On June 18th, 2013, the Large Business and International Division (LB&I) of the IRS released a memorandum (LB&I-04-0613-004) outlining changes to the Information Document Request (“IDR”) process. In particular, the IRS provided that all IDRs issued after June 30, 2013, must be issue focused, they must be discussed with the taxpayer, and the taxpayer and examiner must discuss a reasonable time frame for responding to the request. The IRS intends for adherence to these guidelines to result in a more efficient IDR process with less of a need for IDR enforcement. Nevertheless, the IRS also stated in the memorandum that it will make changes to the IDR enforcement procedure in the near future. The deadlines outlined in the LB&I memorandum are intended to be firm, which has led to some concern that agents will lose flexibility in examinations, though the Service believes that the pre-IDR discussions can alleviate some of those concerns. The Service has not yet stated when additional guidance on the new procedures will be announced.
LB&I Announces Changes to Information Document Request Process
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