On November 4, 2013, the Large Business and International Division ("LB&I") issued a new directive (“Directive”) providing that an agent generally has no discretion in respect of deadlines for responses to information document requests ("I.D.R.'s"). Due to this Directive, taxpayers subject to this Directive are encouraged not to procrastinate in responding to an I.D.R. The new directive is effective beginning January 2, 2014.

Background

The LB&I serves corporations, subchapter S corporations, and partnerships with assets greater than $10 million, and it also performs various international functions including examinations of individuals and businesses with international tax issues.

When under an audit, the Internal Revenue Service ("I.R.S.") may issue an I.D.R. The I.D.R. requests specific information from the taxpayer in respect of tax issues identified by the I.R.S.

On November 4, 2013, the LB&I released a new directive on I.D.R. enforcement processes. Under this Directive, strict deadlines are enforced in respect of the time required to respond by the taxpayer.

Read the original Client Alert: I.R.S. Imposes Strict Response Times to I.D.R.'s for Large Business and International Taxpayers →