IRS Practice And Procedure Alert

On July 2, 2014, the Department of Treasury issued a memorandum that provides guidance to Appeals employees on implementation of the Appeals Judicial Approach and Culture Project (hereinafter “AJAC Project”), which will affect multiple sections of the Internal Revenue Manual (hereinafter “IRM”). The AJAC Project is reinforcing Appeals’ quasi-judicial approach to the way it handles cases, with the goal of improving internal and external taxpayer perceptions of a fair, impartial and independent Office of Appeals.

The memorandum contains attachments that provide guidance pertaining to all Appeals employees who open and close cases and hold hearings, conferences or otherwise resolve open case issues in the affected Examination work streams in Appeals. The guidance generally applies to non-docketed cases and does not change any practice with respect to docketed cases. Similar procedures for docketed cases are anticipated to be issued before year-end.

The effective date of the memorandum is September 2, 2014, except for IRM, which has an effective date of October 1, 2014. The guidance is in effect for all new Appeals case receipts on or after Sept. 2, 2014, and will be incorporated into the IRM within two years from the effective date of the memorandum. The Department of Treasury memorandum can be located HERE.

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Peter J. Scalise serves as the Federal Tax Credits & Incentives Practice Leader for Prager Metis CPAs, LLC a member of The Prager Metis International Group. Peter is a highly distinguished BIG 4 Alumni Tax Practice Leader and has approximately twenty years of progressive public accounting experience developing, managing and leading multi-million dollar tax advisory practices on both a regional and national level.

Peter is a highly acclaimed thought leader in the fields of accounting and taxation with deep subject matter expertise in connection to designing, implementing and defending sustainable methodologies for specialty tax incentives including, but not limited to, research tax incentives; orphan drug credits; therapeutic discovery credits; accounting methods and periods; energy tax incentives in connection to green building envelope efficiency and benchmarking, solar energy, bio energies, fuel cells, wind turbines, micro turbines, and geothermal systems; and comprehensive fixed asset analysis incorporating principles of construction tax planning, cost segregation analysis and the final treasury regulations governing tangible property.

Peter is a renowned keynote speaker and an extensively published author on specialty tax incentives, tax controversy matters, and legislative updates from Capitol Hill for NAREIT, AGRION, USGBC, AICPA, ASTP, NATP, ABA, AIA, and TEI. Peter serves as a member of the Tax Faculty for CPAacademy, iShade and TaxConnections University (“TCU”). Peter serves on both the Board of Directors and Board of Editors for The American Society of Tax Professionals (“ASTP”) and is the Founding President and Chairman of The Northeastern Region Tax Roundtable.

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