IRS Delegation Orders Applicable to Appeals Function Authority

Exhibit 8.1.1-2  (10-23-2007)
Delegation Orders Applicable to Appeals Function Authority

Delegation Order Subject
4-8* Authority to Issue or Execute Agreement to Rescind Notices of Deficiency
4-19* Authority to Sign the Notice to Partners and Shareholders of the Beginning of an Administrative Proceeding at the Partnership or S Corporation Level With Respect to Partnership and Subchapter S Items
5-1* Authority to Accept, Reject, Return, Terminate or Acknowledge Withdrawals of Offers in Compromise
  8* Authority To Sign Agreements as to Liability for Personal Holding Company Tax
8-2* Appeals Review of Penalty Cases
8-5* Authority to Decide Appeals of Participation Denial and Sanctions in the Internal Revenue Service e-file Program
11-2* Authority to Permit Disclosure of Tax Information and to Permit Testimony or the Production of Documents
 14* Granting Extension of Time for Filing Statements in Accordance with 26 CFR 1.534–2
 35* Agreements as Determinations under Section 1313(a)(4) of the Internal Revenue Code of 1954
 42* Authority to Execute Consents Fixing the Period of Limitations on Assessment or Collection Under Provisions of the 1939 and 1954, and 1986 Internal Revenue Codes
 60* 26 CFR 601.106: Appeals Functions. Settlement of Cases Docketed in the United States Tax Court
 66* Authority of Appeals in Protested and Tax Court Cases
 93* Authority to Consent to a Redetermination of Aggregations by a Taxpayer in the Case of Invalid Basic Aggregations or Invalid Additions
 97* Closing Agreements Concerning Internal Revenue Tax Liability
107* Authority to Determine that Certain "Savings Institutions" do not intend to Avoid Taxes by Paying Dividends or Interest for Periods Representing More than 12 Months
112* Authority to Issue Determination and Revocation Letters, to Allow Amendment of Employee Plans After the Expiration of the Remedial Amendment Period and to Issue Examination Reports Relating to Employee Plans
113* Authority to Issue Exempt Organization Determination Letters
136* Authority to Sign Agreements Under Rev. Proc. 74-6 with Respect to Exercise by Trustee of Administrative and Investment Powers
139* Authority to Extend the Correction Period and the Allowable Distribution Period Relating to Private Foundation and Employee Plans Matters
160* Authority of Appeals in Termination of Income Tax and Jeopardy Assessments
171* Authority of Appeals Under 26 CFR 301.6511 and 26 CFR 301.6532
179* Coordination of Certain Issues Before Approval of Settlement or Other Disposition in Appeals
231* Authority to Abate Interest on Erroneous Refunds under IRC 6404(e)(2)
* As revised and updated.

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