- 4.75.33.1 Overview
- 4.75.33.2 Definitions
- 4.75.33.3 Responsibilities of the Director, EO Examinations, and the Director, EO Rulings and Agreements
- 4.75.33.4 Responsibilities of the EO Area Offices and Case/Group Managers
- 4.75.33.5 Reporting Requirements
- 4.75.33.6 Technical Advisors
- 4.75.33.7 Disclosure of Return Information by the Technical Advisor
- Exhibit 4.75.33-1 Example of Letter for Taxpayers in the Technical Advisor Program
- Exhibit 4.75.33-2 Listing of EO Technical Advisors
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Industry Specialization ensures uniform and consistent treatment of issues nationwide and provides better identification and development of issues.
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Since all industry taxpayer Team Examination Program (TEP) cases, formerly known as Coordinated Examination Program (CEP) cases), and non-TEP cases are included in the Technical Advisor Program, the continuity provided by industry specialization expands its benefits beyond the area offices which have a concentration of TEP examinations.
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Industry specialization includes the concepts of Industry-wide Studies, Technical Advisor, Designated Industries, Identified Industry Cases and Coordinated Issues.
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In addition to the industries included in the EO Technical Advisor Program, case/group managers are responsible for compliance with all coordinated issues including Large & Mid-Size Business (LMSB) Coordinated Issues. See IRM 4.40.1 through IRM 4.40.3 for LMSB Technical Advisor Procedures. Case managers, group managers and examiners should also make use of the expertise and guidance available from LMSB Technical Advisors. A current list of the industries or issue areas included in the LMSB Technical Advisors and Issue Specialists can be found in the LMSB and SBSE intranet website.
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For the purposes of this IRM, an industry selected for the Technical Advisor Program is referred to as a Designated Industry.
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An Industry-wide Study is a concurrent evaluation of a particular industry and its principal taxpayers under the direction of an interim Technical Advisor. The concept encompasses:
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The identification of unique industry accounting practices and audit techniques;
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The identification of common issues; and
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The pursuit of potential coordinated issues.
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The purpose of the Industry-wide Study is the identification of those industries which merit inclusion as Designated Industries under the continuing coordination of a Technical Advisor. The Study includes:
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The definition of business activity and the parameters of the industry;
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The identification of industry cases;
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The creation of a communications network among Service personnel involved in the examination of industry cases;
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The analysis and identification of business or economic factors peculiar to the industry; and
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The identification of tax problems, inconsistencies, etc. within the industry.
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Technical Advisor serves as a nationwide advisor for an industry selected for the Technical Advisor Program.
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Technical Advisor Designated Industries are those industries identified as warranting continuing coordination by Technical Advisors. Additions or deletions of Designated Industries may be made as circumstances warrant. See Exhibit 4.75.33-2 for the Designated Industries and the Technical Advisor’s name, location and telephone number.
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Identified Industry Cases are those cases within an industry identified for regular monitoring by the Technical Advisor and the Director, EO Examinations.
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Coordinated Issues are major issues of particular importance to an industry selected for industry-wide coordination.
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The Director, EO Examinations has primary responsibility for the administrative oversight of the Exempt Organizations Technical Advisor Program. The Director, EO Rulings and Agreements, has primary responsibility for the technical coordination of the Exempt Organizations Technical Advisor Program.
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The Director, EO Examinations, will:
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Ensure findings in the designated industries and industry studies are disseminated to all area offices;
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Ensure periodic industry-wide reports are compiled and distributed to all examiners;
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Make program visitations as needed;
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Recommend to the Director, Exempt Organizations, additions, deletions or modifications of industries identified for coordination;
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Develop and maintain effective communications between Division Counsel/Associate Chief Counsel (TEGE) and Director, EO Rulings and Agreements, to ensure that requests for technical advice involving industry-wide issues are expedited;
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Participate in the selection of Coordinated Issues;
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Review the Technical Advisor Digest and Alerts Reports;
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Maintain a file of preliminary evaluations of industries and act as a clearinghouse to prevent duplication;
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Select Designated Industries from those recommended from Industry-wide Studies;
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Provide for liaison with other government agencies;
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Monitor the progress and examination status of cases;
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Provide overall program direction and assistance to the area offices; and
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Ensure the Technical Advisor has adequate resources such as subscriptions to trade and professional magazines and other publications, storage and working space, clerical and technical support, travel funds, etc.
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Conduct operational reviews of the Technical Advisor program as appropriate;
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Approve Technical Advisor Manager requests for outside speech;
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Approve Technical Advisor meetings;
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Provide adequate training for Technical Advisors;
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Assess staffing needs of the Technical Advisor program;
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Initiate action with the Office of Chief Counsel to assemble a team of attorneys to assist each Technical Advisor.
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The Director, EO Rulings and Agreements, has primary responsibility for uniform interpretation and application of the federal tax laws involving organizations exempt from tax under IRC § 501, private foundations, organizations described in IRC § 170(b)(l)(A) except clause (v), political organizations described in IRC § 527, organizations described in IRC § 4947(a), prepaid legal plans described in IRC § 120, and welfare benefit funds described in IRC § 4976.
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The Director, EO Rulings and Agreemenst, will:
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Review status to identify examination activity where technical assistance may be warranted;
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Participate in TEP visitations to the area offices;
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Provide technical assistance and guidance on all EO matters and cases in accordance with the provisions of IRM 1.1.13; and
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Provide primary contact points for technical consultation on issues and cases.
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All technical questions on Technical Advisor Program cases must be discussed with the Technical Advisor before the Director, EO Rulings and Agreements is contacted.
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EO Area Managers are encouraged to request technical assistance from EO Rulings and Agreements with respect to technical problems and to seek clarification and guidance on issues which may or may not arise in an examination of a particular return.
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Technical assistance may be requested with respect to any area of taxation, but it is particularly appropriate in situations such as:
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Potential tax problem which is brought to light by a newspaper or a magazine article, or by a recently enacted State or local law or ordinance;
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Questionable deductions of a type noted in a large number of returns during the screening of tax returns;
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Uncertainty which may arise regarding the interpretation of a published Revenue Ruling;
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Tax-exempt bond issues; and
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Issues for which there is no published precedent.
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Request for Technical Assistance may be made formally in memorandum form or informally by telephone.
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Formal technical assistance requests should be made by the case/group manager through the area manager to the Director, EO Rulings and Agreements.
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Information furnished as technical assistance is advisory only and may not be cited as authority for any action. However, when potential problems are brought to light in requests for technical assistance, the Director, EO Rulings and Agreements, in appropriate cases, will work with the Division Counsel/Associate Chief Counsel (TEGE) and Treasury to publish the Service's position.
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Responsibilities of the area offices and case/group managers are described below.
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The area manager should:
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Be alert to identify an industry which is susceptible to industry-wide study techniques and report such findings to the Director, EO Examinations.
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Recommend when an industry should be classified as a Designated Industry.
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Work with the Technical Advisor to determine the area office cases to be included in the area's Technical Advisor Program.
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Provide the necessary involvement of area management to assure cooperation of all participants in Industry-wide Studies and within Designated Industries.
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Maintain responsibility for the conduct of the program.
Note:
Operational, area office and case reviews should include consideration of the Technical Advisor Program objectives.
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Refrain from withdrawing a case from an industry-wide study without the concurrence of the Technical Advisor.
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Secure the prior concurrence of the Technical Advisor to any disposition of a coordinated issue in identified industry cases.
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Obtain approval from the Technical Advisor on a position contrary to that reflected in a coordinated issue on any case.
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Obtain approval from the Technical Advisor before closing any case involving a coordinated issue.
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Case/group managers examining cases within an industry will:
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Receive notice from the Technical Advisor that their case has been included as an identified industry case when the case is assigned.
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Advise the Technical Advisor of any large case which is engaged in the business activity of a particular Designated Industry and is not an identified industry case.
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This will also apply to cases where the taxpayer is engaged in the business activity only through a division or subsidiary.
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Consult with the appropriate Technical Advisor for planning input during the preplanning stage of all identified industry cases.
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In multi-industry cases the case/group manager will consult with all appropriate Technical Advisors.
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Consult with the appropriate Technical Advisor prior to submitting a Request for Technical Advice on industry issues.
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Follow the decisions on Coordinated Issues formulated by the Technical Advisor.
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Resolution of a coordinated issue on a basis different than that formulated by the Technical Advisor requires the approval of the Technical Advisor. In identified industry cases, decisions to avoid pursuit of a coordinated issue area also require the concurrence of the Technical Advisor.
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Arrange for the participation of the Technical Advisor in the critique process on identified industry cases.
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Case/group managers will be provided with the Technical Advisor Program Digest. Each issue of the Digest will contain a complete listing of coordinated issues for each Designated Industry and a description of the business activity for each industry.
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Case/group managers who have examiners examining cases within an industry will:
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Ensure coordinated issues are included in the examination plan.
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Ensure examiners review Technical Advisor Program Digest and Alerts.
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Consult with the Technical Advisors, when appropriate.
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Ensure the provisions of IRM 4.75.33.4.2.1 are followed.
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Case/group managers must first contact the Technical Advisor on any technical and procedural questions.
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The case/group managers will request and plan all assistance visits with the Technical Advisor.
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The case/group manager will ensure a letter containing the following information is sent to taxpayer and the appropriate representative(s). :
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The first paragraph should includ a statement indicating the Service has a Technical Advisor Program to ensure uniform and consistent treatment of issues on an industry-wide basis and one or more of the Designated Industries includes the taxpayer’s corporation. For purposes of informing the taxpayer about the program, include a statement that a description of the Program and a copy of the Internal Revenue Manual Procedures are being forwarded with the letter.
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The second paragraph should refer to a description of the issues currently being coordinated in the industry is being transmitted with the letter. Inform the taxpayer the Service would appreciate a review of the issues along with comments and recommendations concerning the issues. Request the taxpayer to advise the Service as to other potential issues which may benefit from consideration on an industry-wide basis.
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Advise the taxpayer in the closing paragraph the case/group manager is available to discuss and answer any questions concerning the Technical Advisor Program with the taxpayer, taxpayer’s representative(s) or members of the representative’s staff.
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Include case/group manager’s name, telephone number, employee identification number and mailing address.
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The letter is required to be sent to all taxpayers included in the Technical Advisor Program. The letter should be similar to Pattern Letter 1464(P), which is shown in Exhibit 4.75.33-1. When there is no case manager, the letter will have the signature of the group manager or other appropriate individual.
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Identified Industry Cases (TEP and Non-TEP)
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The Technical Advisor will be notified as soon as a decision is made to examine an industry identified case.
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A copy of the final report of examination will be forwarded to the Technical Advisor prior to closing the case.
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The Technical Advisor will be notified when any coordinated issue is considered.
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Non-identified Large or TEP Cases:
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Any industry case with gross receipts of $50 million or more will be considered a large case, or TEP case, if it meets the point criteria as set forth in IRM 4.75.29.
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When the case/group manager entertains a position in conflict with the position stated in a coordinated issue paper, the Technical Advisor should be notified immediately before proceeding with the examination.
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A copy of the report of examination on unagreed, non-identified industry cases will be forwarded to the Technical Advisor prior to closing the case.
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CEMIS (Coordinated Examination Monitoring Information System) will be the reporting and monitoring system for all TEP Technical Advisor Program "identified and non-identified" industry cases. CEMIS allows users to:
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Report all industry coordinated issues identified in the case, plus up to ten (10) other significant issues,
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Research issues nationwide, and
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Generate several reports from the "Issue Tracking" menu.
Note:
Refer to the CEMIS User Manual, which is on CEMIS, and/or the CEMIS Quick Reference Guide for detailed instructions on how to use the monitoring system and how to access the reports generated by CEMIS.
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All Other Examinations of Industry Cases:
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The Technical Advisor must be notified when consideration is being given to not following the stated position in a coordinated issue paper.
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A copy of the report of examination on unagreed industry cases will be forwarded to the Technical Advisor prior to closing the case.
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Copies of draft audit plans and reports of examination should be submitted by the area offices directly to the Technical Advisors so they can provide appropriate assistance in finalizing these documents.
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Area offices are encouraged to cooperate with the Technical Advisors in providing them with other requested draft reports, e.g. , closing agreements.
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The role of Technical Advisors is to apply expert knowledge in identifying, developing and resolving issues; to educate internal and external customers; and to consult with internal and external customers on traditional and alternative issue resolution strategies in order to meet the objectives of the Service's mission.
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Technical Advisors keep informed of current industry/industry issue activities and monitor developing trends in order to forecast future compliance. As the industry/industry issue focal point, Technical Advisors provide the tools and the support necessary for examination teams to plan and develop their audit of Emerging Issues.
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In order to identify novel and/or controversial tax treatment of transactions, Technical Advisors may:
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Study relevant publications such as trade journals, market reports, corporate annual reports and other SEC filings.
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Collaborate with management in liaison with industry trade associations and other professional organizations.
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Attend industry conferences, conventions and meetings.
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Meet with other Federal, state and local governmental agencies responsible for regulating or otherwise monitoring the assigned industry issue areas.
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Establish a communications network with EO Examinations to facilitate flow of information.
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Communicate with, and obtain feedback from, examiners engaged in auditing taxpayers within the assigned industry issue areas.
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Seek opportunities to address trade and industry groups in order to discuss the industry and related issues. In accepting invitations to address such groups, the current Service guidance on the subject will be observed.
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Identify Issues: Canvass industries for issues and trends; assess viability of issues identified by examiners; analyze and interpret legal developments; conduct studies to determine compliance; collaborate with other functions on issue selection criteria.
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Develop Issues: Gather pertinent facts; research issues, law and industry practices; obtain legal advice and assistance in development of issues; write technical material such as Coordinated Issues; assist in development of technical pronouncements.
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Resolve Issues: Partner with Industries, Appeals and Counsel in traditional issue resolution processes; advise Counsel and Treasury in development of technical pronouncements; recommend legislation and tax law changes; conduct briefings for Joint Committee, Taxpayer Advocate Service and others as appropriate; initiate and administer Compliance Initiative Projects (CIP).
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Consult on Alternative Issue Resolution Initiatives: Consult with Industries on merits of issues and alternate methods of resolution; assist EO Examination in developing issue management strategies and assessing compliance.
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Educate Internal and External Customers: Conduct continued professional education (CPE) sessions, seminars and focus meetings for EO and other Divisions; conduct industry-wide meetings; speak at industry conferences and conventions; write and disseminate informational material such as Digests and Alerts; prepare and present videos and interactive video training presentations; advise foreign counterparts.
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Conduct Case Consultations: In coordination with case/group managers, visit cases; review records; analyze Information Document Requests and taxpayer responses; dialogue with taxpayers; assess, assist and advise further action.
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Develop and Maintain Industry and Issue Expertise: Attend external industry conferences and conventions for continued professional education; network with industry professionals; read industry publications and periodicals to keep abreast of industry practices; attend out-service professional training; attend CPE seminars and focus meetings conducted by the Service; participate in special assignments.
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Field Assistance: Answer questions from internal and external customers and disseminate responses to frequently asked questions through appropriate means.
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As the needs arise, the Director, EO Examiantions, or the Director, EO Rulings, may authorize the formation of Technical Advisor Studies. The purpose of Technical Advisor Studies is to identify industries or issues that merit inclusion in the Technical Advisor Program. The concept encompasses the identification of unique industry accounting practices and audit techiques, the identification of common issues and their tax treatment and the identification of potential Coordinated Issues.
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The Technical Advisor will conduct the studies with assistance from EO Examination, EO Rulings & Agreements, and the office of Chief Counsel, as appropriate.
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Technical Advisor Meetings are periodic or ad hoc meetings held by Technical Advisors to discuss issues, problems, and other matters affecting their industry or issue area.
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Coordiated through appropriate offices, the meetings will be attended by EO Examination agents and managers, representatives from Appeals and the Office of Chief , and others who would benefit from such meetings.
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The Technical Advisor Program was formed to promote uniform and consistent treatment of issues. To better identify, develop and resolve issues, Technical Advisors should:
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Enhance communication and coordination with both internal and external customers.
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Coordinate speeches before external stakeholders with the Director, EO Examinations with a copy forwarded to the EO Office of Communications and Liaison at least one month in advance of the proposed speaking engagement.
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Ensure timely release of formal and informal guidance.
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Assess the need for educating customers through training classes and/or Audit Technique Guidelines and, if necessary, develop the required training material.
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Clarify the law and simplify procedures in order to facilitate tax administration and compliance.
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In coordination with case/group managers, participate in the development of audit plans to ensure proper consideration of Coordinated Issues.
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Determine if technical assistance or advice should be solicited.
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Attempt to reconcile inconsistent positions at the lowest possible level and, if necessary, raise the issue to the next level.
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In consultation with case/group managers, look for potential Coordinated Issues during the planning stage of examinations.
Reminder:
Submit requests for legal guidance early in the examination process.
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Communicate with examination teams concerning Coordinated Issues within the assigned industry and issue areas.
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Develop pro forma Information Document Requests and Audit Plans for Coordinated Issues.
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Keep informed of regulations issued by other government agencies and notify examination teams of any development.
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In cooperation with the Director, International, participate in simultaneous examinations and exchanges with Treaty Partners.
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Meet with examination teams and other functions, as needed, to discuss issues, trends, audit procedures and means of resolution.
Note:
Meetings may be local or national in scope.
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Utilize a TEGE intranet website to diseminate information.
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The Office of the Director, EO Rulings and Agreements, acts as the central clearing point for Emerging Issues and processes proposed Coordinated Issues for final approval.
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Issues can be identified by Revenue Agents, Field Specialists, Technical Advisors, industry publications, general publications, taxpayer inquiries, industry contacts and tax or accounting associations. The Technical Advisor receiving the inquiry conducts an initial review to determine whether the issue should be pursued as an Emerging Issue. This review may include queries of known databases and other research capabilities. Emerging issues may subsequently become Coordinated Issues or be resolved through other means. An Emerging Issue, as used in this IRM, has the following characteristics:
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Is identified by, and from, internal or external sources.
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Addresses a technical issue,e.g., law or procedure, where compliance impact may be unknown.
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Is not clearly defined by law.
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May impact industry-specific or cross-industry cases.
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May have impact across Division boundaries.
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Is an issue on which the Service has taken inconsistent positions in the past or no position at all.
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Needs to be communicated.
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In conjunction with Director, EO Examinations, the Technical Advisor receiving the issue determines whether the issue is a cross-industry issue or an industry-specific issue. In most instances, the issue is sent to the Office of Director, EO Rulings and Agreements, if it crosses industry lines.
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If the issue is a cross-industry and/or cross-division issue, EO Rulings and Agreements, will assemble an Issue Team to develop and further define the issue. This team should include members representing Revenue Agents, Technical Advisors, Technical Advisor Managers, Field Specialists, International, Appeals and Division Counsel, as appropriate. Representatives from other Divisions and Offices may join the Team on an ad hoc basis.
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The Issue Team further defines and expands the issue by conducting research; contacting taxpayer and industry groups; coordinating with Strategy, Research, and Program Planning and Division Counsel; performing case visits as necessary; contacting the issue's initiator for additional information; coordinating with other Technical Advisors, Industries, and Divisions as applicable; and circulating the issue to taxpayers for comment.
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After developing the issue, the Issue Team contacts EO area offices and other Divisions to determine if the Emerging Issue is present on any of the existing cases. The Issue Team must obtain approval of the Director, EO Examinations, and Director, EO Rulings and Agreements, prior to publishing the Emerging Issue.
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Based on the information gathered during the review process, the Issue Team will determine whether the issue materially impacts tax administration and compliance. If it is determined the issue materially impacts tax administration and compliance, the Issue Team may propose a Coordinated Issue. A Coordinated Issue:
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Identifies a key industry-specific or cross-industry issue.
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Ensures uniform treatment of taxpayers but does not represent the official position of the Service.
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Is binding on revenue agents.
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May impact industry-specific or cross-industry cases.
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Resolves compliance problems.
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May potentially impact other Divisions.
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May lead to legislation, litigation or published guidance from Chief Counsel.
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While developing a potential Coordinated Issue, the Issue Team determines whether an interim course of action should be recommended and, if so, how it should be disseminated. The dissemination may be through a memorandum, an EO Directive, an Audit Technique Guide, a CPE presentation, an Issue Alert, an Emerging Issue Notice, a newsletter, etc.
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If it is determined a Coordinated Issue is not warranted, the Issue Team, with Counsel's assistance, prepares an alternative vehicle for guidance to examiners. The guidance may be through a memorandum, an EO Directive, an Audit Technique Guide, a CPE presentation, an Issue Alert, an Emerging Issue Notice, a newsletter, etc.
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The Commissioner, Tax Exempt and Government Entities Division (TEGE), will resolve any disagreement as to whether an issue should be coordinated.
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If it is decided to propose a Coordinated Issue, the Issue Team will be responsible for developing it. Additional taxpayer input and further contact with key cases may be required. The Issue Team may request Field Service Advice, Technical Assistance and/or Technical Advice from Chief Counsel as appropriate.
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The Director, EO Rulings and Agreements, will monitor and process all requests for Coordinated Issues.
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After the proposed Coordinated Issue is developed, it will be formally submitted to the Commissioner, TEGE Division, for approval. This process includes a technical review by the Office of Chief Counsel.
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The proposed Coordinated Issue is submitted to the Director, Rulings and Agreements, through the appropriate Technical Advisor Manager. The proposal should include:
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A concise summary of the issue;
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A statement indicating the proposed Coordinated Issue has been discussed with the appropriate external customers,e.g., industry groups and associations;
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A statement indicating the position has been established and the fact pattern verified.
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Upon receipt and review of the proposed Coordinated Issue, the Director, EO Rulings and Agreements, will forward it to the Division Counsel/Associate Chief Counsel (TEGE) for review.
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The Technical Advisor and the Technical Advisor Manager will monitor the progress of the review by Chief Counsel.
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The Office of Chief Counsel will complete its review of the proposed Coordinated Issue within 90 days of its receipt. During this period, the Office of Chief Counsel will keep the Technical Advisor informed of the status of the review process via monthly progress reports to the Technical Advisor Manager. The Technical Advisor should work directly with the Office of Chief Counsel on any revisions to the proposed Coordinated Issue.
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If the Office of Chief Counsel disagrees with designating the issue as a Coordinated Issue, the Director, EO Rulings and Agreements, may request a meeting with the Office of Chief Counsel and/or Director, EO Examinations, to discuss the matter. The Directors will then make a decision as to whether to proceed with the designation of the issue as a Coordinated Issue. If the Directors cannot reach an agreement, the issue will be brought to the attention of the Commissioner, TEGE Division.
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If the Office of Chief Counsel agrees with designating the issue as a Coordinated Issue, they will notify the Director, EO Rulings and Agreements, through the TEGE Counsel, indicating they concur with the findings of the proposed Coordinated Issue.
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Once so notified, the Director, EO Rulings and Agreements, will forward a copy of the proposed Coordinated Issue to affected Technical Advisors; Technical Advisor Managers; Industry Directors; Director, EO Examinations; and other Offices within TEGE or other Divisions indicating that they may be affected by the proposed Coordinated Issue in order to secure their concurrence. Once all concurrences have been secured, the proposed Coordinated Issue will be submitted for signature to the Director, EO, through the Director, EO Ruling and Agreements and the Division Counsel/Associate Chief Counsel (TEGE).
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Coordinated Issues will become effective upon approval of the Director, EO and delivery to GAO and Congress under Public Law 104-121. At that time, the Coordinated Issue will be released both internally and externally.
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The Director, EO Rulings and Agreements, will review the applicability of issued guidance on an annual basis. If an issued guidance is determined to be no longer applicable, appropriate actions will be taken to withdraw or modify the issued guidance.
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Once an issue is resolved or is no longer applicable, it will be considered for de-coordination. Input from the Director, EO Examinations should be secured for de-coordination.
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After concurrence by affected Technical Advisors and the Director, EO Examinations, requests for de-coordination should be submitted to the Director, EO Rulings and Agreements. The authority to approve the de-coordination of an issue rests solely with the Commissioner, TEGE Division, based on advice from the Director, EO Rulings and Agreements and the Division Counse/Associate Chief Counsel (TEGE). Upon approval, internal and external customers will be notified of the de-coordination.
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The circulation of return information designed to familiarize team members with typical case situations which have arisen, or which would serve to instruct or refresh such employees as to the legal, technical, or procedural issues involved, is permissible within the scope of IRC § 6103(h)(1). However, the dissemination of return information for these purposes is limited to the team members who have a "need to know" the information.It is preferable to use training material foumulated for this purpose that does not contain returns or return information. See IRM 11.3.22.4.1.
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The Technical Advisor should delete the names of taxpayers and/or third parties from circulated return information unless such identification is necessary to understand the purpose for which the material is disseminated. When return information is disseminated, a cover document should clearly indicate the material includes "return information" the dissemination of which should be limited to Service employees with a "need to know" and further disclosure may subject the responsible employee to the civil and criminal sanctions of IRC §§ 7213, 7213A, and 7413.
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It is important to emphasize that return information, as defined in IRC § 6103(b), retains its identity as such, even after identifying material is extracted from it, with the exception of statistical studies and other compilations of data which do not identify individual taxpayers.
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The following are specific answers to questions that have been raised:
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Corporate taxpayers can be told they are part of an Industry-wide Study or are included in a Designated Industry. This information may be disclosed to the corporate taxpayer in various circumstances pursuant to the provisions of IRC §§ 6103(e)(1)(6), (h)(4), and (k)(6).
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The Technical Advisor can permit a free exchange of information about specific cases during industry-wide meetings attended by several different case/group managers.
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If relevant and necessary to discussions or presentations, the Technical Advisor can permit a free exchange of information about specific cases during industry-wide meetings attended by serveral different case/group managers. These meetings must be attended only by appropriate IRS (and Treasury) officials or employees and attendees must be made aware that return information is being discussed/presented which cannot be further disseminated except as permitted by the IRC and Service policy.
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