Note. This Memorandum supplements Tax Resource Manual 15.
October 1, 2013
|To:||Chiefs, Assistant Chiefs, Senior Litigation Counsel, and Line Attorneys
Criminal Enforcement Sections
Assistant Attorney General
|Subject:||Supplemental procedures for Tax Division conferences associated with litigation to which a Tax Division attorney has been assigned|
To ensure the continued independent evaluation of a matter referred to the Tax Division for prosecution, when a taxpayer requests a Tax Division conference in litigation handled wholly or in part by a Tax Division attorney, the following procedures will apply:
- Upon request of the taxpayer, where a line attorney who is not a Senior Litigation Counsel has been or will be assigned to litigation of the case, a manager or Senior Litigation Counsel will attend the Tax Division conference;
- Where a manager or Senior Litigation Counsel has been or will be assigned to litigation of the case, a different manager or Senior Litigation Counsel will attend any requested Tax Division conference along with the assigned attorney(s), and will be assigned to review any memoranda prepared by the manager or Senior Litigation Counsel assigned to litigate the case; and
- Upon completion of the conference, a memorandum of the conference should be prepared by one of the Tax Division participants and should be signed by all Tax Division participants.