An Appeals Coordinated Issue is an issue with IRS-wide impact or importance, requiring coordination to ensure uniformity and consistency nationwide. Appeals’ Technical Guidance Coordinators (TGCs) serve as the focal point for activities involving these issues by providing advice, guidance, and assistance to other Appeals employees in resolving taxpayer disputes. In some instances, Appeals Settlement Guidelines are prepared and represent Appeals’ position regarding the potential hazards of litigation for proper resolution of an Appeals Coordinated Issue by providing guidance to ensure consistent treatment of the issue. A list of published ASGs can be found below. NOTE: Coordinators may have changed since settlement guidelines were published. Please refer to the Technical Guidance - International IndexPDF for the latest coordinator contact information. Abusive Tax Avoidance Transactions Business Directory for Visually impairedPDF Domestic Abusive Trust SchemesPDF Home Based Business PromotionsPDF IRC Section 302/318 Basis Shifting TransactionsPDF IRC Section 351/Contingent LiabilityPDF IRC Section 44 Disabled Access Credit Tax Avoidance Schemes Internet Shopping PortalPDF Lease in, lease out (LILO)PDF 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 2002-21PDF Transaction involving the use of a Loan Assumption agreement to claim an inflated basis in assets acquired from another party Notice 2002-35PDF 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 2003-77PDF IRC 461(f) Contested Liabilities Transactions Preparer/Promoter Penalties Telecommunication System for Hearing ImpairedPDF Air Transportation Federal Income Tax Withholding on Compensation Paid to Nonresident Alien Crew by a Foreign Transportation EntityPDF Cafeteria Plans Heath Insurance Deductibility for Self-employed IndividualsPDF COLI (Corporate Owned Life Insurance) Commercial Banking Accrual of interest on non-performing loans (see Banking - Savings and Loan)PDF Foreign Withholding Taxes (Cross Border Loans)PDF Interchange Merchant Discount Fee Construction/Real Estate Claim Revenue Under a Long-term ContractPDF Employment Tax Medical Resident FICA Refund Claims Environmental IRC 1341 Environmental Remediation Costs Excise Tax Virtual Private Networks Food Industry Charitable Contributions of Surplus FoodPDF Package Design CostPDF Forest Products Losses of Timber form Southern Pine BeetlePDF Logging Truck RoadsPDF Fuel from a Nonconventional Source (FNS) Methane Gas Project (IRC § 29 Credit), Credit for FNSPDF Gaming The Applicable Recovery Period Under IRC 168(a) for Slot Machines, Video Lottery Terminals and Gaming Furniture, Fixtures and EquipmentPDF Class Life of Floating Gaming Facilities I.R.C. § 118 SALT State and Local Location Tax Incentives (I.R.C. § 118 SALT)PDF Exclusion of Income: Non-Corporate Entities and Contributions to Capital, I.R.C. § 118PDF Insurance – Life IRC 807 Basis Adjustment – Change in Basis vs. Correction of ErrorPDF Loss Utilization in a Life-nonlife Consolidated Return Separate v. Single Entity ApproachPDF Intangibles Amortization of Employment ContractsPDF Covenants Not to CompetePDF Interest Computations Net Rate Interest Netting - Requirement that Both Statutes be Open for Pre-98 Act Years Overpaid Estimated Taxes International Foreign Sales Corporations (FSC) Advance Payment Transactions Inventory Dollar Value LIFO: Segments of InventoryPDF Dollar Value LIFO: Bargain Purchase InventoryPDF Dollar-value LIFO: Earliest Acquisition MethodPDF Leasing Promotions Lease Stripping TransactionsPDF Losses Reported from Inflated Basis Assets from Lease Stripping TransactionsPDF 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. Maquiladora IRC Section 1504(d) Election IRC Section 168(g)PDF Media/Communications Investment Tax Credit - Transition Property Military Military Disability Retirement BenefitsPDF Mining Strike Costs Excess MoisturePDF Receding Face DeductionPDF The Effect of Costs Incurred During a Strike on the Percentage of Depletion ComputationPDF Motor Vehicle Dollar-Value LIFO - Definition of an ItemPDF Remanufacturers' Inventory of CoresPDF Excess Parts InventoryPDF Notional Principal Contracts Notional Principal Contracts (Contingent Deferred Swaps)PDF Partnerships Subchapter K Anti-abuse Regulation 1.701-2PDF Petroleum Capitalization of Delay RentalsPDF North Sea IDC Transition RulePDF Pharmaceutical Medicaid RebatesPDF Research and Experimentation Expenditures (Reg. 1.861-17(a)(4) Research Credit Extraordinary Expenditures for UtilitiesPDF R&E Credit - Self-Constructed SuppliesPDF Qualifying Wages Under Section 41 in Determining the Tax Credit or Increasing Research ActivitiesPDF Wages of Technical Writers and the Research Credit PDF Retail Tenant's Rent Leveling IRC 467 Lease Agreements Valuation of an Acquired Retailer's InventoryPDF Savings and Loans Supervisory GoodwillPDF Accrual of Interest on Non Performing Loans (see Banking)PDF Validity of Regulations Sec. 1.593-6A(b)(5)(vi) Shipping Federal Income Tax Witholding on Conpensation Paid to Nonresident Alien Crew by a Foreign Transportation Entity (See Air Transportation)PDF Income Tax Withholding on Wages Paid to U.S. Crew Sports Franchises Media Rights Acquired in Connection with a Sports FranchisePDF Telecommunications Taxation of Universal Service FeesPDF Utilities Investment Credit Transition Property Membership Payments Made to Industry-created Research Organizations
