[12588]
September 13, 2000
TO: TAX COMMITTEE No. 39-00
RE: IRS ANNOUNCES COMPREHENSIVE CASE RESOLUTION PILOT PROGRAM
The Internal Revenue Service (“IRS”) has announced1 its Comprehensive Case
Resolution (“CCR”) Pilot Program, through which large business taxpayers may request
expedited resolution of disputed issues in all years open under examination by the Large and
Mid-Size Business Division (“LMSB”), in Appeals, and in docketed status before the United
States Tax Court. Jointly administered by LMSB, Appeals, and Office of Chief Counsel (where
relevant), the CCR program’s stated purpose is to enable taxpayers and the IRS to work
cooperatively to resolve all open issues on all open years currently or previously under
examination.
In the pilot phase, the CCR program is available to large businesses that currently have
at least one open year under a “substantially complete” Coordinated Examination and at least
one prior year in Appeals (including docketed cases currently under Appeals’ jurisdiction). The
resolution process under the CCR program will be the taxpayer’s formal administrative appeal
for the LMSB years, with a target of closing all years within six to twelve months. Notice
2000-43 states that “if agreement cannot be reached using this process, Appeals will not again
consider the unagreed issues from the years under examination by LMSB.”
Taxpayers interested in participating in the pilot CCR program may contact their Team
Manager or the CCR Pilot Coordinator to discuss their suitability for the program. Applications
will be solicited through September 29, 2000, and the IRS will select participants through
October 31, 2000. Participants in the pilot phase of the CCR program will be asked to
participate in an evaluation process.
Naomi Gendler Camper
Assistant Counsel
Attachment
Attachment (in .pdf format)
1 See Notice 2000-43, attached.
2