Caroline Rule Published in The CPA Journal, Tax Practice and Procedure, October 2015, "The IRS LB&I’s New Document Request Process, 18 Months Later: How It Works, and How to Make it Work.”

On February 28, 2014, the IRS Large Business and International Division (LB&I) issued a directive LB&I-04-02-004, setting forth how LB&I intended to fundamentally change its procedures for issuing information document requests (IDR) (IRS Form 4564). The issue, went into effect on March, 3, 2014. It provides that 1) draft IDRs are issued and 2) if taxpayers do not timely comply with the ensuing IDRs , enforcement through the issuance of summonses is mandatory. It should be noted that. while the 2014 directive is to be followed by all LB&I employees, it does not confer substantive rights on taxpayers.

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