 |
5.1.17.1
(05-20-2008)
General Information
-
The provisions of IRC §6103 and corresponding regulations apply to all third-party contacts.
-
For third-party contacts made for the purpose of collecting or determining a tax liability, IRC §7602(c) requires the IRS
to:
-
Provide advance notice to the taxpayer that third-party contacts may be made,
-
Periodically provide a list of all third-party contacts to the taxpayer, and
-
Provide a list of third-party contacts to the taxpayer upon request.
Note:
Any tax period under investigation by Criminal Investigation (CI) is not subject to the requirements of IRC §7602(c). A criminal
investigation is initiated when an administrative referral based on a firm indication of fraud is made to CI. Third-party
contacts to develop the referral are contacts under IRC §7602(c).
|
|
|
