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25.1.4.5
(01-01-2003)
Special Conditions of Probation
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The Court may order probation for the taxpayer
as part of the sentence imposed. The order of probation may contain special
conditions relating to the settlement and/or payment of civil tax liability
and penalties. The SAC will notify the field territory manager of the special
probation requirements.
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Cl will update Transaction Code(s) 914 to TC 910.
The TC 910 will not be released until the special conditions of probation
have been satisfied or the conditions are terminated by the Court.
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The field territory manager will inform the SAC
of the status of the case by the earliest of the following dates:
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When the case is disposed of by the compliance function;
or
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180 days prior to expiration of the probationary
period specified.
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The memorandum will include information relative
to the taxpayer’s cooperation and should indicate any unwarranted actions.
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The SAC will recommend legal action if the taxpayer
fails to comply with the conditions of probation.
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IRC 6103(h)(4) allows for disclosure of returns
and return information to a U.S. probation officer under the following circumstances:
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The returns and return information must relate to
a taxpayer convicted of a criminal tax violation,
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The U.S. Probation Officer must have the responsibility
of determining compliance with the tax related conditions of probation,
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The returns and return information are limited to
those years specified in the conditions of probation, and
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The disclosure would not identify a confidential
informant or seriously impair a civil or criminal tax investigation.
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Any disclosure to a U.S. Probation Officer must
be coordinated with the area disclosure officer.
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