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Exhibit 8.7.3-5
(11-06-2008) Memo Template for Appeals Emerging Issues
[The identifying number is added to the memo after it has been signed by the Director, Technical Services, and has become
final.]
MEMORANDUM FOR
DIRECTOR, FIELD OPERATIONS-EAST
DIRECTOR, FIELD OPERATIONS-WEST
FROM:
NAME
Director, Technical Services
SUBJECT:
Appeals Emerging Issue Designation Name of Issue [and Related Penalties (show only if Applicable)] Name of Issue [and Related Penalties (show only if Applicable)] UIL ERCS Tracking or Project Code (show only if applicable)
I have designated the above issue as an Appeals Emerging Issue effective with the date of this memorandum. In accordance with
IRM 1.4.28.9 and IRM 8.2.1.6(2), Appeals Officers (AOs) and Appeals Team Case Leaders (ATCLs) who have this issue must make
a referral to Appeals Technical Guidance through their manager upon assignment or preliminary review using Form 13381, available
on ACDS. If the form is not available on ACDS, Form 13381 on the Appeals web site may be used: http://appeals.web.irs.gov/lbsp/default.htm.
NAME is the Technical Guidance Coordinator for this issue. AOs and ATCLs should contact FIRST NAME at (NNN) NNN-NNNN to obtain
the most current information and should maintain contact throughout consideration to keep him/her apprised of the case status,
settlement negotiations, and outcome. Since Coordinators may change, it is recommended that AOs and ATCLs refer to the website
(above) for updates.
Third paragraph should contain:
• Brief description of the nature of issues involved and, if a shelter, how it’s abusive • Code sections involved (for reference purposes) • Whether or not the issues are factual, legal, or both • Penalties, if applicable • Avoid any reference to a specific taxpayer or group of taxpayers that might constitute disclosure
When an AO/ATCL identifies an emerging issue in a case, the Feature Code EM will be added to the keycase workunit record.
Either Appeals Processing Services or the AO/ATCL may update ACDS for the Feature Code. [Additional coding may be required
for tracking purposes and should be set forth in the memo as appropriate.]
Tracking of these issues in CIRS is not required. If you have any questions, please call NAME, Director, Technical Guidance
at (NNN) NNN-NNNN.
(Client’s IRS tax debt of $22,000 was settled for $2,900 payable over 24 months at NO interest)
I wanted to take this opportunity to thank you and your staff for helping me with my tax issues. Your assistance has removed the considerable stress associated with trying to communicate reasonable with the IRS.
As you know, I had accrued more than $22,000 in back taxes, interest and penalties. My health was deteriorating and my ability to work was limited. To believe there was a way, or even someone to help with this problem was waning away. I read about your services and quickly contacted your office. Your staff immediately went out of there way to answer my questions and make me feel as ease. Your call to me was reassuring that I had an opportunity to negotiate a reasonable settlement and stop the constant threat of financial ruin.
I especially want to commend Mr. Smith of your office for his understanding and commitment. He was very precise about the efforts ahead and willing to explain and answer any questions in the day-to-day activities of your process.
I would strongly recommend your services to anyone needing help with tax or other issues relating to the IRS. Please do not hesitate to use me as a reference.
