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5.1.30.1
(09-21-2007)
Introduction
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The purpose of this chapter is to communicate the principles of a strategic approach to casework and how those principles
can be applied directly to the actions revenue officers take to resolve cases. A strategic approach encompasses looking at
the overall case and devising a strategy that will generate compliance and resolve balance due accounts or unfiled returns.
The strategy developed will take into account the different aspects of the case. The factors that will influence the strategy
developed include:
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Size of the liability
The amount of time and depth of the investigation needs to be in accordance with the compliance impact and the amount of the
liability.
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Complexity of the case
The strategy needs to encompass all aspects of the case and will be more detailed when multiple entities are involved.
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Type of liability and entity
Trust fund taxes of a corporation may involve different contacts and sources of information than an income tax liability of
an individual.
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Compliance history
Taxpayers who have not been able to stay in compliance for several years or quarters may require a different approach to resolve
the case. Different actions may be necessary when working with a taxpayer that is not making current Federal Tax Deposits
(FTD) compared to a taxpayer that is current with FTDs.
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Cooperation level of the taxpayer
Taxpayers that provide full financial disclosure will require different steps to reach resolution than taxpayers that refuse
to provide a listing of all assets and liabilities.
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Results of financial analysis
The steps necessary to resolve the account will be driven by the results of the financial analysis.
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Type of business activity in which the taxpayer is engaged
The contacts and methods needed to resolve a case need to be geared to the type of business activity of the taxpayer. By understanding
the business activity, unique sources of income or information can be identified.
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These factors will influence other aspects of the case investigation. They need to be considered when deciding the amount
of research needed before initial contact and the depth of the financial investigation required for locating and verifying
asset information.
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While the strategy developed will be unique for each case, all existing IRM requirements must still be followed and this section
does not replace any IRM procedures. Developing a strategic approach to a case involves more than taking an action, but rather
incorporates a plan that determines why that action is the best choice to take at a given time. It involves anticipating potential
problems and taking actions that will help avoid those problems. It involves weighing the different options available and
selecting the one(s) that will produce the desired results for each individual case.
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The timing and coordination of actions are part of the overall case strategy that is developed. Often the strategy will include
taking simultaneous case actions to maximize the benefits of the actions. The process of adopting a strategic approach to
casework involves not only selecting the proper actions, but includes avoiding actions that can be time consuming or that
produce minimal results. Duplicating actions that were unsuccessful in moving a case forward, including actions taken by Automated
Collection System (ACS) or a prior revenue officer, are steps the revenue officer should avoid unless there are indications
they will now be more effective. The strategic approach to casework differs from the plan of action in that it encompasses
the analysis and decision making that takes place in formulating a plan of action. Applying a strategic approach involves
analyzing the case information and using that information to develop a comprehensive case strategy that focuses on case resolution.
This will result in an action plan that can be expected to produce the most effective results.
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In order to develop the strategy there will be times where you will have to place yourself in the shoes of the account you
are working. If you are working a business account you will need to consider the types of expenses and income sources related
to that business activity. If you are looking for information on a particular business or asset, you will have to consider
how and where the asset is used and the expenses associated with that business or asset. This will help locate information
and assets that can be used to resolve an account.
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The balance of this IRM section consists of strategy templates based on the type of case assigned to the revenue officer.
While not all inclusive, the templates are intended to assist the revenue officer in developing the best strategy to apply
in different types of case assignments.
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