclosed to the public under the provisions of I.R.C. § 6110. This Chief Counsel Notice supplements and modifies Chief Counsel Notice 2002-026, issued on May 16, 2002, which outlined the procedures for obtaining and processing CCA. |
| CC-2003-021 |
June 26, 2003 |
| Claims for Refund on Late-Filed Original Income Tax Returns -Change in Litigation Position in the Ninth Circuit |
| This notice announces a change in the Service’s litigating position concerning the application of I.R.C. § 6511(a) to a claim for credit or refund made on a late-filed original income tax return in cases appealable to the Ninth Circuit Court of Appeals. |
| CC-2003-020 |
June 25, 2003 |
| Notice 2000-44 Son of Boss Tax Shelter |
| The purpose of this Notice is to assist Chief Counsel attorneys in advising field personnel in the development of cases involving the type of transaction described in the second fact pattern of Notice 2000-44, 2000-2 C.B. 255, and substantially similar transactions (referred to herein as Son of Boss transactions). |
| CC-2003-019 |
June 12, 2003 |
| Change in Litigating Position Application of Addition to Tax Under Section 6651(a)(2) on Section 6020(b) Returns |
| This notice announces a change in the Service’s litigating position concerning the application of the section 6651(a)(2) addition to tax for returns prepared under section 6020(b). This Notice supersedes Notices N(35)001-047 (October 16, 2001) and N(35)000-169 (November 16, 1999). |
| CC-2003-018 |
June 10, 2003 |
| Delegation of Signature Authority Over Certain Closing Agreements |
| The purpose of this Notice is to advise employees and others that I am delegating the authority to sign closing agreements described in Treas. Reg. § 1.1503-2(g)(2)(iv)(B)(2)(i) to the Deputy Associate Chief Counsel (International Field Service and Litigation). This authority may not be redelegated. To the extent that any authority previously exercised consistent with this delegation may require ratification, it is hereby approved and ratified. This delegation of authority is authorized under CC Order 0-30-2000-017 (November 19, 2000) and CCDM Notice N(30)000-346 (November 19, 2000). |
| CC-2003-017 |
May 29, 2003 |
| Change in Pre-Review Requirements for Collection Due Process Cases |
| The purpose of this Notice is to eliminate pre-review requirements for certain documents prepared or filed in Collection Due Process (CDP) cases. This Notice supersedes Chief Counsel Notice 2002-034 and will be incorporated into the CCDM when reissued. |
| CC-2003-016 |
May 29, 2003 |
| Collection Due Process Cases |
| This Notice updates and replaces CC-2001-038, known as the Collection Due Process (CDP) Handbook, which provided guidance on the handling of CDP cases arising under I.R.C. §§ 6320 (liens) and 6330 (levies). These sections are a codification of section 3401, the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub. L. No. 105-206, 112 Stat. 685 (1998). |
| CC-2003-015 |
May 14, 2003 |
| Claims for Relief from Joint and Several Liability – Update on Requirements for Notification of Nonpetitioning Spouse |
| This Notice updates the procedures to follow in proceedings before the Tax Court in which a taxpayer raises a claim for relief from joint and several liability under section 6015 and the other spouse (or former spouse) who signed the joint return for the year(s) at issue is not a party to the case. This Notice also obsoletes N(35)000-173 (October 17, 2000). |
| CC-2003-014 |
May 08, 2003 |
| Following Published Guidance in Advice and Litigation |
| This notice clarifies and supersedes the Chief Counsel Notice (CC-2002-043) dated October 17, 2002, regarding the requirement that Chief Counsel attorneys follow legal positions established by published guidance in papers filed in the Tax Court or in defense or suit letters sent to the Department of Justice. |
| CC-2003-013 |
April 22, 2003 |
| Litigation Fees Settlement Authority of Area Counsel Under I.R.C. § 7430 |
| Effective as of the date of this Notice, certain claims for section 7430 administrative and litigation costs, as described below, may be settled without the approval of the Associate Chief Counsel (Procedure & Administration). |
| CC-2003-012 |
April 09, 2003 |
| Obtaining Tax Accrual Workpapers |
| This notice sets out procedures to be used in connection with the Service’s policy regarding requests for tax accrual and other financial audit workpapers relating to the tax reserve for deferred tax liabilities and to footnotes disclosing contingent tax liabilities appearing on audited financial statements. |
| CC-2003-011 |
March 31, 2003 |
| Change to the Tax Court’s Standing Pretrial Order |
| On February 10, 2003, the United States Tax Court announced that it had adopted changes to the format for the Standing Pretrial Order used in connection with Notices Setting Cases for Trial. This new format will be used by the Tax Court commencing with the Fall 2003 Trial Sessions. |
| CC-2003-010 |
March 14, 2003 |
| Change in Litigating Position UIL#482.02-00 |
| The purpose of this notice is to announce a change in the Service's litigating position concerning the application of section 482 to certain aspects of “lease strips” or other “stripping transactions” described in Notice 95-53, 1995-2 C.B. 334. |
| CC-2003-009 |
March 12, 2003 |
| New Word Processing Standard for Office of Chief Counsel |
| The purpose of this Notice is to inform all Chief Counsel employees that, as of September 30, 2003, Microsoft Word will be the standard word processing application for all of the Office of Chief Counsel. |
| CC-2003-008 |
Feb. 03, 2003 |
| Ethical Obligations of Every Chief Counsel Attorney |
| This notice reminds all Chief Counsel attorneys of their obligation to adhere to the highest ethical standards in all aspects of their responsibilities, including representation of the Commissioner before the Tax Court. |
| CC-2003-007 |
Jan. 28, 2003 |
| Employee Rights |
| In accordance with Article 4, Section 4H of the Negotiated Agreement between the Office of Chief Counsel and NTEU Chapter 251, the purpose of this notice is to advise bargaining unit employees of their rights to representation by NTEU in meetings that are being held in connection with a conduct investigation. |
| CC-2003-006 |
Jan. 27, 2003 |
| Private Letter Rulings, Technical Advice Memoranda, and Technical Expedited Advice Memoranda |
| This Notice informs Chief Counsel attorneys of procedures to follow when assisting in the submission or responding to requests for Technical Advice Memoranda (TAMs), Technical Expedited Advice Memoranda (TEAMs) or Private Letter Rulings (PLRs). |
| CC-2003-005 |
Jan. 16, 2003 |
| Obsoletion of OMs 10224-20236 |
| The purpose of this Notice is to announce obsoletion of Office Memoranda (OMs) 10224- 20236. |
| CC-2003-004 |
Jan. 06, 2003 |
| Confidential Financial Disclosure |
| The purpose of this notice is to review the positions in Counsel that require the filing of a Confidential Financial Disclosure Report (OGE Form 450) and the procedures for reviewing and processing the forms. This notice is to replace CCDM 30.4.8.13 (April 22, 1992). |
| CC-2003-003 |
Dec. 12, 2002 |
| Processing for Public Inspection Certain Advice Issued by Field Attorneys |
| This Notice provides instructions for processing for public inspection written advice prepared by any Field attorney, which advice was reviewed by any Associate Office and subsequently issued to field or service center campus employees of the Internal Revenue Service. These procedures contemplate that such memoranda are reviewed prior to issuance and that discussions occur between Field and Associate Office attorneys prior to the advice being sent for review to the Associate Office. These procedures do not apply to written advice that is prepared by the Field and not reviewed by the Associate Offices. |
| CC-2003-002 |
Dec. 11, 2002 |
| Legal Advice Program |
| The purpose of this Notice is to clarify some aspects of the Office of Chief Counsel’s legal advice program as discussed in the Chief Counsel’s “Roles” memo dated August 26, 2002. |
| CC-2003-001 |
Nov. 12, 2002 |
| Protection of Confidential Sources |
| The purpose of this Notice is to remind Chief Counsel employees of our adherence to the Service’s practice of not disclosing the identity of confidential sources. This Notice also establishes the requirement that the Deputy Chief Counsel (Operations) be apprised of any case in which Counsel, over its objection, is being asked to disclose the identity of a confidential source. |
