The IRS Large Business & International Division recently issued a directive to all LB&I employees that should improve the way that they, and taxpayers, deal with Information Document Requests. Major considerations include:
- The directive applies for IDRs issued after June 30, 2013—not examinations begun after that date. All IDRs issued since that date and going forward are subject to this new directive
- Some revenue agents have required taxpayers to sign separate agreements on the IDR management process. This directive obviates those agreements.
- If these process directions are not followed and the taxpayer believes it would benefit from their use, it is advisable to use LB&I's Rules of Engagement and begin elevating the matter through the management and executive ranks.
- Taxpayers need to be certain that agreements reached for documentation in an IDR are met, but that if more time subsequently is needed, that they discuss it ahead of time with the agent. The LB&I Commissioner's comments included a reminder that summonses are always a possibility, but she did not anticipate many would be issued if the process is working properly.