Mechanical debulking with endoscopic biopsy forceps allowed for passage of the bronchoscope to the distal LMSB
where a metallic foreign body was appreciated (Figure 2(b)).
Among the other highlights was the unveiling of the IRS new, International organization by Michael Danilack, LMSB
's Deputy Commissioner (International).
In the third LMSB
directive (LMSB-04-0209-004), issued on March 4, 2009, the industry director took up the issue of how prior-period expenses might result in the creation of DPGR in future years, even though the expenses may have resulted from activities that took place prior to the effective date of section 199.
The strategic initiatives identified by the LMSB
Division for 2007 also identified principal compliance objectives a private company can use to avoid an IRS audit.
The procedure for using FTS for SB/SE taxpayers depends on the procedure set forth in Revenue Procedure 2003-40 for the LMSB
FTS Dispute Resolution Program, although the programs are run separately.
The Commissioner explained that the National Office appreciates that uncertain tax positions should not automatically be challenged and assured TEI that LMSB
will emphasize this during its training program.
Introduced in 2006 as an element of LMSB
issue management strategy, issue tiering is intended to strengthen the LMSB
's ability to identify and prioritize certain issues in a coordinated manner, thereby providing consistent treatment among taxpayers.
For example, in an attachment to the LMSB
memo (and in a shorter form in the SB/SE excise tax memo) the Service suggests questions for examiners to ask taxpayers in connection with potential preparer penalties, including:
As stated in Notice 2001-67, the purpose of the pilot is "to enable taxpayers and the IRS to work together in a concentrated and expedited fashion to resolve outstanding issues while the case is in LMSB
jurisdiction." Thus, a taxpayer selecting this program has the opportunity to be heard by an Appeals Division mediator prior to the issuance of a 30-day letter.
Commissioner Maloy welcomed TEI President Neil D.
PFA program is designed to enable eligible taxpayers--whether or not they are under IRS audit--to resolve the tax treatment of issues the agency is likely to challenge or dispute in a post-filing audit before the business files next year's tax return (including extensions).
She explained that anxiety that auditors will use the positions reported on the new schedule as the basis for sending Notices of Proposed Adjustment or use the maximum tax adjustments reported as the starting point for discussion of amounts at issue are "unfounded." To allay taxpayer skepticism, she referred to the high level of taxpayer satisfaction with LMSB
's Compliance Assurance Process (CAP) program as an example of the IRS not abusing taxpayer transparency.