Plans, directs and coordinates the legal work of the CT function.

Provides input to the Chief Counsel, Chief, Criminal Investigation and other senior executives within CI on matters of CT policy.

Reviews high profile/sensitive cases centralized in the National Headquarters.

Plans and implements actions, including periodic meetings, necessary to create and maintain strong communications within the CT function and between CT, CI and other functions.

Issues advice, direction, and guidance in the appropriate form, including but not limited to legal advice memorandum; informal and formal technical advice; Legal Guidance Memorandum; IRM provisions; Chief Counsel Notices and Directive Manual provisions; and various other publications and handbooks on various issues such as money laundering, tax crimes, electronic surveillance, sentencing, and search warrants.

Reviews CI requests for use of special investigation techniques, including but not limited to proposed Grants of Immunity under 18 U.S.C. § 6001, et seq.; initial requests, deviations and extensions of Group I undercover operations as a member of the Undercover Advisory Committee; highly sensitive search warrants centralized in the National Headquarters; and non-consensual electronic surveillance.

Reviews requests for Code judicial forfeitures pursuant to IRC § 7301, et seq. and makes recommendations on forfeiture petitions for remission or mitigation or offers in compromise.

Responds to inquiries including, but not limited to, those from Congress; other governmental agencies; professional organizations and the public as well as FOIA requests.

Prepares Chief Counsel Advice for disclosure under IRC § 6110.

Coordinates between Department of Justice, other Chief Counsel/IRS functions and other Government agencies.

Disseminates Department of Justice declines.

In consultation with the Chief Counsel and the General Counsel, makes appellate and certiorari recommendations to Department of Justice.

Designs, coordinates, and conducts CT training, including Basic, Advanced, Symposium, and specialized schools.

Provides full time senior attorney(s) as instructors at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia.

Provides a Counsel liaison to multi-governmental agency task forces.

Implements and evaluates operational policies and procedures designed to improve the delivery of legal services.

Identifies and communicates emerging and significant issues.

Performs such other functions as may be prescribed from time to time by the Chief Counsel.

When assigned to National Headquarters, to serve as legal and technical consultants on the most difficult, important and complex matters arising in connection with the work of the Division, as well as less complex matters assigned at the discretion of the Division Counsel/Associate Chief Counsel (CT) or his or her Deputy. Special Counsel assist and represent the Division Counsel/Associate Chief Counsel (CT) at Chief Counsel, Internal Revenue, and Treasury conferences where policy is developed and determined.

When assigned to FLETC, to serve as the primary legal instructor and Chief Counsel representative on Criminal Investigation's teaching cadre at FLETC. The Special Counsel in this capacity exercise overall program and policy responsibility for the substantive criminal tax teaching provided at FLETC.

Acts for the Division Counsel/Associate Chief Counsel (CT) in the absence of the Division Counsel and Deputy Division Counsel. When acting in such capacity, the Assistant assumes complete responsibility for the activities of the Office of the Division Counsel/Associate Chief Counsel (CT).

Collaborates closely with the Division Counsel regarding any administrative issues under the jurisdiction of Criminal Tax. Specifically, the Assistant plans, directs, and coordinates the administrative and management policies and programs of the office, serving as liaison to the budgetary, information technology, and management committees of the Chief Counsel and the Commissioner.

Assists the Deputy Division Counsel/Associate Chief Counsel (CT) in the management and supervision of the Area Counsel (Criminal Tax). The Assistant conducts Area visitations, works with the Area Counsel relative to staffing issues and workload issues in their Areas, and other duties and responsibilities assigned by the Division Counsel/Associate Chief Counsel (CT) and his or her Deputy.

Serves as the appraising official of the Special Counsel assigned to the FLETC and the approving official of the docket attorney assigned to the FLETC. The Assistant works with the Special Counsel and Criminal Investigation personnel relative to the oversight of this program.

Supervises the attorneys in the Office of Division Counsel/Associate Chief Counsel in positions below GS-15. This responsibility includes, but is not limited to, assigning work, reviewing work products, and appraising the annual performance of the attorneys.

Serves as the appraising official of the Executive Assistant and the Management Analyst and the approving official of the Administrative Officer.

Develops and executes policies, procedures, and directives designed to manage the budgetary process for all aspects of the Criminal Tax function.

Develops, implements, and evaluates operational policies and procedures designed to improve the delivery of legal services.

Develops, implements and evaluates modernization policies and procedures for the Criminal Tax function.

Performs such other functions and duties as may be prescribed from time to time by the Division Counsel/Associate Chief Counsel (CT) and the Deputy Division Counsel/Associate Chief Counsel (CT) .

Plans, directs, and coordinates the legal work of the Criminal Tax function in the assigned geographic area.

Plans and implements actions, including periodic meetings, necessary to create and maintain strong communications within the assigned area and between other areas and the Office of Division Counsel/Associate Chief Counsel Associate.

Provides formal and informal legal advice and assistance in matters requiring the approval of the CI Area Manager.

Informs division attorneys and the CI Area Manager of developments in substantive and procedural matters.

Coordinates and participates in training of Counsel and CI personnel.

Periodically meets with the CI Area Manager to ensure that necessary legal services are being provided and to discuss areas for improvement.

Alerts the Division Counsel/Associate Chief Counsel (CT) to sensitive or unique matters in the area.

Makes recommendations to the Division Counsel/Associate Chief Counsel (CT) on emerging issues.

Supports the Division Counsel/Associate Chief Counsel (CT) in the design, coordination and conducting of criminal tax schools.

Supports the Division Counsel/Associate Chief Counsel (CT) in the preparation and updating of manual provisions, training materials, technical updates and other publications.

Coordinates between Department of Justice, other Chief Counsel and Service functions and other Government agencies.

Performs such other functions as may be prescribed from time to time by the Division Counsel/Associate Chief Counsel (CT).

Supervises the Special Litigation Assistants, division attorneys and technical assistants assigned to the Criminal Tax function in the Area and local offices.

Assigns, reassigns, and transfers Area Counsel (CT) and Division Counsel (CT) personnel under his or her jurisdiction among any of the Area's subordinate offices, as necessary.

Prepares evaluations and appraises the performance of subordinate personnel, taking personnel actions as necessary for those under his/her supervision.

Assigns and reviews work products, establishes work assignment priorities, monitors workload balances, and transfers work among docket attorneys to ensure a proper workload balance.

Ensures performance and program goals, strategy, and organizational policies are clearly communicated to employees.

Approves travel and travel vouchers and manages other assigned budgetary functions for the area.

Prepares and maintains records and reports with respect to the work of the CT function in the area.

Designates an Acting Area Counsel (CT) or other manager for the function for the temporary absence of the incumbent.

Redelegates his/her authority as necessary, except where such redelegation is expressly restricted or otherwise restricted by law, regulation, or policy.

Signs on behalf of the Chief Counsel by the use of the by-line or in his/her own name (whichever is appropriate) correspondence and other papers pertaining to the functions of Counsel and which are considered in the course of the official duties of the Area Counsel (CT).

Represents the Commissioner in the litigation of cases pending in the U.S. Tax Court.

Prepares enforcement, defense, and settlement letters in summons enforcement and refund litigation cases, and leading the coordination of these Department of Justice cases with other Counsel functions.

Makes recommendations of acquiescence and nonacquiescence in adverse decisions in litigation, providing on-going services to Department of Justice and coordinating with Associate Chief Counsels on recommendations to the Chief Counsel and Department of Justice regarding appeals of adverse decisions, rehearing and rehearing en banc, the filing of amicus curiae briefs, petitions for writ of certiorari to the U.S. Supreme Court, and any other appropriate judicial action pertaining to matters under the jurisdiction of LMSB.

Manages the Significant Case Program, which allows for coordination of significant cases approaching litigation, and docketed in the U.S. Tax Court and other federal courts.

Manages the Strategic Litigation Program, which includes a nationwide staff of Special Trial Attorneys and which provides the primary support for the litigation of significant cases in the Tax Court.

Provides pre-filing and post-filing legal advice to LMSB examination teams, either in the audit of returns or in the consideration of claims for refund.

Coordinates input from the LMSB Commissioner with the Deputy Chief Counsel (Technical), Associate Chief Counsels and Treasury officials with respect to the need for and the administrability of published guidance, including regulations, notices, revenue rulings, revenue procedures, actions on decision and other items of published guidance.

Coordinates key issues and cases with the Chief Counsel, Deputies Chief Counsel, Associate Chief Counsels, and other members of the Chief Counsel organization.

Oversees the Industry Counsel and International Field Counsel Programs, which are the counterparts to the Industry Technical Advisor and International Technical Advisor Programs in LMSB Pre-Filing and Technical Guidance.

Works in concert with the LMSB Office of Tax Shelter Analysis to identify and address abusive tax avoidance transactions.

Supports the Division Counsel (SB/SE) in bankruptcy matters.

Provides legal advice on Advance Pricing Agreements, Pre-filing Agreements and other closing agreements.

Provides internal and external training on issues.

Conducts public outreach to taxpayer organizations.

The Area Counsel for Financial Services (Area 1), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Financial Services.

The Area Counsel for Heavy Manufacturing and Transportation (Area 2), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Heavy Manufacturing and Transportation.

The Area Counsel for Retailers, Food, Pharmaceuticals and Health Care (Area 3), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Retailers, Food, Pharmaceuticals and Health Care.

The Area Counsel for Natural Resources (Area 4), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Natural Resources.

The Area Counsel for Communications, Technology and Media, (Area 5) who serves as the principal legal advisor to, and is collocated with, the Industry Director, Communications, Technology and Media.

Docketed Cases. To process and handle cases docketed in the Tax Court involving SB/SE or W&I taxpayers.

Statutory Notices. To perform the duties and functions relating to the consideration and review, prior to issuance, of proposed statutory notices of deficiency and statutory notices of claim disallowance prepared by SB/SE or W&I

Subpoenas. To approve on behalf of the Chief Counsel actions to be taken with respect to Tax Court subpoenas and disclosure of information in Tax Court litigation within the jurisdiction of the division.

Adverse Decisions. To make recommendations to the Chief Counsel respecting adverse Tax Court decisions within the jurisdiction of the division.

Cases in the Tax Court. To dispose of Tax Court cases within the jurisdiction of the division by trial, settlement, or dispositive motion.

Refund Matters. To authorize or sanction counterclaims, third-party complaints, or the commencement of collection suits with respect to refunds suits of taxpayers within the jurisdiction of SB/SE or W&I pending in the district courts or the Court of Federal Claims and to perform necessary legal services on behalf of the Service as directed in connection with taxpayer suits for refund of taxes.

Legal Advice and Opinions. Upon request, to furnish collection advice and opinions to SB/SE personnel or other functions of the Service responsible for collection matters in any matter (court and noncourt).

Actions. To advise SB/SE Field personnel, handle the legal work, and assist US Attorneys in cases involving:

Bankruptcy Matters. To handle legal work pertaining to the collection and protection of tax claims and liens of the United States in proceedings under the bankruptcy law, including Special Assistant United States Attorney (SAUSA) work.

Bankruptcy Plans. To accept or reject plans where the United States is a creditor or equity security holder, including municipal debt adjustment plans, reorganization plans, and railroad reorganization plans (11 U.S.C. §§ 901(a) and 1126(a)). This covers proceedings where the United States possesses solely an IRS claim (a Treasury claim), as well as proceedings in which there are other claims of the United States in addition to the claim of the IRS. A non-Treasury claim of the United States includes any department, agency, federally chartered corporation, or instrumentality of the United States. To the extent that an agreement cannot be reached between the Chief Counsel, IRS, and the holder of a non-Treasury claim of the United States, the matter will be referred to the General Counsel of the Treasury for resolution.

Suits. To determine what civil actions shall be brought by the Government in connection with the collection with the collection of internal revenue taxes and to authorize or sanction commencement of such actions.

Offers-in-Compromise. To review and dispose of offers-in-compromise.

Leases, Bonds, and Escrow Agreements. To handle legal matters arising within the regions with respect to leases, bonds, escrow agreements, and other similar matters relating to the collection of taxes.

Appeals. To make recommendations to the Chief Counsel respecting appeals of court decisions in general litigation matters.

Disclosure of Information. To assist, when called upon, Service field personnel in matters involving the disclosure of information. The Office of Assistant Chief Counsel (Disclosure & Privacy Law), however, retains primary responsibility for disclosure matters.

Jeopardy and Termination Assessments and Jeopardy Levies. To approve in writing the making of jeopardy and termination assessments and jeopardy levies. This authority may be redelegated no lower than Associate Area Counsel.

Summons Matters. To review, upon request, proposed summonses, and to recommend enforcement or defense in summons litigation matters, involving SB/SE & W&I taxpayers.

Writs of Entry. To review, upon request, proposed writs of entry, and to recommend the filing of motions to obtain writs of entry in collection matters.

Writs Ne Exeat. To review, upon request, and to recommend the filing of writs ne exeat in collection matters.