Appeals Settlement Guidelines (ASG)

 

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 Index (PDF) for the latest coordinator contact information.

Abusive Tax Avoidance Transactions

Air Transportation

Cafeteria Plans

COLI (Corporate Owned Life Insurance)

Commercial Banking

Construction/Real Estate

Employment Tax

  • Medical Resident FICA Refund Claims

Environmental

  • IRC 1341 Environmental Remediation Costs

Excise Tax

  • Virtual Private Networks

Food Industry

Forest Products

Fuel from a Nonconventional Source (FNS)

Gaming

I.R.C. § 118 SALT

Insurance – Life

Intangibles

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

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.

Maquiladora

Media/Communications

  • Investment Tax Credit - Transition Property

Military

Mining

Motor Vehicle

Notional Principal Contracts

Partnerships

Petroleum

Pharmaceutical

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

Research Credit

Retail

S Corporations

Savings and Loans

Securities & Financial Services

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

Shipping

Sports Franchises

State Refundable Credits

Telecommunications

Utilities

  • Investment Credit Transition Property
  • Membership Payments Made to Industry-created Research Organizations