In addition, they prescribe required supervisory approval and procedures for imposing a preparer penalty and for making referrals to the IRS Office of Professional Responsibility. The memos can provide practitioners with useful insights into administrative guidelines examiners are expected to follow in deter...
The Second Circuit held that there was a clear distinction between a referral and the beginning of a collection proceeding. It further stated that the Code is silent on when a case can be referred to the DOJ. Therefore, regulations that limit the IRS’s referral power “cannot read ...