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 (PDF) for the latest coordinator contact information. Abusive Tax Avoidance Transactions Business Directory for Visually impaired PDF Deductions for Contributions to 401(k) or Defined Contribution Plans during Grace Period, Related Change of Accounting Adjustments, and Penalties; PDF Domestic Abusive Trust Schemes PDF Home Based Business Promotions PDF IRC Section 302/318 Basis Shifting Transactions PDF IRC Section 351/Contingent Liability PDF IRC Section 44 Disabled Access Credit Tax Avoidance Schemes Intermediary Transaction Tax Shelters and Penalties PDF Internet Shopping Portal PDF 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 2002-21 PDF Transaction involving the use of a Loan Assumption agreement to claim an inflated basis in assets acquired from another party Notice 2002-35 PDFInvolves 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 PDF 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 PDF PDFIRC 461(f) Contested Liabilities Transactions Preparer/Promoter Penalties Sale in, lease out (SILO) PDF Telecommunication System for Hearing Impaired PDF Air Transportation Federal Income Tax Withholding on Compensation Paid to Nonresident Alien Crew by a Foreign Transportation Entity PDF Cafeteria Plans Heath Insurance Deductibility for Self-employed Individuals PDF 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 Contract PDF Employment Tax Medical Resident FICA Refund Claims Environmental IRC 1341 Environmental Remediation Costs Excise Tax Virtual Private Networks Food Industry Charitable Contributions of Surplus Food PDF Package Design Cost PDF Forest Products Losses of Timber form Southern Pine Beetle PDF Logging Truck Roads PDF Fuel from a Nonconventional Source (FNS) Methane Gas Project (IRC § 29 Credit), Credit for FNS PDF Gaming The Applicable Recovery Period Under IRC 168(a) for Slot Machines, Video Lottery Terminals and Gaming Furniture, Fixtures and Equipment PDF 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. § 118 PDF Insurance – Life IRC 807 Basis Adjustment – Change in Basis vs. Correction of Error PDF Loss Utilization in a Life-nonlife Consolidated Return Separate v. Single Entity Approach PDF Intangibles Amortization of Employment Contracts PDF Covenants Not to Compete PDF 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 Inventory PDF Dollar Value LIFO: Bargain Purchase Inventory PDF Dollar-value LIFO: Earliest Acquisition Method PDF Leasing Promotions Lease Stripping Transactions PDF Losses Reported from Inflated Basis Assets from Lease Stripping Transactions PDF Intermediary Transactions Tax Shelters PDF 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 Benefits PDF Mining Strike Costs Excess Moisture PDF Receding Face Deduction PDF The Effect of Costs Incurred During a Strike on the Percentage of Depletion Computation PDF Motor Vehicle New Qualified Plug-in Electric Drive PDF Dollar-Value LIFO - Definition of an Item PDF Remanufacturers' Inventory of Cores PDF Excess Parts Inventory PDF Notional Principal Contracts Notional Principal Contracts (Contingent Deferred Swaps) PDF Partnerships Subchapter K Anti-abuse Regulation 1.701-2 PDF Petroleum Capitalization of Delay Rentals PDF Cost Depletion Recoverable Reserves PDF North Sea IDC Transition Rule PDF Pharmaceutical Medicaid Rebates PDF Research and Experimentation Expenditures (Reg. 1.861-17(a)(4) Research Credit Extraordinary Expenditures for Utilities PDF R&E Credit - Self-Constructed Supplies PDF Qualifying Wages Under Section 41 in Determining the Tax Credit or Increasing Research Activities PDF Wages of Technical Writers and the Research Credit PDF Retail ACRS and ITC for Suspended Ceilings PDF Contributions to 401(k) Plans Attributable to Compensation Paid After Year End Under 401(a)(6); Tenant's Rent Leveling IRC 467 Lease Agreements Valuation of an Acquired Retailer's Inventory PDF S Corporations Shifting of Income to Tax Exempt Organization (SC2) PDF Savings and Loans Supervisory Goodwill PDF Accrual of Interest on Non Performing Loans (see Banking) PDF Validity of Regulations Sec. 1.593-6A(b)(5)(vi) Supervisory Goodwill PDF Securities & Financial Services Transfer or Sale of Compensatory Options or Restricted Stock to Related Persons- Notice 2003-47 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 Franchise PDF State Refundable Credits New York State, Qualified Empire Zone, Enterprise Credit, Real Property Taxes PDF Telecommunications Taxation of Universal Service Fees PDF Utilities Investment Credit Transition Property Membership Payments Made to Industry-created Research Organizations
