II. Execution Phase Stages of issue development include determining the facts, applying the law to those facts, and understanding the various tax implications of the issue. The issue team should conduct interactive discussions, including using the IDR process to develop the facts. Every effort should be made to resolve any factual differences. Open communication and continuous reassessment should continue throughout the Execution Phase. A. Risk Assessment 1. Review IRC Section 6662(e) Response The issue team will review and analyze the taxpayer’s IRC Sec. 6662(e) documentation prior to the taxpayer orientation meetings and note areas that require further development, confirmation, or inquiry: