Vol. 30, No. 2 #3 (April 2007). Communicating with the Internal Revenue Service Through the Office of Practitioner Liaison.

• Author: By Christopher M. Reimer, LL.M

Wyoming Bar Journal

2007.

Vol. 30, No. 2 #3 (April 2007).

Communicating with the Internal Revenue Service Through the Office of Practitioner Liaison

WYOMING LAWYER Vol. 30, No. 2 (April 2007) Communicating with the Internal Revenue Service Through the Office of Practitioner Liaison By Christopher M. Reimer, LL.M

A tax practice is unique in that it takes an integrated team to adequately represent our clients. On the front lines, accountants answer most of our individual and small business clients' questions regarding taxes, and also file their annual returns. The tax attorney is often brought in after controversy with the IRS arises. By enhancing communication with our clients (and our clients' advisors) we can provide better tax planning representation, and perhaps help to avoid tax controversy altogether. Throughout every stage of tax representation it is important to try to effectively communicate with the IRS. However, communicating with the IRS can be a thorny task. The IRS has undergone numerous reorganizations over the years, and in 2005 the Small Business/Self Employed division created the office of Stakeholder Liaison. In a nutshell, the Stakeholder Liaison office attempts to establish relationships with organizations representing small business and self-employed taxpayers. The Wyoming State Bar is one such organization. Since 2005, Tom Long and I have represented the Wyoming State Bar in front of the office of Stakeholder Liaison. During that time we have been involved in semi-annual telephone conferences with various IRS employees, including the Wyoming Stakeholder Liaison Area Manager (Northwest Division), and representatives from other areas of the IRS. For example, during our last conference a representative from Treasury Inspector General for Tax Administration (TIGTA) made a presentation on current IRS enforcement activity with respect to Circular 230. Circular 230 governs practice before the IRS (accountants and attorneys alike), and includes some provisions similar to our own Wyoming Rules of Professional Conduct (conflicts of interest, fees, advertising, etc.). A further discussion of Circular 230 and how it may impact your practice is beyond the scope of this article, but I encourage practitioners who are interested to refer to the materials of the "High End Estate Planning" CLE I co-presented at the 2006...