LB&I directive - Unified guidance on information document requests (IRDs) 

February 28: The IRS Large Business & International (LB&I) division posted a new LB&I directive that is intended to clarify the IRS procedures concerning information document requests (IDRs). LB&I-04-0214-004 (February 28, 2014)

As noted in today’s LB&I directive, the IRS previously issued two directives relating to IRDs—in June 2013 and in November 2013.

Today’s directive incorporates and supersedes the 2013 directives and provides further clarification of the use of the new IDR processes. The purpose of today’s LB&I directive is to allow for the procedures governing IDR issuance and enforcement to be “easily and clearly understood.”

Today’s release also states:

…it is important to continue to emphasize the importance of both the IRS and taxpayers engaging in robust discussions that include the issue that is the subject matter of an IDR, what information is necessary to evaluate that issue and why, what information the taxpayer has and how long it will take to provide it, and how long it will take the IRS to review the information for completeness and respond to the taxpayer.

Meaningful communication between the IRS and taxpayers in advance of an IDR being issued is essential to provide efficiencies for both parties. For example, the IRS will be better able to manage field specialists, determine reasonable estimated closing dates, and reduce unproductive time waiting for information. Similarly, taxpayers will be better able to manage their tax department resources with focused IDR requests that have reasonable time frames. It is anticipated that when both the IRS and taxpayers engage in robust, good faith communication in advance of an IDR being issued, enforcement procedures will be needed only infrequently

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