Tax Analysts Tax Notes reports that the IRS Large Business and International Division (LBI) released mandatory, stringent new procedures for enforcing information document requests (IDRs) and issuing summonses, minimizing examiners' discretion even at the manager level.
Under the new process effective January 2, if information requested in an IDR isn't received by the IDR response deadline and the new requirements for issuing IDRs have been followed, the LB&I examiner is required to issue a delinquency notice within 10 calendar days of the IDR response deadline. If the IDR response remains incomplete by the delinquency notice deadline, the examiner is required to issue a pre-summons letter within 14 calendar days of the delinquency notice deadline that sets another new deadline, which can't be more than 10 calendar days away unless the director of field operations grants approval. If the IDR response remains incomplete by the pre-summons letter deadline, the examiner is required to coordinate the issuance of a summons with assigned counsel.
