1.1.6  Chief Counsel

Manual Transmittal

February 3, 2012

Purpose

(1) This transmits revised IRM 1.1.6, Organization and Staffing, Chief Counsel.

Material Changes

(1) IRM 1.1.6.1.1 was added to designate the First Assistant to the Chief Counsel pursuant to the Secretary of the Treasury’s 10/21/11 decision. See CCDM 30.3.1.7, Acting Chief Counsel under the Vacancies Reform Act and Other Matters of Succession.

Effect on Other Documents

IRM 1.1.6 dated January 12, 2011 is superseded.

Audience

All Divisions and Functions

Effective Date

(02-03-2012)

Michael T. Cochis
Director, Planning and Management Division

1.1.6.1  (01-12-2011)
Chief Counsel for the Internal Revenue Service

  1. The Chief Counsel for the Internal Revenue Service provides advice to the IRS Commissioner on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue laws, represents the IRS in litigation, and provides all other legal support needed by the IRS to carry out its mission of serving America’s taxpayers. In carrying out these responsibilities, Counsel must interpret the law with complete impartiality so that the American pubic will have confidence that the tax law is being applied with integrity and fairness.

  2. The Office of Chief Counsel prepares legislative proposals, regulations, revenue rulings and procedures, actions on decisions, and other items of public guidance and legal advice. The Office coordinates these matters with other components of the Service, the Treasury Department, other government agencies, and international organizations.

  3. The Office of Chief Counsel coordinates the Service’s position in litigation with the Service and the Department of Justice in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. The Office prepares recommendations concerning defense, settlement, appeal, or certiorari; and coordinates other matters with the Department as required.

  4. The Office of Chief Counsel reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with United States Tax Court litigation. The Office processes petitions and complaints, briefs, actions on decision, and other matters.

  5. The Office of Chief Counsel develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memorandums, and Chief Counsel Directives Manual provisions to provide uniform application of law and regulation. The Office provides support and guidance in connection with the development of Internal Revenue Manual provisions.

  6. The Office of Chief Counsel issues Technical advice, and other legal advice responding to questions raised by Service personnel. The Office reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

  7. The Office of Chief Counsel issues letter rulings and general technical information letters in response to requests from taxpayers.

  8. The Office of Chief Counsel also provides guidance on legal matters involving the IRS in the areas of claims, labor and personnel law; ethics and general government law; and public contracts and technology law.

1.1.6.1.1  (02-03-2012)
Organization of the Office of Chief Counsel

  1. The Deputy Chief Counsel (Operations) serves as the principal deputy to the Chief Counsel. The Deputy Chief Counsel (Operations) acts as the Chief Counsel when the office of Chief Counsel is vacant, and, when so acting, may perform all the functions or duties of the Chief Counsel, including any functions or duties that by law must be performed by the Chief Counsel personally. Additional information can be found in CCDM 30.3.1.7, Acting Chief Counsel under the Vacancies Reform Act and Other Matters of Succession.

  2. The organization of the office is depicted in Exhibit 1.1.6-1. Key officials in the Office of Chief Counsel include:

    • Deputy Chief Counsel (Operations)

    • Deputy Chief Counsel (Technical)

    • Special Counsel to the National Taxpayer Advocate

    • Associate Chief Counsel (Corporate)

    • Associate Chief Counsel (Finance & Management)

    • Associate Chief Counsel (Financial Institutions & Products)

    • Associate Chief Counsel (General Legal Services)

    • Associate Chief Counsel (Income Tax Accounting)

    • Associate Chief Counsel (International)

    • Associate Chief Counsel (Passthroughs & Special Industries)

    • Associate Chief Counsel (Procedure & Administration)

    • Associate Chief Counsel/Division Counsel (Criminal Tax)

    • Associate Chief Counsel/Division Counsel (Tax Exempt & Government Entities)

    • Division Counsel (Large Business & International)

    • Division Counsel (Small Business/Self Employed)

    • Division Counsel (Wage & Investment)

  3. The major functions of these officials are described below. Detailed information concerning their duties is contained in CCDM 30.3.2, Delegations of Authority and Designations.

1.1.6.2  (02-03-2012)
Deputy Chief Counsel (Technical)

  1. The Deputy Chief Counsel (Technical) maintains jurisdiction over legal issues arising in published guidance, letter rulings, technical advice, and other processes. The Deputy Chief Counsel (Technical) participates in the interpretation and development of internal revenue laws.

  2. The Deputy Chief Counsel (Technical) supervises:

    • The Associate Chief Counsel (Corporate)

    • The Associate Chief Counsel (Financial Institutions & Products)

    • The Associate Chief Counsel (Income Tax Accounting)

    • The Associate Chief Counsel (International)

    • The Associate Chief Counsel (Passthroughs & Special Industries)

    • The Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities)

1.1.6.3  (01-12-2011)
Deputy Chief Counsel (Operations)

  1. The Deputy Chief Counsel (Operations) maintains jurisdiction over issues arising in litigation nationwide and has primary responsibility for matters involving management of the Office of Chief Counsel. The Deputy Chief Counsel (Operations) participates in the formulation of tax litigation policy.

  2. The Deputy Chief Counsel (Operations) supervises:

    • The Division Counsel (Large Business & International)

    • The Division Counsel (Small Business/Self Employed)

    • The Division Counsel (Wage & Investment)

    • The Division Counsel/Associate Chief Counsel (Criminal Tax)

    • The Associate Chief Counsel (Finance & Management)

    • The Associate Chief Counsel (General Legal Services)

    • The Associate Chief Counsel (Procedure & Administration)

1.1.6.4  (07-29-2005)
Special Counsel to the National Taxpayer Advocate

  1. The Special Counsel to the National Taxpayer Advocate (CNTA) provides legal advice and support directly to the National Taxpayer Advocate and the Taxpayer Advocate Service. As there is no field component to the Office of the CNTA, the Office of the Division Counsel (Small Business/Self Employed) assists in providing legal advice and support to the Taxpayer Advocate Service field offices.

  2. The CNTA is responsible for matters that:

    • Require interpretation of the provisions of IRC §§ 7803(c) and 7811

    • Raise questions regarding the authority delegated to the National Taxpayer Advocate (NTA) and the Taxpayer Advocate Service

    • Relate to the completion of legislative recommendations drafted for the NTA’s Annual Report to Congress

1.1.6.5  (10-30-2008)
National Counsel and Special Counsels

  1. The National Counsel, Special Counsels and other senior advisors serve on the immediate staff of the Chief Counsel to provide advice and guidance regarding the formulation of policy; the management of the legal programs of the Office; the preparation and review of proposed legislation; or technical and legal issues of interest to the Chief Counsel or the IRS.

1.1.6.6  (07-29-2005)
Associate Chief Counsel (Corporate)

  1. The Associate Chief Counsel (Corporate) (CC:CORP) reports to the Deputy Chief Counsel (Technical). The office of the Associate Chief Counsel (Corporate) is located in Washington, D.C.

  2. The Associate Chief Counsel (Corporate) is responsible for tax matters involving:

    • Corporate organizations

    • Reorganizations

    • Liquidations

    • Spin offs

    • Transfers to controlled corporations

    • Distributions to shareholders

    • Debt vs. Equity determinations

    • Bankruptcies

    • Consolidated return issues affecting affiliated groups of corporations

  3. The office of the Associate Chief Counsel (Corporate):

    • Furnishes information, advice, and assistance in the development and drafting of internal revenue legislation

    • Initiates recommendations and coordinates with Legislative Affairs in providing advice and assistance on legislative matters

    • Prepares memoranda or reports to the Associate General Counsel (Legislation, Litigation, and Regulation) setting forth the views of the Office of Chief Counsel on proposed or pending legislation

  4. The office of the Associate Chief Counsel (Corporate) works with Treasury officials on regulations and Treasury Decisions, assesses public comments and conducts public hearings on proposed regulations, and manages the movement of regulations through the review process within the Service and the Department of the Treasury.

  5. The office of the Associate Chief Counsel (Corporate) prepares revenue rulings, revenue procedures, announcements, notices, and news releases to be published for the guidance of taxpayers and Service personnel.

1.1.6.7  (01-12-2011)
Associate Chief Counsel (Finance & Management)

  1. The Associate Chief Counsel (Finance & Management) (CC:FM) reports to the Deputy Chief Counsel (Operations). The office of the Associate Chief Counsel (F&M) consists of a number of divisions and technical and administrative staff in Washington, D.C., and four areas in the field.

  2. The Associate Chief Counsel (F&M) supports the administrative, financial and managerial programs of the Office of Chief Counsel. The office of the Associate Chief Counsel (F&M) performs all Counsel-wide finance and management activities. The office’s major functional areas include:

    • Human Resources

    • Labor and Employee Relations

    • Planning and Management

    • Financial Management

    • Business Systems

    • Library Services

  3. The Associate Chief Counsel (F&M) manages Counsel’s business systems and strategic planning processes, information systems program, and organizational studies and analyses.

  4. The Associate Chief Counsel (F&M) directs the management of the Chief Counsel Library, a highly specialized tax law library system, which supports Chief Counsel and IRS staff in all substantive areas pertaining to tax law.

1.1.6.7.1  (07-29-2005)
Area Manager (F&M)

  1. The field support function is divided into four geographical areas with 10 to 14 posts of duty per area. The Area Managers (F&M) are responsible for managing administrative support to all field operations in the following programs:

    • Legal Services

    • Financial Management

    • Personnel Administration

    • Labor and Employee Relations

    • Library Services

    • Training

1.1.6.8  (06-06-2008)
Associate Chief Counsel (Financial Institutions & Products)

  1. The Associate Chief Counsel (Financial Institutions & Products) (CC:FIP) reports to the Deputy Chief Counsel (Technical). The office of the Associate Chief Counsel (FIP), located in Washington, D.C., consists of:

    • A Deputy Associate Chief Counsel

    • Six branches

    • Technical and planning staff

    • Administrative staff

  2. The office of the Associate Chief Counsel (FIP) provides legal advice, litigation services, and litigation support on tax matters involving financial institutions and the taxation of financial products such as:

    • Insurance companies, products, and annuities

    • Commercial banks and thrift institutions

    • Regulated investment companies and real estate investment trusts

    • Equity and debt securities, discount and premium obligations, options, forwards, futures contracts, financial derivatives

    • Tax exempt bonds

    • Asset securitization, such as real estate mortgage investment conduits

    • Financial strategies, such as hedging arrangements, constructive sales, and straddles

  3. The office of the Associate Chief Counsel (FIP) issues Technical Advice or other legal advice responding to questions raised by IRS personnel; the office issues letter rulings and general technical information letters in response to requests from taxpayers.

1.1.6.9  (07-29-2005)
Associate Chief Counsel (General Legal Services)

  1. The Associate Chief Counsel (General Legal Services) (CC:GLS) reports to the Deputy Chief Counsel (Operations). The office of Associate Chief Counsel (GLS) consists of three branches in Washington, D.C. and six areas in the field.

  2. The office of the Associate Chief Counsel (GLS) represents the IRS and the Office of Chief Counsel in all proceedings not directly related to tax issues, including:

    1. Litigation in proceedings on unfair labor practice, arbitration, adverse action, discrimination, rules of conduct, agency grievance and other employee appeals before the Merit Systems Protection Board (MSPB), the Federal Labor Relations Authority (FLRA), and Equal Employment Opportunity Commission (EEOC)

    2. Litigation in travel claims, bid protests, contract claims, and other government contract proceedings before the General Accounting Office (GAO), the General Services Administration Board of Contract Appeals (GSBCA), Department of Labor (DOL), Small Business Administration (SBA)

    3. Legal advice and assistance with respect to negotiation and collective bargaining

    4. Representation to an employee of the IRS where the employee is or may be subject to a civil or criminal proceeding by reason of their performance of official duties

  3. The office of the Associate Chief Counsel (GLS) reviews and coordinates material prepared in connection with cases in the U.S. Tax Court related to conflict of interest or ethical matters involving:

    • Former employees of IRS and Counsel

    • Practitioners, including the propriety of representations before IRS and the U.S. Tax Court

  4. The Associate Chief Counsel (GLS) is the Deputy Ethics Official (DEO) pursuant to 31 C.F.R. § 0.105.

1.1.6.9.1  (07-29-2005)
Area Counsel (GLS)

  1. Area Counsel (GLS) are located in each of the six geographic offices of the Associate Chief Counsel (GLS):

    • Atlanta

    • Chicago

    • Dallas

    • Manhattan

    • San Francisco

    • Washington, DC

  2. Area Counsel litigate and arbitrate non-tax cases arising in their geographic areas. Area Counsel provide litigation support to the Department of Justice with respect to (or litigate, where appropriate) suits filed under FTCA, Title VII of the Civil Rights Act, suits employing the theory of Bivens v. Six Unknown Defendants of the FBI (Bivens), State court criminal complaints, and other miscellaneous non-tax suits.

  3. Area Counsel provide legal advice to agency employees and components with respect to general government matters involving:

    • Procurement

    • Property management

    • Intellectual property law

    • Federal travel

    • Delegations of authority

    • The Federal Advisory Committee Act

    • Appropriations and grant law

    • The Records Acts

  4. Area Counsel provide legal advice on labor, personnel, and discrimination matters only as related to cases in litigation or concerning which litigation is imminent.

1.1.6.10  (06-06-2008)
Associate Chief Counsel (Income Tax Accounting)

  1. The Associate Chief Counsel (Income Tax Accounting) (CC:ITA) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (ITA), located in Washington, D.C., consists of:

    • A Deputy Associate Chief Counsel

    • Eight branches

    • Administrative staff

  2. The office of the Associate Chief Counsel (ITA) provides legal advice, litigation services, and litigation support on tax matters involving:

    • Recognition and timing of income and deductions

    • Sales and exchanges

    • Capital gains and losses

    • Accounting methods and periods

    • Depreciation and other cost recovery issues

    • Installment sales

    • Long-term contracts

    • Inventories

    • Alternative minimum tax

    • Certain credits

  3. The office of the Associate Chief Counsel (ITA) issues Technical advice and other legal advice or determinations responding to questions raised by IRS personnel; the office issues letter rulings and general technical information letters in response to requests from taxpayers.

1.1.6.11  (07-29-2005)
Associate Chief Counsel (International)

  1. The Associate Chief Counsel (International) (CC:INTL) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (International) consists of six technical branches, four branches in the Advance Pricing Agreement (APA) Program, and administrative staff. The office of the Associate Chief Counsel (International) is primarily located in Washington, D.C.; one branch of the APA program is located in San Francisco.

  2. The office of the Associate Chief Counsel (International) provide legal advisory services that support uniform interpretation, application, enforcement, and litigation of all international and foreign tax matters:

    • Relating to the activities of non-U.S. persons or entities within the United States

    • Involving the international provisions of the United States revenue laws

    • Arising from bilateral and multilateral tax treaties and agreements to which the United States is a party

    • All foreign revenue laws that pertaining to tax matters in the United States

  3. The office of the Associate Chief Counsel (International) formulates and coordinates goals and strategies for the effective and comprehensive strategic management of international issues and assists the Treasury Department and other government agencies in tax treaty negotiations and in negotiations with respect to other international agreements.

  4. The office of the Associate Chief Counsel (International) conducts the negotiation and execution of all Advance Pricing Agreements.

  5. The office of the Associate Chief Counsel (International) provides legal advice and assistance to the United States Competent Authority on all matters of treaty interpretation and implementation, including both substantive legal issues as well as all procedural issues arising out of treaty-based processes, such as information exchange and cross-border information gathering and collection processes.

1.1.6.12  (06-06-2008)
Associate Chief Counsel (Passthroughs & Special Industries)

  1. The Associate Chief Counsel (Passthroughs & Special Industries) (CC:PSI) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (PSI), located in Washington D.C., consists of:

    • A Deputy Associate Chief Counsel

    • Seven branches

    • Technical and planning staff

    • Administrative staff

  2. The office of the Associate Chief Counsel (PSI) provides legal guidance, litigation services and litigation support for tax matters involving:

    • Income taxes of "S" corporations, partnerships (including limited liability companies), estates, and trusts

    • Estate, gift, and excise taxes

    • Oil, gas and other natural resources

    • Depletion

    • General business tax credits

    • Research and experimental expenditures

    • Cooperatives and homeowners associations

    • Low-income housing credit

    • Domestic production deductions

1.1.6.13  (06-06-2008)
Associate Chief Counsel (Procedure & Administration)

  1. The Associate Chief Counsel (Procedure & Administration) (CC:PA) reports to the Deputy Chief Counsel (Operations). The office of the Associate Chief Counsel (P&A), located in Washington, D.C., consists of:

    • The Deputy Associate Chief Counsel (Enforcement)

    • The Deputy Associate Chief Counsel (Guidance)

    • The Deputy Associate Chief Counsel (Legislation and Policy)

    • The Legal Processing Division

    • Seven branches

    • Administrative staff

  2. The office of the Associate Chief Counsel (P&A) provides advice on all facets of judicial and tax administrative practice including matters relating to:

    • Reporting and paying taxes; filing information returns

    • Assessing and collecting taxes (including interest and penalties)

    • Abating, crediting or refunding over-assessments or overpayments of tax

    • Bankruptcy; summonses and information gathering

    • Federal tax liens and levies

    • Damage claims

    • Attorney fees

    • Disclosure, privacy and Freedom of Information Act issues

    • Judicial practice and judicial doctrines

  3. The office of Associate Chief Counsel (P&A) approves actions to be taken with respect to U.S. Tax Court subpoenas and disclosure of information in Tax Court litigation.

  4. The office of Associate Chief Counsel (P&A) serves as the Commissioner’s delegate for assertion of claims of executive privilege involving internal or interagency records or information that are predecisional and deliberative in matters before the U.S. Tax Court, U.S. Court of Federal Claims and other federal courts.

1.1.6.14  (07-29-2005)
Division Counsel/Associate Chief Counsel (Criminal Tax)

  1. The Division Counsel/Associate Chief Counsel (Criminal Tax) (CC:CT) reports to the Deputy Chief Counsel (Operations). The office of the Division Counsel/Associate Chief Counsel (CT) consists of technical, planning, and administrative staff in Washington, D.C., and six areas in the field.

  2. The Division Counsel/Associate Chief Counsel (CT) plans, directs, and coordinates policies and programs with respect to substantive criminal matters, criminal procedure and investigative matters, including:

    • Tax, currency, and money laundering crimes

    • Administrative and grand jury investigations

    • Undercover operations and non-consensual electronic surveillance

    • Search warrants and forfeitures

    • Proposed Grants of Immunity under 18 U.S.C. § 6001, et seq.

    • Referral of cases to the Department of Justice (DOJ) for prosecution or commencement of judicial forfeitures

    • Providing appellate recommendations to DOJ

  3. The Division Counsel/Associate Chief Counsel (CT) provides full time senior attorney(s) as instructors at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia.

1.1.6.14.1  (07-29-2005)
Area Counsel (CT)

  1. Area Counsel (CT) are located in each of the six geographic offices of the Associate Chief Counsel (CT):

    • Philadelphia

    • Baltimore

    • Atlanta

    • Chicago

    • Dallas

    • Laguna Niguel

  2. Each Area Counsel is responsible for advising and counseling the Director, Field Operations in the IRS’ six Criminal Investigation areas and their Special Agents in Charge, located in field offices, in all legal aspects of the criminal tax function.

1.1.6.15  (01-12-2011)
Division Counsel (Large Business and International)

  1. The Division Counsel (Large Business and International) (CC:LB&I) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (LB&I) consists of Special Counsel and administrative staff in Washington, D.C., and five Area Counsels in the field.

  2. The office of the Division Counsel (LB&I) provides legal services on industry-focused issues with an emphasis on global tax administration. The Division Counsel (LB&I) has primary responsibility for providing litigation services and legal advice on matters involving:

    • Subchapter C corporations

    • Subchapter "S" corporations

    • Partnerships with assets greater than $10 million

  3. The office of the Division Counsel (LB&I) handles the litigation of cases pending in the United States Tax Court, and prepares enforcement, defense, and settlement letters in summons enforcement and refund litigation cases. The Division Counsel (LB&I) makes recommendations of acquiescence and nonacquiescence in adverse decisions in litigation.

  4. The office of the Division Counsel (LB&I) manages the Significant Case Program, which allows for coordination of significant cases approaching litigation.

1.1.6.15.1  (01-12-2011)
Area Counsel (LB&I)

  1. The Area Counsels serve as the principal legal advisor to their respective IRS Industry Director with which they are aligned. The five Area Counsels are:

    • The Area Counsel for Financial Services (Area 1), Manhattan

    • The Area Counsel for Heavy Manufacturing and Transportation (Area 2), Philadelphia

    • The Area Counsel for Retailers, Food, Pharmaceuticals and Health Care (Area 3), Downers Grove

    • The Area Counsel for Natural Resources and Construction (Area 4), Houston

    • The Area Counsel for Communications, Technology and Media, (Area 5), Oakland

  2. Each Area Counsel is responsible for legal work within a defined geographic area and for developing specialized knowledge of one of the industries served nationally by the IRS.

  3. Within each area, Deputy Area Counsel provide primary support to Industry Director staff with respect to:

    • Industry specific pre-filing, filing, and post- filing activities

    • Litigation matters

1.1.6.16  (10-30-2008)
Division Counsel (Small Business/Self-Employed)

  1. The Division Counsel (Small Business/Self-Employed) (CC:SBSE) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (SB/SE) consists of technical, planning, and administrative staff in Washington, D.C., and nine areas in the field.

  2. The Division Counsel (SB/SE) is the principal legal advisor to the Division Commissioner, SB/SE, and to the field components of the Wage & Investment Division, the Taxpayer Advocate Service, and the SB/SE function of the Appeals Division.

  3. The office of the Division Counsel (SB/SE) provides legal advice, services and litigation on matters relating to:

    • All cases involving collection and bankruptcy issues, regardless of their taxpayer classification

    • Individuals who file Schedules C, E, or F, or Forms 2106

    • Estate and gift tax returns

    • Fiduciary returns

    • Excise tax returns and/or forms

    • Individuals with international tax returns

    • Corporations, "S" corporations and partnerships with assets less than $10 million

    • Individuals classified as Wage & Investment taxpayers

1.1.6.16.1  (10-30-2008)
Area Counsel (SB/SE)

  1. Area Counsel (SB/SE) are located in each of the nine geographic offices of the Associate Chief Counsel (SB/SE), coinciding with one or more IRS SB/SE compliance areas:

    • Manhattan

    • Philadelphia

    • Jacksonville

    • Chicago

    • Denver

    • Dallas

    • San Francisco

    • Los Angeles

    • Kansas City

  2. The Area Counsel are responsible for providing legal advice and opinions relating to the matters listed in paragraph (3) above within their geographical areas.

  3. The Associate Area Counsel (SB/SE) are the first-line managers of SB/SE attorneys and paralegals. The Associate Area Counsel report to the Area Counsel responsible for their geographic area.

  4. SB/SE attorneys handle U.S. Tax Court and bankruptcy cases. Many bankruptcy cases involving tax claims are assigned to attorneys who are designated as Special Assistant U.S. Attorneys. Attorneys may also be assigned to assist the Department of Justice in the handling of collection, refund and other cases in the U.S. District Courts.

1.1.6.17  (12-16-2009)
Division Counsel/Associate Chief Counsel (Tax Exempt & Government Entities)

  1. The Division Counsel/Associate Chief Counsel (Tax Exempt & Government Entities) (CC:TEGE) reports to the Deputy Chief Counsel (Technical). The office of Division Counsel/Associate Chief Counsel (TE/GE) is located in Washington D.C. and in several field offices. The office consists of:

    • A Deputy Division Counsel/Associate Chief Counsel (Employee Benefits)

    • A Deputy Division Counsel/Associate Chief Counsel (Exempt Organizations, Employment Tax and Government Entities)

    • A Deputy Division Counsel/Associate Chief Counsel (Field Service)

    • Eight branches

    • Technical and planning staff

    • Administrative staff

    • Six Area Counsels

  2. The Division Counsel/Associate Chief Counsel (TE/GE) is responsible for issues pertaining to the uniform interpretation and application of federal tax laws involving:

    • Employment taxes and taxes on self-employment income

    • Exempt organizations

    • Employee benefit plans (including employer-provided medical plans)

    • Executive compensation

    • Indian tribal governments

    • Federal, state, and local governments

  3. The office of the Division Counsel/Associate Chief Counsel (TE/GE) represents the Service in litigation in the U.S. Tax Court and serves as the chief legal advisor with respect to legislation, regulations, and other guidance; rulings; advisory opinions; and litigation within its jurisdiction.

1.1.6.17.1  (06-06-2008)
Area Counsel (TE/GE)

  1. Area Counsel offices are designed as groups of versatile specialized staff providing nationwide advisory and litigation services to the TE/GE Operating Division on employee benefits, exempt organizations, employment taxes, and government entities issues.

  2. The six Area Counsels are:

    • Northeast (Long Island)

    • Mid-Atlantic (Baltimore)

    • Great Lakes (Chicago)

    • Gulf Coast (Dallas)

    • Mountain States (Denver)

    • Pacific Coast (Los Angeles)

1.1.6.18  (07-29-2005)
Division Counsel (Wage & Investment)

  1. The Division Counsel (Wage & Investment) (CC:WI) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (W&I) consists of technical staff and is located in Washington, D.C.

  2. The Division Counsel (W&I) provides advice on the legal issues, regulations, and needs relevant to serving all wage earning or investing taxpayers who generally have income reported only on Forms W-2 and 1099.

  3. The Division Counsel works closely with the IRS W&I Division Commissioner in formulating the Division’s program policies, programs, systems and strategies, and assists the Division in determining how to better serve their taxpayer segment. The field staff of the Division Counsel (Small Business/Self Employed) provides legal services to the IRS W&I Division field organization.

1.1.6.19  (01-12-2011)
Field Management Matrix

  1. The Field Management Matrix is an integrated management structure that balances geographic and functional needs at all levels, but does not change the existing Divisional lines of authority or supervisory chains of command. The Field Management Matrix focuses on office-wide issues of teamwork, resource allocation, and skill development. The matrix structure requires the appointed managers to assume additional duties to support cross-Divisional coordination and communication.

  2. Managing Counsel are appointed in each of the 48 posts of duty to address issues that have an office-wide impact, such as the following:

    • Office closings

    • Office functions

    • Recruitment

    • Training

    • Local bar and taxpayer community contacts

  3. Area Teams interact with Managing Counsel, assume a leadership role that transcends existing Division management roles, ensure collaboration and cooperation across Divisions, maintain high levels of Service-wide client satisfaction, and foster an effective relationship with the National Treasury Employees Union (NTEU). The teams are comprised of appointed representatives from each business unit, one of which is selected as the Team Leader, within the following geographic areas:

    • Northeast — CT, MA, ME, NH, NY, RI, VT

    • Central — DC, DE, KY, MD, MI, NJ, OH, PA, WV

    • Southeast — AL, AR, FL, GA, LA, MS, NC, SC, TN, VA

    • Midwest — IA, IL, IN, KS, MN, MO, ND, NE, SD, WI

    • Southwest — AZ, CO, MT, NM, NV, OK, TX, UT, WY

    • West — AK, CA, HI, ID, OR, WA

Exhibit 1.1.6-1 
Chief Counsel Organization

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