Tax Controversy & Dispute Resolution ()
The Large Business & International Division (LB&I) of the Internal Revenue Service issued on February 28, 2014 a third directive that provides further clarification of the use of the new information document request (IDR) process. The directive incorporates and supersedes the two prior LB&I directives concerning the IDR process issued on June 18, 2013 and November 4, 2013. Pursuant to the directive, the IDR enforcement process is effective March 3, 2014. However, the IRS will not issue delinquency notices, the first step in the graduated three-step enforcement process, prior to April 3, 2014.