| CC-2005-018 |
September 29, 2005 |
| Tax Court Orders Webpage |
| This Notice announces the electronic availability of Tax Court orders on the Chief Counsel intranet site via the Tax Court Orders webpage and sets forth procedures that Chief Counsel personnel should follow to retrieve orders from the Tax Court Orders webpage. |
| CC-2005-017 |
September 27, 2005 |
| Interim Procedures for "Ballard" Type Issues |
| On August 19, 2005, the Tax Court issued orders in approximately 120 cases (or groups of cases to the extent there are related dockets) that were previously tried by Special Trial Judges under T.C. Rule 183(a). A number of the cases were petitioned in the 1980’s, and a number of the opinions issued in these cases date back to the early 90’s, if not earlier. In each of these cases, the draft opinions of the Special Trial Judges (the Special Trial Judges’ reports pursuant to Rule 183(b)) were adopted by one of the Tax Court’s regular/senior judges and issued as opinions of the court. This is the process that was the subject of the Supreme Court’s recent opinion in Ballard v. Commissioner, 544 U.S. ___, 125 S. Ct. 1270 (2005). |
| CC-2005-016 |
August 25, 2005 |
| Guidance regarding the use of the Tax Court's Electronic (North) Courtroom located in the Tax Court building in Washington, D.C. |
| On May 17, 2004, the Tax Court announced the availability of its electronic courtroom for conducting court proceedings beginning on or after June 1, 2004. This notice provides information regarding the use of the United States Tax Court’s Electronic (North) Courtroom located in the Tax Court building in Washington, D.C. |
| CC-2005-015 |
June 20, 2005 |
| New Office Management Structure for Chief Counsel Field Offices |
| This Notice announces the new matrix management approach for Office of Chief Counsel (“Counsel”) field offices, effective July 25, 2005. The new field management matrix will provide for coordination of field operations at the local level, without altering any supervisory chains of command. |
| CC-2005-014 |
June 24, 2005 |
| Improper Allocation Documents for the Commercial Revitalization Deduction |
| This notice announces a change in the required information to be included in the documents for allocations under § 1400I of commercial revitalization expenditure amounts that were made by a commercial revitalization agency before 2005. |
| CC-2005-013 |
June 16, 2005 |
| Employee Rights |
| In accordance with Article 4, Part II Section 1 of the collective bargaining agreement between the Office of Chief Counsel and NTEU, this notice is issued 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-2005-012 |
June 07, 2005 |
| Revised Procedures for Proving Fraud After a Criminal Conviction |
| This Notice describes the use of collateral estoppel to narrow issues for trial in a civil fraud case when the petitioner has been convicted of tax evasion, willful failure to file a return, or filing a false return. |
| CC-2005-011 |
May 20, 2005 |
| Frequently Asked Questions Regarding Litigation of section 6015 cases in Tax Court. |
| This Notice answers many of the most frequently asked questions received from attorneys regarding relief from joint and several liability under section 6015. The questions relate to five topics: the nonpetitioning spouse, the suspension of the collection statute when a taxpayer files a section 6015 claim, the effect of agreements between the Service and the requesting spouse, the actual knowledge defense to a petitioner’s claim under section 6015(c), and procedures under Chief Counsel Notice CC-2004-026. |
| CC-2005-010 |
May 20, 2005 |
| Guidance for Handling Section 6015 Cases When a Claim for Relief is Filed More than Two Years After the Service Applied a Refund to a Joint and Several Liability. |
| This Notice provides guidance regarding cases involving requests for relief from joint and several liability under I.R.C. § 6015 when the claim for relief from joint and several liability is filed more than two years after the Service offset a refund against an existing joint tax liability. |
| CC-2005-009 |
May 19, 2005 |
| Change in Pre-Review Requirements for Suit Letters Requesting Judicial Approval of Principal Residence Seizures |
| The purpose of this Notice is to advise that suit letters requesting judicial approval of a principal residence seizure will no longer be pre-reviewed in Branch 1, Collection, Bankruptcy & Summonses. |
| CC-2005-006 |
April 14, 2005 |
| Delegation of Authority to Hear Certain Appeals to the Secretary |
| This is a notice of delegation of authority to decide appeals to the Secretary of the Treasury, or his delegate, filed under Treasury Circular 230, 31 C.F.R. Part 10, with respect to enrollment decisions. |
| CC-2005-005 |
April 08, 2005 |
| Discretionary Disclosure Policy |
| The purpose of this Notice is to apprise all Chief Counsel employees of a change in the discretionary disclosure policy of the Service that affects our responses to discovery and Freedom of Information Act (FOIA) requests.1 This Notice also explains who has the authority to make certain discretionary disclosure determinations for the Office of Chief Counsel. |
| CC-2005-004 |
Feb. 04, 2005 |
| Discretionary Disclosure Policy |
| This Notice announces changes to procedures for Associate Chief Counsel review in significant bankruptcy cases. Chief Counsel attorneys working Chapter 11 cases under the Significant Bankruptcy Case Program should forward disclosure statements and plans in certain cases to the Office of Assistant Chief Counsel (Collection, Bankruptcy & Summonses) to ensure coordination and coordinate review with technical subject matter experts in the Associate Chief Counsel offices. |
| CC-2005-003 |
Jan. 19, 2005 |
| Administrative Collection of a Partnership's Employment Taxes from the Partners |
| This Notice confirms that United States v. Galletti, 124 S. Ct. 1548 (2004), does not alter the Service’s longstanding position that it may administratively collect a partnership’s employment taxes from general partners based on their derivative liability under state law. This Notice also discusses the proper wording of Notices of Federal Tax Lien and whether general partners are entitled to Collection Due Process rights. |
| CC-2005-002 |
Dec. 23, 2004 |
| Requests for Nonstandard Tax Court Transcripts |
| This notice announces a change to the procedures for seeking approval to request a nonstandard Tax Court transcript. |
| CC-2005-001 |
Nov. 29, 2004 |
| Issue Tracking for Abusive Tax Shelters |
| This Notice alerts attorneys to the existence of UIL codes for abusive tax shelters (including listed transactions). Attorneys should review their inventory of open cases to ensure that the appropriate UIL codes for abusive tax shelters have been used. |
