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Appeals Settlement Guidelines (ASG)

NOTE: Coordinators may have changed since settlement guidelines were published. Please refer to the Technical Guidance - International Index (PDF) for the latest coordinator contact information.

Abusive Tax Avoidance Transactions

  • Business Directory for Visually impaired
  • Deductions for Contributions to 401(k) or Defined Contribution Plans during Grace Period, Related Change of Accounting Adjustments, and Penalties;
  • Domestic Abusive Trust Schemes
  • Home Based Business Promotions
  • IRC Section 302/318 Basis Shifting Transactions
  • IRC Section 351/Contingent Liability
  • IRC Section 44 Disabled Access Credit Tax Avoidance Schemes
  • Intermediary Transaction Tax Shelters and Penalties
  • Internet Shopping Portal
  • Lease in, lease out (LILO)
  • Notice 2000-15 Abusive Charitable Remainder Trusts
  • Notice 2000-44 Transactions - Described as generating losses resulting from artificially inflating the basis of partnership interests
  • Notice 2002-21 Transaction involving the use of a Loan Assumption agreement to claim an inflated basis in assets acquired from another party
  • Notice 2002-35 Involves the use of a National Principal Contract to claim current deductions for periodic payments while disregarding the accrual of a right to receive offsetting payments in the future
  • Notice 2002-50 Transactions involving the use of a straddle, a tiered partnership structure, a transitory partner, and the absence of a sec 454 election to claim a permanent noneconomic loss
  • Notice 2002-65 Pass-through Entity Straddle Tax Shelter Transactions and Penalties
  • Notice 2003-47 Transfers of Compensatory Stock Options to Related Persons
  • Notice 2003-22 Certain arrangements involving employee leasing companies that have been used to avoid or evade federal income and employment taxes.
  • Notice 2003-35 Tax Exempt Small Insurance Company Transactions
    under 501(c)(15) and related penalties
  • Notice 2003-77 IRC 461(f) Contested Liabilities Transactions
  • Preparer/Promoter Penalties
  • Sale in, lease out (SILO)
  • Telecommunication System for Hearing Impaired

Air Transportation

Cafeteria Plans

  • Heath Insurance Deductibility for Self-employed Individuals

COLI (Corporate Owned Life Insurance)

Commercial Banking

  • Accrual of interest on non-performing loans (see Banking - Savings and Loan)
  • Foreign Withholding Taxes (Cross Border Loans)
  • Interchange Merchant Discount Fee

Construction/Real Estate

  • Claim Revenue Under a Long-term Contract

Employment Tax

  • Medical Resident FICA Refund Claims


  • IRC 1341 Environmental Remediation Costs

Excise Tax

  • Virtual Private Networks

Food Industry

Forest Products

Fuel from a Nonconventional Source (FNS)

  • Methane Gas Project (IRC § 29 Credit), Credit for FNS


I.R.C. § 118 SALT

Insurance – Life

  • IRC 807 Basis Adjustment – Change in Basis vs. Correction of Error
  • Loss Utilization in a Life-nonlife Consolidated Return Separate v. Single Entity Approach


Interest Computations

  • Net Rate Interest Netting - Requirement that Both Statutes be Open for Pre-98 Act Years
  • Overpaid Estimated Taxes


  • Foreign Sales Corporations (FSC) Advance Payment Transactions


Leasing Promotions

Mare Leasing

Primary issue of whether expenses were incurred in carrying on a trade or business. Alternatively, whether individuals were materially participating and at risk; whether expenses were ordinary and necessary; and whether expenses should be capitalized or currently deducted.


  • IRC Section 1504(d) Election
  • IRC Section 168(g)


  • Investment Tax Credit - Transition Property



Motor Vehicle

Notional Principal Contracts


  • Subchapter K Anti-abuse Regulation 1.701-2


  • Capitalization of Delay Rentals
  • Cost Depletion Recoverable Reserves
  • North Sea IDC Transition Rule


  • Medicaid Rebates
  • Research and Experimentation Expenditures (Reg. 1.861-17(a)(4)

Research Credit


S Corporations

  • Shifting of Income to Tax Exempt Organization (SC2)

Savings and Loans

  • Supervisory Goodwill
  • Accrual of Interest on Non Performing Loans (see Banking)
  • Validity of Regulations Sec. 1.593-6A(b)(5)(vi)
  • Supervisory Goodwill

Securities & Financial Services

  • Transfer or Sale of Compensatory Options or Restricted Stock to Related Persons- Notice 2003-47


Sports Franchises

  • Media Rights Acquired in Connection with a Sports Franchise

State Refundable Credits


  • Taxation of Universal Service Fees


  • Investment Credit Transition Property
  • Membership Payments Made to Industry-created Research Organizations
Page Last Reviewed or Updated: 24-Nov-2014