Stock Manager V3.4.52.rar
The issue manager, in collaboration with the case manager, will lead the issue team in resolving issues utilizing appropriate issue resolution tools. Expeditious issue resolution necessitates open communication, cooperation and collaboration among the issue team members and with the taxpayer. Issue exit strategies will be considered for recurring and carryover issues to provide certainty for the government and the taxpayer.
Stock Manager v3.4.52.rar
Resolution: LB&I managers have the broad authority to resolve issues based upon the application of the tax law to the facts and circumstances. Other issue resolution tools, as outlined in IRM 184.108.40.206, Issue Resolution Tools, should be used to resolve issues when appropriate.
Case managers will look to applicable delegation orders for potential issue resolution tools. See Delegation Order 4-24 (Rev. 1) in IRM 220.127.116.11.20 and Delegation Order 4-25 (Rev. 2) in IRM 18.104.22.168.21.
LB&I managers have the authority to accept settlement offers on any issue in a Large Business and International (LB&I) case under their jurisdiction where a settlement (including a hazards settlement) has been effected by Appeals in a previous, subsequent or the same tax period (the settled period) with respect to the same issue of the same taxpayer, or of another taxpayer who was directly involved in the transaction or taxable event.
The issue manager must review, approve and sign the NOPA before issuance to the taxpayer. The case file must document all meaningful efforts by both the issue manager and the case manager to resolve issues.
The case manager has responsibility for the preparation and delivery of the 30-day letter to the taxpayer. See IRM 22.214.171.124.1, 30-Day Letters, for guidance on the required form letters. The 30-day letters will be expeditiously prepared and mailed in accordance with existing procedures. The case will be included in the 30-day letter suspense files at the group level and updated timely to status 13 on ERCS after the mailing of the 30-day letter to the taxpayer.
The case manager will monitor cases in status 13 to ensure timely closure of cases to Appeals. Large Corporate Compliance (LCC) cases often have complex issues with a lengthy protest that must be fully addressed. LCC cases should close to Appeals within 240 days of the issuance of the 30-day letter. For all other workstreams, the case should be closed to Appeals within 120 days from the issuance of the 30-day letter.
The taxpayer may request an extension of time in which to file a protest. Before an extension is granted, the examination team must determine if a statute extension should be solicited to ensure adequate time to address the protest and still meet the remaining time on the statute requirements set by Appeals. The case manager, in collaboration with the issue manager(s), may approve the request based on the facts and circumstances in each case. Letter 686 may be used for this purpose.
The team coordinator and case manager must be aware of circumstances in which Appeals will not accept a case from LB&I. Refer to IRM 126.96.36.199, Returning a Case to Examination - ATE, for list of possible circumstances.
A case-specific advisory memorandum (Feedback Memo) will be issued to all examiners and specialists whose work product has been reviewed. Case quality scores will not be included. An advisory memorandum will be distributed electronically to examiners or specialists and their manager. Examiners or specialists who have questions concerning the contents of a memorandum may submit inquiries electronically to the address the advisory memorandum transmitted and a reply will be provided by QRA. If there is a serious disagreement with the results of the review between the reviewer or review team and examiner or examination team, the examiner or exam team will have the right to elevate the disagreed issues.
LQMS results are not to be used to evaluate the performance of an individual employee or team. Upon receipt of the advisory memorandum, the manager will discuss, as appropriate, its contents with the employee. Unless employees provide their manager with a written or email request that a copy of the memorandum be retained in his/her Employee Performance File, all copies of the memorandum will be disposed of by the manager no later than (45) days after the issuance date.
If the recurring issue is due to inadequate records, the taxpayer will be advised in writing relative to the areas where the accounting procedures or practices are inadequate or need to be changed. The inadequate records notice will be issued by the case manager and should be directed to the principal corporate officer responsible for taxes. See IRM 188.8.131.52, Inadequate Records Notices: Overview.
All cases related to the key case must be closed through the primary examination group. An exception applies for employment tax, excise tax and withholding tax cases, which generally close out of their respective specialty groups. The case manager enters all closing data in IMS.
Electronic Data Retention: IMS is considered an official record keeping system with the same confidence as a paper case file. It is important that all required case file documents are uploaded and verified in IMS. The examiner and the team manager must review the documents uploaded in IMS for accuracy and completeness in the same manner a paper case file is reviewed and assembled. Refer to IRM 4.46.6, Workpapers and Reports Resources, for guidance on lead sheets, naming convention and required workpapers. See IRM Exhibit 4.46.6-4 for guidance on uploading documents in IMS.
Exception to Paperless Case Closing: Most documents should be in digital format already. However, if an examiner is unable to scan paper documents using the high-speed multi-functional copy/scanner device (MFD) provided in the employees POD, the examiner can discuss the facts and circumstances with the team manager. This discussion must be documented in the case file. The examiner can follow the procedures in IRM 184.108.40.206.2.4 , Exception to Paperless Case Closing to CCP, to close the case electronically to CCP and mail the case file to Files.
Exception for Pathway Hires: Most Pathway hires use stand-alone RGS (not on CEAS) for the first two years of the four-year training program. For the Pathways program cases using stand-alone RGS, examiners will upload the NForwardX1.zip file to SAIN 007, Report Preparation, in IMS. The NForwardX1.zip file must contain all forms and documents that are required in a paper case file (as noted in Step 1). The manager must review the NForwardX1.zip file to ensure all documents load properly in RGS. The Memo to File must be completed with the taxpayer information and uploaded to SAIN 090 along with all other required closing documents (see Step 2). See the Memo to File at this link: -%20Memo%20to%20File.pdf
Step 1 applies to all managers and examiners working on the case. The case and/or issue manager of each employee on a case with workpapers or other aspects to upload must review and ensure the documents are uploaded timely and accurately so the case can close.
LB&I Manager Verification of Unagreed Case: For cases meeting the criteria noted in paragraph (1), LB&I managers must verify the following information prior to sending the case to Appeals:
The crucial step for the LB&I manager is to close the case off IMS. Any electronic documents needed for the paper file must either be saved or printed directly from the IMS Team Website after resumption of normal operations. If the case is not closed off IMS, Appeals CANNOT start case. Failure to do this step properly may result in your case being returned from Appeals.
If any relevant documents are not in IMS, the case is at risk of being returned to the team. If notified of issues, the team manager must upload these documents directly to the Appeals SharePoint site and the IMS team website immediately.
If a case is going to Appeals, workpaper files are forwarded to Appeals for their use in resolving the unagreed issue(s). LB&I case examination workpapers will be forwarded with the closed case file. Team managers will ensure appropriate reports, schedules, workpapers and other administrative data that may be needed for future examinations are uploaded to IMS so they are available to subsequent examination teams.
If files need to be shipped to another location, the case manager will control the documents by utilizing Form 3210, Document Transmittal. Form 3210 must always accompany taxpayer sensitive records shipped to other offices (for example, Appeals, Counsel, LB&I Quality Review and Analysis, etc.).
When Appeals releases jurisdiction of cases to LB&I, Appeals will update the case in IMS. The update will generate an e-mail to the case manager and team coordinator informing them that the case is being returned to the group. The appeals officer will complete Form 5402, Appeals Transmittal and Case Memo, and state that the taxpayer has provided Appeals with new information and the case is being returned to LB&I. The actual hardcopy case will be returned through Technical Services.
The case manager may perform a critique of the completed cycle through a collaborative meeting or through multiple meetings. The critique should be held during the final stages of the examination or within thirty days after the case is closed from the field. Critiques should be held even when there are overlapping examinations.
The case manager, issue manager(s) and issue team members should keep in mind that the primary objective for conducting the critique is to evaluate opportunities to improve future examinations. The recent examination must be thoroughly evaluated with emphasis on how subsequent examinations, if warranted, can be improved. Some of the more important topics to be discussed during the critique are listed below:
Determination as to whether the examination procedures were effective and efficient. This appraisal should be sufficiently detailed to provide the case manager and/or issue manager(s) of the subsequent examination a basis for adopting new examination techniques and planning new specialized computer programs. 041b061a72