Who Decides Whether To Authorize a Taxpayer’s Certification For Transitional Treatment To The Streamlined Procedures?
Earlier this week, I spoke to an IRS Revenue Agent who shed some light on how the decision regarding transitional treatment is made for those taxpayers seeking to transition to the Streamlined Procedures from OVDP. Under the current procedures, the agent and his or her manager make the decision regarding transitional treatment, with involvement as necessary […]