THE PURPOSE OF this article is to provide a general overview of the substantive rules of practice and procedure as set forth in the Internal Revenue Code (the “Code”),1 the Treasury Regulations and decided cases that apply to federal income tax controversies and to offer practical strategies on how to represent a taxpayer before the Internal Revenue Service (the “IRS” or the “Service”) in examinations.
THE IRS MISSION AND ORGANIZATION FOR EXAMINING TAXPAYERS AND TAX RETURNS
In 1998 the IRS revised its long-standing mission statement to read: “Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all.”2 This mission statement was required to be revised by the IRS Restructuring and Reform Act of 1998, Pub. L. No. 105-206, hereafter referred to as “the Restructuring Act,” to provide greater emphasis on serving
the public and meeting the needs of taxpayers.
The mission of the Examination Division of the IRS is to further public confidence in the enforcement of the tax laws:
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