New LB&I knowledge management strategies: IPGs and IPNs.

• Author: Adams, Robert D.
• Position: IRS Large Business and International Division, issue practice groups, international practice networks

IRS Large Business and International (LB&I) Division executives have I referred several times in recent months to issue practice groups (IPGs) and international practice networks (IPNs). (1) These groups have been mentioned or described generally in formal speeches by IRS Commissioner Douglas Shulman and Steven T Miller, deputy commissioner for services and enforcement, as well as the commissioner and deputy commissioner (international) for LB&I, as part of a new knowledge management strategy. Eleven IPGs are being piloted at the time this is written, and the first two IPNs were launched early this summer. (2)

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LB&I's adoption of the IPG and IPN knowledge management network became official on Aug. 17, when in a memorandum to all LB&I employees, LB&i Commissioner Heather C. Maloy stated:

In place of the Tiered Issue Process, LB&I is developing a knowledge management network (currently being piloted) through the use of Issue Practice Groups ("IPGs") for domestic issues and International Practice Networks ("IPNs") for international issues. IPGs and IPNs are designed to provide examination teams the technical advice they need to manage their cases efficiently, consistently and with a high degree of technical proficiency. IPGs and IPNs are designed to foster effective collaboration and the sharing of knowledge and expertise across LB&I and Chief Counsel. LB&I views the IPGs and IPNs as a better mechanism than the Tiered Issue Process for balancing the need for consistency with the recognition that there is no "one size fits all" approach to examining and resolving issues. (3) Maloy noted that LB&I had used the tiered issue process since 2006 "to set exam priorities and address certain corporate tax issues that it believed posed challenges to compliance." But, she wrote, the division now needs a broader framework for managing compliance priorities and providing guidance to examiners. She wrote:

This new approach should:

* Provide LB&I examiners clear and timely guidance on how to address issues;

* Promote collaboration among LB&I employees;

* Increase accountability and transparency in the resolution of issues; and

* Enable robust lines of communication with taxpayers.4 Although this is still an evolving area, it is an opportune time to explore the nuts and bolts of IPGs and IPNs.

IPGs and IPNs in General

With IPGs and IPNs, LB&I is trying to tackle some age-old concerns and some relatively new ones. One of the chief goals of both IPGs and IPNs is to bring to bear within each practice group or network the best of the wide spectrum of experience and knowledge within LB&I and the Chief Counsel's office. Many revenue agents (RAs) will retire soon, subtracting vast audit experience from LB&I. Some newer RAs hired from private-sector accounting firms and corporate tax departments are specialists in various areas of tax law, business operations, and specific industries but may not have much experience in audits or IRS process and systems. These more recently hired RAs make up over half of all RAs in LB&I. Before the soon-to-be retirees' deep experience in IRS audit techniques, internal process, and face-to-face dealings with taxpayers is lost, LB&I needs to find a way to gather, transfer, and retain those attributes.

Second, it is not easy to identify and access special subject matter expertise around the country within LB&I or among Chief Counsel's field attorneys. Even if these experts are identified, they might not be permitted to spend much time on the matter since they may have previous assignments from direct supervisors who have to meet their own annual commitments. Work rules of the National Treasury Employees Union (NTEU) may prohibit or at least inhibit such crossuse of bargaining unit time as well. Therefore, there needs to be a bridge that allows expertise and knowledge of particular personnel to be used where it is needed, regardless of reporting lines.

Third, consistency needs to be maintained across the country so that similarly situated taxpayers are treated similarly in resolving their issues, regardless of geography. Without a structure at the top that can see all the facets of similar issues across the nation, similar issues likely will not be resolved in a similar manner.

In general concept, IPGs and IPNs are to be the repository of knowledge and expertise in designated subject areas. From them, advice and/or operational rules are imparted to others so that the best decisions may be made in resolving controversial issues. LB&I intends to establish a clear line of sight between people needing help and the IPGs or IPNs, to resolve such issues consistently across the country. IPGs will focus on specific issues, Code sections, or narrow industry matters, just as technical specialists (TSs) do currently, while IPNs will focus on broader subjects that generally align with newly identified areas of emphasis in LB&I's international strategy.'

In short, LB&I wants to use IPGs and IPNs to leverage all its experience and knowledge in the best, most efficient way to gain robust internal dialogue among its agents for deeper understanding and sharing within LB&I. The division wants to foster consistency, based on taxpayer-specific situations. For example, it wants to...