Information For...

For you and your family
Individuals abroad and more
EINs and other information

Filing For Individuals

Information For...

For you and your family
Standard mileage and other information

Forms and Instructions

Individual Tax Return
Request for Taxpayer Identification Number (TIN) and Certification
Single and Joint Filers With No Dependents
Employee's Withholding Allowance Certificate

 

Request for Transcript of Tax Returns
Employer's Quarterly Federal Tax Return
Installment Agreement Request
Wage and Tax Statement

Popular For Tax Pros

Amend/Fix Return
Apply for Power of Attorney
Apply for an ITIN
Rules Governing Practice before IRS

Resolution of SC2 Transaction

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

Internal Revenue Service
Large and Mid-Size Business Division             April 6, 2005

MEMORANDUM FOR    LMSB Leadership Team
                                          SBSE Leadership Team

FROM:                              Bobby E. Scott 
                                          Industry Director, Natural Resources and Construction

SUBJECT: Resolution of SC² Transaction

There will be no formal settlement initiative offer on the S Corporation Tax Shelter issue (or SC² transaction) described in Notice 2004-30. However, taxpayers will be offered an opportunity to resolve their cases based on the examiner's use of Delegation Order 4-25 and the Appeals Stated Position. Taxpayers will be allowed 30 days from the date of the offering letter to accept the offer. Taxpayers who do not resolve these issues should not expect a more favorable resolution in Appeals.

Please ensure that all agents and other personnel take appropriate action to offer all taxpayer's who engaged in this transaction an opportunity to resolve their issues based on Delegation Order 4-25 and the Appeals Stated Position. All examiners have been contacted by the SC² Issue Management Team and provided with instructions for issuance of the offering letter to the taxpayers. For those taxpayers who do not accept the offer, the agents should continue to work these issues expeditiously.