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Weekly IRS Roundup January 1 – January 5, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 1, 2024 – January 5, 2024.

January 2, 2024: The IRS released Internal Revenue Bulletin 2024-1, which includes the following:

  • Revenue Procedure 2024-1, which contains the revised procedures for letter rulings and information letters issued by the different offices of the associate chief counsel. This revenue procedure also contains the revised procedures for determination letters issued by the Large Business and International Division, the Small Business/Self-Employed Division, the Wage and Investment Division and the Tax Exempt and Government Entities (TE/GE) Division.
  • Revenue Procedure 2024-2, which explains when and how associate chief counsel offices should provide advice in technical advice memoranda (TAM). The revenue procedure also explains taxpayers’ rights when a field office requests a TAM.
  • Revenue Procedure 2024-3, which provides a revised list of areas of the Internal Revenue Code under the jurisdiction of the associate chief counsel’s offices of Corporate; Financial Institutions and Products; Income Tax and Accounting; Passthroughs and Special Industries; Procedure and Administration; and Employee Benefits, Exempt Organizations, and Employment Taxes. These relate to matters in which the IRS will not issue letter rulings or determination letters.
  • Revenue Procedure 2024-4, which provides guidance on the types of advice the IRS offers to taxpayers on issues under the jurisdiction of the Commissioner, TE/GE Division and Employee Plans Rulings and Agreements. It also details the procedures that apply to requests for determination letters and private letter rulings. This revenue procedure updates Revenue Procedure 2023-4.
  • Revenue Procedure 2024-5, which provides the procedures for issuing determination letters on issues under the jurisdiction of the Director, Exempt Organizations Rulings and Agreements.
  • Revenue Procedure 2024-7, which provides the areas under the jurisdiction of the associate chief counsel (international) in which letter rulings and determination letters will not be issued.

January 4, 2024: The IRS encouraged taxpayers to check out IRS.gov for tips, tools and resources to help them prepare to file their 2023 federal income tax returns.

January 4, 2024: The IRS published Tax Tip 2024-01, which provides a brief overview of tax credits and deductions for individuals.

January 5, 2024: The IRS announced an extension for dealers and sellers of clean vehicles to submit time-of-sale reports. Dealers and sellers generally will now have until January 19, 2024, to submit a time-of-sale report for vehicles sold from January 1, 2024, through January 16, 2024.

January 5, 2024: The IRS announced the launch of a special Tax Professional Awareness Week that will commence January 8, 2024, and assist tax professionals on what to expect during the 2024 filing season.

January 5, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief [...]

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Nominations Announced for Tax Court and IRS Commissioner

On January 23, 2018, President Trump announced his intent to nominate Courtney Dunbar Jones to the US Tax Court. He previously nominated Elizabeth Copeland and Patrick Urda on August 3, 2017.

Courtney Dunbar Jones is a senior attorney in the Tax-Exempt and Government Entities division in the Office of Chief Counsel of the Internal Revenue Service (IRS). If confirmed, she will assume the position left vacant by the 2016 retirement of Judge John O. Colvin. Judge Colvin still performs judicial duties as a Senior Judge on recall.

On January 24, 2018, numerous press outlets announced that President Trump will nominate Charles “Chuck” Rettig of Hochman, Salkin, Rettig, Toscher & Perez, to serve as the next Commissioner of the IRS.

Rettig has been in private practice at Hochman, Salkin for more than 35 years and has a long record of leadership in our field. Among his many accomplishments, Rettig was instrumental in working with the IRS to establish key settlement initiatives over the last 15 years, including providing key practitioner guidance in designing the Offshore Voluntary Disclosure Program.

If confirmed, Rettig would helm an IRS that has been significantly reshaped by budget cuts and staff attrition in recent years. Rettig would also oversee the implementation of tax reform. Rettig has been a friend and mentor to many of us in the tax controversy bar over the years, and we are encouraged by the selection of someone from the private bar to the post.




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IRS Announces New Chief of IRS Appeals

In further changes to the Internal Revenue Service (IRS) Appeals Division, it was recently announced that Donna C. Hansberry will replace Kirsten B. Wielobob as chief of IRS Appeals. Ms. Hansberry is currently the deputy commissioner of the Tax Exempt and Government Entities Division. She started as a trial attorney for the IRS Office of Chief Counsel in 1987 and was previously assistant to the commissioner (attorney-advisor for tax). Ms. Weilobob will move to the position of deputy commissioner for services and enforcement.

There have been very significant changes to IRS Appeals during the last several months that challenge whether the division will continue to be a successful tool for taxpayers and the IRS to resolve difficult cases that are stuck at the Exam Division. The “changing of the guard” may be a sign of more changes to come. Indeed, Ms. Hansberry was formerly a trial attorney and was in charge of the Joint International Tax Shelter Information Centre, director of global high wealth and abusive transactions. For prior coverage on changes at IRS Appeals, see our previous articles:

“More Changes to IRS Appeals Procedures”

“IRS Appeals – Changes Afoot?”

“IRS Updates Rules Regarding Appeals Conferences”




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