To serve as liaison to the staffs of the General Counsel and the Commissioner as to matters identified in the previous paragraph

To plan, direct, and coordinate the administrative and management policies and programs of the Office

To participate in the formulation of tax litigation policy

To serve as liaison to the staffs of the General Counsel and the Commissioner as to matters identified in the previous paragraph

To participate in the interpretation and development of internal revenue laws

The discharge of attorney personnel for conduct violations of the standards described in CCDM 39.1.1.2.2.1, Standards Applicable to All Office of Chief Counsel Employees, requires the prior approval of the Deputy Chief Counsel (Operations) or the Associate Chief Counsel (Finance & Management).

Concurrence is required for a nondischarge action on a GS-15 employee by the Deputy Chief Counsel (Operations) or the Associate Chief Counsel (F&M).

All disciplinary or adverse action shall be taken only after consulting and receiving guidance from the Office of Associate Chief Counsel (F&M), Labor and Employee Relations Division.

A copy of documents effecting disciplinary or adverse actions against employees at GS-14 and below that do not require prior approval or concurrence must be provided to the Associate Chief Counsel (F&M).

To administer the oath of office or any other oath required by law in connection with employment in the Federal service.

Except when doing so would change the basic rate of pay, to prescribe the official hours of duty for his or her function and, when necessitated by operating requirements, to establish an administrative workweek of five 8-hour days other than Monday through Friday for individual employees or groups of employees whose services are required on Saturday or Sunday or both, and to establish tours of duty for educational purposes. The exercise of authority to change tours of duty for employees must be in compliance with statute, regulation, and any applicable Treasury Department policy. See 5 U.S.C. § 6101.

To approve leave (including approval of the correction of administrative errors and determination that a period of sickness or injury interfered with the use of scheduled annual leave), charge absence without leave for unauthorized absences, authorize brief absences from duty without charge to leave or loss of pay, for individual employees under their supervision and control in accordance with applicable statutes, executive orders, regulations and policies.

To order or approve the performance of overtime duty for all employees under his or her supervision for which compensatory time off shall be provided for incumbents of exempt positions under the Fair Labor Standards and for which overtime pay shall be provided for incumbents of nonexempt positions under the Fair Labor Standards (provided funds are available for such duty). Non-exempt employees may also elect to receive compensatory time off for overtime worked.

To order or approve the performance of work on holidays for all employees under his or her supervision provided funds are available for such duty.

To sign in their own names pocket commissions to be issued to attorneys under his or her supervision.

To direct official travel and approve advances and travel vouchers for reimbursement of expenses, including non-workday travel, under the Federal Travel Regulation and Treasury and Service travel and relocation guidance, which is redelegated through Division Counsel and Associates Chief Counsel to the supervisory level for official domestic travel. No employee of the Office of Chief Counsel may approve his or her own travel or his or her own travel voucher or otherwise approve the use of travel authorities as applied to him or her.

To authorize reimbursement for subsistence on an actual expense basis under circumstances and conditions permitted by the Federal Travel Regulation and Service travel and relocation guidance, which is redelegated to Deputies Associate Chief Counsel and Area Counsel;

To authorize or approve the use of cash to procure emergency passenger transportation services, which may be redelegated in writing to Deputies Associates Chief Counsel and Area Counsel.

To authorize travel and transportation payment for emergency purposes under the Federal Travel Regulation and Service travel and relocation guidance, which is redelegated to Area Counsel.

This authority may be redelegated to the docket attorney level.

Except as specifically and expressly limited, the authority vested in the Division Counsel to sign in their own names may be redelegated to the docket attorney level. Area Counsel offices are to use Area Counsel stationery in order to clarify the authority and appearance of the Area Counsel in dealing with the public. As a national organization, Strategic Litigation groups are to use Division Counsel (Strategic Litigation) stationery. The use of by-lines should correspond to the letterhead.

To serve as the principal liaison officer for the Chief Counsel with congressional committees, the Department of the Treasury, the Commissioner's Office, the Department of Justice, and other departments and agencies of the Government on matters or cases within his or her delegated jurisdiction.

To coordinate the work of his or her function with the other functions of the Office and the Service and to dispose of all matters under his or her jurisdiction, referring to the Chief Counsel, a Deputy Chief Counsel, or other appropriate official of the Office of Chief Counsel such matters as in his or her discretion seem proper, or as directed.

To supervise, assign work, review the work product, and appraise the performances of the personnel of the function, wherever located.

To plan, direct, and supervise the operations of their respective function.

To establish, subject to the approval of the Chief Counsel and the General Counsel, branches, sections or other units or offices within the function, and to recommend further necessary changes in the organizational structure of the function or of the Office to the Chief Counsel, with reference to changes in the organizational structure of the Service or other components of the Office.

To make recommendations with respect to the number of employees necessary for the performance of the work under their jurisdiction.

To prepare and maintain records and reports with respect to the work of the function.

To designate an acting official of the function (or of a subordinate function), during the temporary absence of an incumbent. The authority to designate an acting official for a position held by an official in the Senior Executive Service may only be delegated to officials reporting directly to the official holding the position or to his or her Deputy.

Developing and executing policies, procedures, and directives designed to manage the budget process of all aspects of office operations;

Developing and monitoring performance measures and program goals for: the provision of legal services, litigation, and published guidance, and the implementation, compliance, and outreach initiatives within his/her jurisdiction;

Implementing and evaluating operational policies and procedures designed to improve the delivery of legal services;

Ensuring that performance and program goals, strategy, and organizational policies are clearly communicated to employees; and

Identifying emerging issues in the topical areas and litigation matters within its jurisdiction to improve delivery of legal services.

To plan, direct, and coordinate the policies and programs with respect to legislation, regulations, interpretation of rulings and opinions pertaining to the laws administered by the Service for which the Associate has subject matter jurisdiction.

For matters under his or her subject matter jurisdiction, to determine whether an action on decision should be prepared and to prepare such document for the signature of the Chief Counsel, after considering any memorandum from Division Counsel recommending an action on decision.

For matters under his or her subject matter jurisdiction, to review decisions, make recommendations for appeal, write settlement letters, and write letters recommending appeal for signature by the Chief Counsel, after considering and describing in the transmittal to the Chief Counsel any memorandum of Division Counsel making recommendation on such matters.

For matters under his or her jurisdiction, to review prior to filing documents prepared by Division Counsel listed below:

To represent the Service at motions sessions before the U.S. Tax Court, except in those cases where Division Counsel sends attorneys to argue their motions.

For matters under his or her subject matter jurisdiction, to prepare or review motions for reconsideration of Tax Court opinions for the approval of the Chief Counsel.

For matters under his or her subject matter jurisdiction, to prepare action memorandums on whether to seek certiorari, including the preparation of letters recommending certiorari for signature by the Chief Counsel and approval by the General Counsel.

For matters under their jurisdiction, to enter into and approve a written agreement with any person relating to the internal revenue tax liability of such person (or of the person or estate for whom he/she acts): (1) in respect to any prospective or completed transactions if the request to the Chief Counsel for determination or ruling was made before any affected returns have been filed; and (2) for a taxable period or periods ended prior to the date of agreement and related specific items affecting other taxable periods.

To prescribe the extent, if any, to which any technical advice memorandum or other legal guidance issued under his/her jurisdiction shall be applied without retroactive effect. The same authority is delegated to the Deputies Associate Chief Counsel. See Delegation Order 30-1 , Application of Rulings without Retroactive Effect (IRM 1.2.53.2).

To approve for the Chief Counsel announcements pertaining to civil litigation policy as it pertains to tax litigation matters under his/her jurisdiction.

Furnishes, upon request, information, advice, and assistance in the development and drafting of internal revenue legislation and committee reports thereon; initiates recommendations and coordinates with Legislative Affairs in providing advice and assistance on legislative matters; prepares, upon request, memoranda or reports to the Associate General Counsel (Legislation, Litigation, and Regulation) setting forth the views of the Office of Chief Counsel on proposed or pending legislation.

Works with Treasury officials with respect to, and directs the drafting and development of, regulations and Treasury Decisions, assesses public comments and conducts public hearings on proposed regulations, and manages the movement of regulations through the review process within the Service and the Department of the Treasury.

Prepares revenue rulings, revenue procedures, announcements, notices, and news releases to be published for the guidance of taxpayers and Service personnel.

Assists the Operating Divisions in setting strategic goals, policy and procedure by providing input in the areas within the Associate's jurisdiction and working with Division Counsel and other Counsel offices to ensure the correct application of law.

Coordinates the Service's position in litigation with Division Counsel, the Service, and Department of Justice in areas within the Associate's jurisdiction in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. Makes appeal and settlement recommendations and prepares other documents setting forth the Service's position in such cases.

Coordinates the resolution of cases and other matters where the subject matter is within the jurisdiction of the Associate's office. Works with the Service, Operating Divisions, Division Counsel, Taxpayer Advocate, and other components of the Service, as appropriate.

Provides administrative and technical support to Division Counsel and other Associates Chief Counsel in the handling and processing of litigation pending in the U.S. Tax Court and other federal courts. Reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with U.S. Tax Court litigation. Processes or coordinates, as appropriate, petitions and complaints, briefs, actions on decision, and other matters with Division Counsel and other Associates.

Works with Division Counsel in: advising Department of Justice as to the facts and legal positions of the Service in matters within the jurisdiction of the Associate's office; preparing recommendations concerning defense, offers in compromise, settlement, appeal, or certiorari; and coordinating other matters with the Department as required.

Develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memorandums and CCDM provisions to provide uniform application of the provisions within the Associate's jurisdiction to the Office of Chief Counsel. Provides support and guidance in connection with the development of IRM provisions.

Issues technical advice or other legal advice or determinations responding to questions raised by Service personnel.

Issues letter rulings and general technical information letters in response to requests from taxpayers.

Reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

To direct, supervise, and evaluate the work of the heads of Counsel-wide finance and management activities: Human Resources, Strategic Planning, Finance, Labor and Employee Relations, Business Systems, Library services, and field support operations.

To be responsible for the general administration and management of the Office of Chief Counsel nationally, and to prepare and issue appropriate orders, instructions, and directives pertaining to management and administrative matters for guidance and planning of the Office.

To serve as the Financial Plan Manager for the Office of Chief Counsel, and to plan, direct and coordinate the financial management and administrative policies and programs of the Office, including all personnel-fiscal and budgetary operations.

To direct the management of the field non-legal support operations, including all administrative and clerical personnel who provide support to field functions; to supervise and manage, and delegate the authority to supervise and manage (both to supervisors within the Office of the Associate Chief Counsel (F&M) and other Counsel supervisors) all field Counsel employees who are not attorneys, paralegals, or technical advisors; and to perform, and to delegate the authority to perform all of the administrative functions necessary for the support operation of the field offices.

To serve as the project manager for Counsel's national automation initiative, the Counsel Automated Systems Environment (CASE-MIS), and to be responsible for the viability and continued progress of the Counsel information systems program, which is administered by the IRS Chief Information Officer's (CIO) organization. This is accomplished through continuing oversight of the ClO's formulation and execution of Counsel's budget for CASE-MIS. The Chief Counsel Executive Steering Committee (CC ESC) ensures the ClO is provided overall program priorities for the CASE-MIS initiative in concert with Counsel's business requirements. The Associate Chief Counsel (F&M) signs-off on the annual program letter which is used as a basis for the budget spending plan development process; receives advance notice of any proposed reductions or redirection of funds; and provides comments and recommendations to the ClO relative to the impact of such changes on Chief Counsel's ability to carry out effective legal support to the Service.

To manage Counsel's business systems and strategic planning processes, and organizational studies and analyses; to assist in or provide the formulation of executive performance goals and organizational measures; management consulting services on organizational performance issues; and the continued viability of management information systems for workload staffing and time-reporting.

To direct the management of the Chief Counsel Library, a highly specialized tax law library system, which provides Chief Counsel and IRS staff with support in all substantive areas of the mission of the Service as it pertains to tax law.

To direct the management of a full range of human resource functions. Serves as a member of the Executive Resource Boards (i.e., national and local) and chairs the Executive Resource Board when the Deputy Chief Counsel is unable to participate. Establishes implements and evaluates policies and programs to ensure that all required human resources services, training, and workforce communications are provided throughout the Office. Deals with a wide variety of labor and employee relations matters, and is authorized to approve a variety of personnel issues including settlements in grievance/adverse action cases.

To administer the Equal Employment Opportunity Program and to approve, on behalf of the Deputy Chief Counsel (Operations), the appointment of Equal Employment Opportunity representatives.

To approve or disapprove all requests for waivers of overpayment of pay and allowances up to $5000.

To authorize or approve the allowance and payment from Government funds of expenses related to relocation of employees, and related advance of funds, in accordance with guidance from the Chief Financial Officer. This delegation does not include the authority to agree to the payment of moving expenses by an office other than the gaining office in transfers between the Service and another agency, department, bureau of the Department of the Treasury, etc. This delegation does not include the authority to approve a period of service of less than two years, or to accept separation, without penalty, from service before the end of one year of service, with respect to employees serving outside the coterminous United States under circumstances requiring two years of service. This authority may not be redelegated.

To negotiate basic agreements, with labor organizations holding exclusive recognition for any unit of employees within the Office, subject to final approval by the Chief Counsel, and, in his or her discretion, to authorize negotiation by other Office of Chief Counsel officials on local issues.

To approve in advance requests to speak, publish, or teach made by Associates Chief Counsel and Division Counsel, including the authority to approve travel, travel vouchers, and travel not at Government expense (to the extent permitted by Delegation Order 1-22), where appropriate, in connection with the approval of such requests; and, in connection with the foregoing requests, to act as the agency designee for purposes of making written determinations that the agency interest in having the official participate in a widely attended gathering outweighs the concern that acceptance of a gift of free attendance to such an event may or may appear to improperly influence the official in the performance of his official duties.

Prepares legislative proposals, regulations, revenue rulings and procedures, actions on decisions, other items of public guidance and advisory opinions on matters of law within the jurisdiction of the Associate's office. Coordinates these matters with other components of the Service, Chief Counsel's office and Treasury, as necessary.

Assists the Operating Divisions in setting strategic goals, policy and procedure by providing input in the areas within the Associate's jurisdiction and working with Division Counsel and other Counsel offices to ensure the correct application of law.

Coordinates the Service's position in litigation with Division Counsel, the Service, and Department of Justice in areas within the Associate's jurisdiction in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. Makes appeal and settlement recommendations and prepares other documents setting forth the Service's position in such cases.

Coordinates with other agencies with respect to issues of coordinated jurisdiction, e.g., the Securities and Exchange Commission (SEC) with respect to tax exempt bonds.

Coordinates the resolution of cases and other matters where the subject matter is within the jurisdiction of the Associate's office. Works with the Service, Operating Divisions, Division Counsel, Taxpayer Advocate, and other components of the Service, as appropriate.

Provides administrative and technical support to Division Counsel and other Associate Chief Counsel in the handling and processing of litigation pending in the U.S. Tax Court and other federal courts. Reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with U.S. Tax Court litigation. Processes or coordinates, as appropriate, petitions and complaints, briefs, actions on decision, and other matters with Division Counsel and other Associates.

Advises Department of Justice as to the facts and legal positions of the Service in matters within the jurisdiction of the Associate's office; prepares recommendations concerning defense, settlement, appeal, or certiorari; and coordinates other matters with the Department as required.

Develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memorandums, and CCDM provisions to provide uniform application of the provisions within the Associate's jurisdiction to the Office of Chief Counsel. Provides support and guidance in connection with the development of IRM provisions.

Issues Technical Advice or other legal advice responding to questions raised by Service personnel.

Issues letter rulings and general technical information letters in response to requests from taxpayers.

Reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

With respect to litigation, litigation support, and litigation-related activity, to litigate and arbitrate labor and personnel cases arising in their geographic areas in appropriate forums (such as before the MSPB, FLRA, and EEOC) or before neutrals.

For cases filed or to be filed in their geographic areas, to review and prepare for hearing the enrollee and disbarment cases referred by the Director, Office of Professional Responsibility and the Executive Director of the Joint Board for the Enrollment of Actuaries and to represent those officials before the administrative law judges, providing litigation support to Department of Justice for appealed cases where the position of those officials was substantially sustained in the administrative adjudication and by the agency.

To provide litigation support to Department of Justice in suits filed under the FTCA in their geographic area, where no administrative claim has been filed, and to refer to the Branch Chief (CLP) such suits where such claim has been filed.

To provide litigation support to Department of Justice with respect to, or to litigate (where appropriate), suits filed under Title VII of the Civil Rights Act, suits employing the theory of Bivens v. Six Unknown Defendants of the FBI (Bivens), State court criminal complaints, and other miscellaneous nontax suits filed in their geographic area - in all such matters coordinating significant cases for review as appropriate under Office procedures for the coordination of significant cases and cases involving ethics and professionalism.

To provide legal advice to agency employees and components in their geographic area with respect to general government matters involving: property management, Federal travel, delegations of authority, the Federal Advisory Committee Act, fiscal law, the Records Acts, and such other matters as may be from time to time prescribed by the Associate Chief Counsel (GLS). Area Counsel will provide legal advice on labor, personnel, and discrimination matters only as related to cases in litigation or concerning which litigation is imminent.

To provide advice on general government matters on local issues arising with agency employees and components in their geographic area, notifying the Branch Chief (EGG) of sensitive cases, and referring to the Branch Chief (EGG) those precedential questions or that will have an unusual or nationwide impact.

With respect to litigation, litigation support, and litigation-related activity, to provide legal advice and program coordination support to Area Counsel for labor, personnel, and discrimination cases in litigation and arbitration before relevant forums (such as the MSPB, FLRA, and EEOC) or before neutrals.

To provide litigation support to Department of Justice with respect to, or to litigate (where appropriate), suits filed under Title VII of the Civil Rights Act, suits employing a Bivens theory, State court criminal complaints, and other miscellaneous nontax suits in cases not otherwise covered by Area Counsel.

To provide litigation support to Department of Justice in suits filed under the FTCA in cases not covered by Area Counsel, including cases in which administrative claims have been filed and the Claims Manager has referred the case to the Branch Chief (CLP) for assistance.

To handle direct litigation arising from subject matters under its jurisdiction as assigned by the Associate Chief Counsel (GLS).

With respect to legal advice, to provide legal advice on labor-management relations, personnel, and discrimination matters, including matters, proposals, and referrals under the Office's professionalism program (originally CC Notice N(30)487-1), and to provide program coordination to Area Counsel in all of these matters.

To provide legal advice concerning administrative claims and suits filed under the Federal Torts Claims Act (FTCA), the Federal Claims Collection Act (FCCA), the Debt Collection Act (DCA), and the Military and Civilian Employees' Claims Act (MCECA), and representation of agency employees in damage and other suits for acts taken in their official capacity (including officials and employees under investigation by State and local authorities for official acts), including individual administrative claims referred directly by Claims Manager to the Branch Chief (CLP) for legal assistance, as well as program coordination to Area Counsel in these matters.

To provide legal advice and assistance with respect to, and (where appropriate) to represent the Service and the Office in arbitration, negotiation, and collective bargaining on labor and personnel issues and agreements of National scope.

With respect to litigation, litigation support, and litigation-related activity, to review and coordinate pleadings, briefs, settlement documents, notices of appeal, and any other material prepared in connection with cases in the U. S. Tax Court related to conflict of interest or ethical matters.

To provide litigation support to Department of Justice on appealed cases arising under Treasury Department Circular No. 230 not otherwise covered by Area Counsel.

To provide litigation support to Department of Justice on all general government and legal management matters not otherwise covered by Area Counsel.

To handle direct litigation arising from subject matters under its jurisdiction as assigned by the Associate Chief Counsel (General Legal Services).

With respect to legal advice, to act as the program coordinator and primary advisor to the DEO.

To act as the program coordinator for matters arising from the Office of Professional Responsibility and Joint Board for the Enrollment Actuaries.

To provide legal advice and ethics advisory opinions on all ethics matters, wherever such matters arise or such advice is needed or required, including advice on matters as to the propriety of acts involving the Service and Office employees under 18 U.S.C. Pt. I, Ch. 11; the Ethics in Government Act; and Government-wide, Treasury, Service, Office, and professional standards and rules of conduct or behavior.

To supervise, coordinate, and perform the legal work of the Office on matters relating to conflicts of interest or ethical considerations involving former employees of the Service and the Office, and practitioners, including the propriety of representations before the Service and the U.S. Tax Court.

To provide formal ethics training and briefings, wherever needed.

To provide legal oversight of the filing, review, and action on financial statements of Service and Office employees who are required to file such statements under Title I of the Ethics in Government Act of 1978 (Pub. L. No. 95- 521) (as amended).

To perform ethics reporting of any type.

To provide legal advice on all general government and legal management matters not otherwise covered by Area Counsel, including Federal agency housekeeping matters, such as those matters arising under or concerning fiscal and budgetary statutes and regulations; travel statutes and regulations; property management statutes and regulations; the Federal Advisory Committee Act (FACA); delegations of authority; intellectual property; and the Records Acts.

The Branch Chief (EGG) is responsible for ethics matters of any type, whether litigation, litigation support, or advice, and wherever the case is filed or the matter arises (including matters and cases arising with the Divisions).

With respect to litigation, litigation support, and litigation- related activity, to represent the Service, the Office, and (as requested) the Department in travel claims, bid protests, contract claims, and other government contract proceedings before the GAO, the GSBCA, DOL, SBA, and other government contract forums.

To provide litigation support to Department of Justice on all cases that concern the procurement of goods or services.

With respect to legal advice, to provide legal advice on public contract formation and administration and all public contract matters, including the review of solicitations and contracts, the review of competitive range and other significant pre-award decisions, informant and indemnity agreements, agreements made to effectuate criminal investigation undercover operations, contracting out, interagency agreements for the acquisition of goods and services, computer security, and technology law matters arising under statutes, regulations, and policies bearing on the use and management of technology in the Federal Government.

To represent the Service and the Office, where appropriate, in interagency matters and on interagency councils bearing on the formulation of Government procurement and information technology policy.

To provide primary legal advice on grants and cooperative agreements, agreements respecting the FedState program, and agreements implementing public-private partnerships.

The Branch Chief (PCTL) is responsible for procurement matters of any type, whether litigation, litigation support, or advice, and wherever the case is filed or the matter arises (including matters and cases arising with the Divisions).

Prepares legislative proposals, regulations, revenue rulings and procedures, other items of public guidance, actions on decision and advisory opinions on matters of law within the jurisdiction of the Associate Chief Counsel's office. Coordinates these matters with other components of the Service, Chief Counsel's Office and Treasury, as necessary.

Assists the Operating Divisions in setting strategic goals, policy and procedure by providing input in the areas within the Associate Chief Counsel's jurisdiction and working with Division Counsel and other Counsel offices to ensure the correct application of law.

Coordinates the position of the Service in litigation with the Operating Division Counsel, and Department of Justice in areas within the Associate Chief Counsel's jurisdiction in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. Recommends appeal and settlement of Tax Court and refund cases and prepares other documents setting forth the Service's position in such cases.

Coordinates the resolution of cases and other matters where the subject matter is within the jurisdiction of the Associate Chief Counsel's office. Works with the Service, Operating Divisions, Division Counsel, Taxpayer Advocate and other components of the Service, as appropriate.

Provides administrative and technical support to Division Counsel and other Associate Chief Counsel in the handling and processing of litigation pending in the U.S. Tax Court and other federal courts. Reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with U.S. Tax Court litigation. Processes or coordinates, as appropriate, petitions and complaints, briefs, actions on decision, and other matters with Division Counsel and other Associates.

Advises Department of Justice as to the facts and legal positions of the Service in matters within the jurisdiction of the Associate Chief Counsel's office; prepares recommendations concerning defense, settlement, appeal, or certiorari; and coordinates other matters with the Department as required.

Develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memoranda, and CCDM provisions to provide uniform application of the provisions within the Associate's jurisdiction to the Office of Chief Counsel. Provides support and guidance in connection with the development of IRM provisions.

Issues Technical Advice and other legal advice or determinations responding to questions raised by Service personnel.

Issues letter rulings and general technical information letters in response to requests from taxpayers.

Reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

Prepares legislative proposals, regulations, revenue rulings and procedures, actions on decisions, other items of public guidance and legal advice within the jurisdiction of the Associate's office. Coordinates these matters with other components of the Service, Chief Counsel's Office, Treasury, other government agencies, and international organizations, as necessary.

Assists the Operating Divisions in setting strategic goals, policy, and procedure by providing input in the areas within the Associate's jurisdiction and working with the Division Counsel and other counsel offices to ensure the correct application of law. Formulates and coordinates goals and strategies for the effective and comprehensive strategic management of international issues through all phases of the tax administration process in conjunction with the Director International, the Division Counsel (LMSB), and the Division Counsel (SB/SE). Works closely with international specialists assigned to the Division Counsel and located in various field offices across the country to provide legal advice to the Operating Divisions.

Coordinates the Service's position in litigation with the Division Counsel, the Service, and Department of Justice in areas within the Associate's jurisdiction in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. Makes appeal and settlement recommendations and prepares other documents setting forth the Service's position in such cases.

Works with the Service, Operating Divisions, Division Counsel, Taxpayer Advocate, and other components of the Service, as appropriate, to ensure consistent and appropriate resolution of cases and other matters where the subject matter is within the jurisdiction of the Associate's office.

Provides administrative and technical support to the Division Counsel and other Associate Chief Counsel in the handling and processing of litigation pending in the U.S. Tax Court and other federal courts. Reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with litigation, as appropriate. Coordinates, as appropriate, petitions and complaints, briefs, actions on decision, and other matters with the Division Counsel and other Associates.

Develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memorandums, and CCDM provisions to provide uniform application of the provisions within the Associate's jurisdiction to the Office of Chief Counsel. Provides support and guidance in connection with the development of IRM provisions.

Issues Technical Advice, and other legal advice responding to questions raised by Service personnel.

Issues letter rulings and general technical information letters in response to requests from taxpayers.

Reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

Conducts the negotiation and execution of all Advance Pricing Agreements. See CCDM 32.4.1, Advance Pricing Agreements.

Serves as a member of the International Council with the LMSB Director for International and Treasury's International Tax Counsel, a three-office partnership designed to formulate and coordinate goals and strategies for the development and advancement of sound tax policy and administration in the international arena.

Plans, directs, and coordinates the Office of Chief Counsel's participation in all multinational fora, such as the Organization for Economic Cooperation and Development, the Group of Four, and the Pacific Association of Tax Administrators.

Represents the Office of Chief Counsel and assists Treasury and other government agencies in tax treaty negotiations and in negotiations with respect to other international agreements.

Provides legal advice and assistance to the United States Competent Authority on all matters of treaty interpretation and implementation, including both substantive legal issues as well as all procedural issues arising out of treaty-based processes, such as information exchange and cross-border information gathering and collection processes. In addition, provides assistance to Area Counsel, Division Counsel, and Operating Division personnel with respect to such matters.

The Deputy Associate Chief Counsel (International - Technical) is delegated the authority to sign closing agreements pertaining to elections under IRC § 953(d).

The Deputy Associate Chief Counsel (International Field Service and Litigation) is delegated the authority to sign closing agreements described in Treas. Reg. §1.1503-2(g)(2)(iv)(B)(2)(i).

The Director (APA) is delegated the authority to sign Advance Pricing Agreements and Recommend ed United States Negotiating Positions.

Prepares legislative proposals, regulations, revenue rulings and procedures, actions on decisions, other items of public guidance and advisory opinions on matters of law within the jurisdiction of the Associate's office. Coordinates these matters with other components of the Service, Chief Counsel's Office and Treasury, as necessary.

Assists the Operating Divisions in setting strategic goals, policy, and procedure by providing input in the areas within the Associate's jurisdiction and working with Division Counsel and other Counsel offices to ensure the correct application of law.

Coordinates the Service's position in litigation with Division Counsel, the Service and Department of Justice in areas within the Associate's jurisdiction in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. Makes appeal and settlement recommendations and prepares other documents setting forth the Service's position in such cases.

Coordinates the resolution of cases and other matters where the subject matter is within the jurisdiction of the Associate's office. Works with the Service, Operating Divisions, Division Counsel, Taxpayer Advocate, and other components of the Service, as appropriate.

Provides administrative and technical support to Division Counsel and other Associate Chief Counsel in the handling and processing of litigation pending in the U.S. Tax Court and other federal courts. Reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with U.S. Tax Court litigation. Processes or coordinates, as appropriate, petitions and complaints, briefs, actions on decision, and other matters with Division Counsel and other Associates.

In coordination with Division Counsel, advises Department of Justice as to the facts and legal positions of the Service in matters within the jurisdiction of the Associate's office; prepares recommendations concerning defense, settlement, appeal, or certiorari; and coordinates other matters with the Department as required.

Develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memoranda, and CCDM provisions to provide uniform application of the provisions within the Associate's jurisdiction to the Office of Chief Counsel. Provides support and guidance in connection with the development of IRM provisions.

Issues Technical advice or other legal advice or determinations responding to questions raised by Service personnel and Division Counsel.

Issues letter rulings and general technical information letters in response to requests from taxpayers.

Reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

Prepares legislative proposals, regulations, revenue rulings and procedures, letter rulings, actions on decisions, other items of public guidance and advisory opinions on matters of law within its jurisdiction. Coordinates these matters with other components of the Service, Chief Counsel's office and Treasury as necessary.

Assists the Operating Divisions in setting strategic goals, policy, and procedure by providing input in the areas within the Associate's jurisdiction and working with the Operating Division Counsel and other Counsel offices to ensure the correct application of law.

Coordinates the Service's position in litigation with the Operating Division Counsel, the Service, and the Department of Justice in areas within the Associate's jurisdiction in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. Makes appeal and settlement recommendations and prepares other documents setting forth the Service's position in such cases.

Coordinates the resolution of cases and other matters where the subject matter is within the jurisdiction of the Associate's office. Works with the Service, Operating Divisions, Operating Division Counsel, Taxpayer Advocate, and other components of the Service as appropriate.

Provides administrative and technical support to the Operating Division Counsel and other Associates Chief Counsel in the handling and processing of litigation pending in the U.S. Tax Court and other federal courts. Reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with U.S. Tax Court litigation. Processes or coordinates, as appropriate, petitions and complaints, briefs, actions on decision, and other matters with the Operating Division Counsel and other Associates Chief Counsel.

Assists in the authorization or sanction of counterclaims, third party complaints, or the commencement of collection suits with respect to refund suits pending in the district courts, the U.S. Court of Federal Claims and in performance of necessary legal services on behalf of the Service as directed in connection with taxpayer suits for refund of taxes, EXCEPT alcohol, tobacco, and firearms taxes.

Coordinates with the Department of Justice the defense of any case where an employee's refusal to testify or produce Service records results in, or may result in, an order to show cause as to why that employee should not be held in contempt of court, or an actual order of contempt. Prepares such documents setting forth the Service’s position in such cases.

Advises the Department of Justice as to the facts and legal positions of the Service in matters within his/her jurisdiction; prepares recommendations concerning defense, settlement, appeal, or certiorari; and coordinates other matters with the Department as required.

Develops policy, procedure, directives, Chief Counsel Notices, and CCDM provisions to provide uniform application of the provisions within the Associate's jurisdiction to the Office of Chief Counsel. Provides support and guidance in connection with the development of IRM provisions.

Issues Technical Advice and other legal advice or determinations responding to questions raised by Service personnel.

Approves on behalf of the Chief Counsel actions to be taken with respect to U.S. Tax Court subpoenas and disclosure of information in U.S. Tax Court litigation.

As provided by Executive Order 12778, serves as sanctions officer for the Office of Chief Counsel who reviews motions for sanctions filed by litigation attorneys within the meaning of the Executive Order, or against such litigation attorneys, the United States, its agencies, or its officers. Such review may be redelegated to the Deputies Associate Chief Counsel, Branch Chiefs, Senior Technician Reviewers and Special Counsel within the Associate Office.

Serves as the liaison officer of the Chief Counsel with the U.S. Tax Court and the U.S. Court of Federal Claims.

Serves as the Commissioner's delegate for assertion of claims of executive privilege involving internal or interagency records or information that are predecisional and deliberative in matters before the U.S. Tax Court, U.S. Court of Federal Claims and other federal courts, as appropriate.

Coordinates, as appropriate, with other executives and managers in their handling and processing of actions to restrain disclosure under I.R.C § 6110 in the U.S. Tax Court, including the determination of the Service’s litigating position in such cases.

Accepts and acknowledges service of process directed to the Service or its employees acting in their official capacity.

Prepares opinions as to whether there is a sufficient showing of fraud, malfeasance, or misrepresentation to warrant reopening closing agreements.

The Publications and Regulations section performs a wide variety of duties with respect to regulations and other documents filed with the Federal Register, including reviewing and editing regulations; assigning Regulatory Identification Numbers; coordinating codification of regulations in the Code of Federal Regulations; submitting regulations to the Small Business Administration; coordinating Paperwork Reduction Act submissions; ensuring that all final and temporary regulations comply with the Congressional Review Act; scheduling and coordinating public hearings; drafting, correcting and filing documents with the Federal Register; preparing the Service's portions of the semi-annual Unified Agenda of Regulations; retrieving, distributing and filing public comments; processing FOIA requests for public comments and public hearing information; and preparing many regulations and regulatory law related special projects for the Office of Chief Counsel.

The Disclosure Support section processes for public release all written determinations prepared by the Office of Chief Counsel that are subject to the provisions of I.R.C. § 6110, and processes all Office of Chief Counsel FOIA requests. The DS section also provides paralegal assistance on special projects for the office of Chief Counsel.

The Litigation Technology section supports electronic discovery for the Office of Chief Counsel. All eDiscovery information and resources can be found on the Chief Counsel Litigation Technology Page and CCDM 34.7.1.

Under the authority of the Deputy Associate Chief Counsel (P&A) with responsibility over P&A Branches 6 & 7, the Branch Chiefs and Senior Technician Reviewers in P&A Branches 6 & 7 are authorized to receive service of any subpoena, summons, or other judicial process directed to an officer or employee of the Department of the Treasury in his or her official capacity in any litigation (other than the U.S. Tax Court).

This authority may be redelegated by the Deputy Associate Chief Counsel (P&A) with responsibility over P&A Branches 6 & 7 to other attorneys in P&A Branches 6 & 7.

If a Deputy U.S. Marshall or other process server attempts to serve process on any person not delegated authority to receive process server to one of the persons having authority to receive service.

Plans, directs and coordinates the legal work of the CT function.

Provides input to the Chief Counsel, Chief, Criminal Investigation and other senior executives within CI on matters of CT policy.

Reviews high profile/sensitive cases centralized in the National Headquarters.

Plans and implements actions, including periodic meetings, necessary to create and maintain strong communications within the CT function and between CT, CI and other functions.

Issues advice, direction, and guidance in the appropriate form, including but not limited to legal advice memorandum; informal and formal technical advice; Legal Guidance Memorandum; IRM provisions; Chief Counsel Notices and Directive Manual provisions; and various other publications and handbooks on various issues such as money laundering, tax crimes, electronic surveillance, sentencing, and search warrants.

Reviews CI requests for use of special investigation techniques, including but not limited to proposed Grants of Immunity under 18 U.S.C. § 6001, et seq.; initial requests, deviations and extensions of Group I undercover operations as a member of the Undercover Advisory Committee; highly sensitive search warrants centralized in the National Headquarters; and non-consensual electronic surveillance.

Reviews requests for Code judicial forfeitures pursuant to IRC § 7301, et seq. and makes recommendations on forfeiture petitions for remission or mitigation or offers in compromise.

Responds to inquiries including, but not limited to, those from Congress; other governmental agencies; professional organizations and the public as well as FOIA requests.

Prepares Chief Counsel Advice for disclosure under IRC § 6110.

Coordinates between Department of Justice, other Chief Counsel/IRS functions and other Government agencies.

Disseminates Department of Justice declines.

In consultation with the Chief Counsel and the General Counsel, makes appellate and certiorari recommendations to Department of Justice.

Designs, coordinates, and conducts CT training, including Basic, Advanced, Symposium, and specialized schools.

Provides full time senior attorney(s) as instructors at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia.

Provides a Counsel liaison to multi-governmental agency task forces.

Implements and evaluates operational policies and procedures designed to improve the delivery of legal services.

Identifies and communicates emerging and significant issues.

Performs such other functions as may be prescribed from time to time by the Chief Counsel.

When assigned to National Headquarters, to serve as legal and technical consultants on the most difficult, important and complex matters arising in connection with the work of the Division, as well as less complex matters assigned at the discretion of the Division Counsel/Associate Chief Counsel (CT) or his or her Deputy. Special Counsel assist and represent the Division Counsel/Associate Chief Counsel (CT) at Chief Counsel, Internal Revenue, and Treasury conferences where policy is developed and determined.

When assigned to FLETC, to serve as the primary legal instructor and Chief Counsel representative on Criminal Investigation's teaching cadre at FLETC. The Special Counsel in this capacity exercise overall program and policy responsibility for the substantive criminal tax teaching provided at FLETC.

Acts for the Division Counsel/Associate Chief Counsel (CT) in the absence of the Division Counsel and Deputy Division Counsel. When acting in such capacity, the Assistant assumes complete responsibility for the activities of the Office of the Division Counsel/Associate Chief Counsel (CT).

Collaborates closely with the Division Counsel regarding any administrative issues under the jurisdiction of Criminal Tax. Specifically, the Assistant plans, directs, and coordinates the administrative and management policies and programs of the office, serving as liaison to the budgetary, information technology, and management committees of the Chief Counsel and the Commissioner.

Assists the Deputy Division Counsel/Associate Chief Counsel (CT) in the management and supervision of the Area Counsel (Criminal Tax). The Assistant conducts Area visitations, works with the Area Counsel relative to staffing issues and workload issues in their Areas, and other duties and responsibilities assigned by the Division Counsel/Associate Chief Counsel (CT) and his or her Deputy.

Serves as the appraising official of the Special Counsel assigned to the FLETC and the approving official of the docket attorney assigned to the FLETC. The Assistant works with the Special Counsel and Criminal Investigation personnel relative to the oversight of this program.

Supervises the attorneys in the Office of Division Counsel/Associate Chief Counsel in positions below GS-15. This responsibility includes, but is not limited to, assigning work, reviewing work products, and appraising the annual performance of the attorneys.

Serves as the appraising official of the Executive Assistant and the Management Analyst and the approving official of the Administrative Officer.

Develops and executes policies, procedures, and directives designed to manage the budgetary process for all aspects of the Criminal Tax function.

Develops, implements, and evaluates operational policies and procedures designed to improve the delivery of legal services.

Develops, implements and evaluates modernization policies and procedures for the Criminal Tax function.

Performs such other functions and duties as may be prescribed from time to time by the Division Counsel/Associate Chief Counsel (CT) and the Deputy Division Counsel/Associate Chief Counsel (CT).

Plans, directs, and coordinates the legal work of the Criminal Tax function in the assigned geographic area.

Plans and implements actions, including periodic meetings, necessary to create and maintain strong communications within the assigned area and between other areas and the Office of Division Counsel/Associate Chief Counsel Associate.

Provides formal and informal legal advice and assistance in matters requiring the approval of the CI Area Manager.

Informs division attorneys and the CI Area Manager of developments in substantive and procedural matters.

Coordinates and participates in training of Counsel and CI personnel.

Periodically meets with the CI Area Manager to ensure that necessary legal services are being provided and to discuss areas for improvement.

Alerts the Division Counsel/Associate Chief Counsel (CT) to sensitive or unique matters in the area.

Makes recommendations to the Division Counsel/Associate Chief Counsel (CT) on emerging issues.

Supports the Division Counsel/Associate Chief Counsel (CT) in the design, coordination and conducting of criminal tax schools.

Supports the Division Counsel/Associate Chief Counsel (CT) in the preparation and updating of manual provisions, training materials, technical updates and other publications.

Coordinates between Department of Justice, other Chief Counsel and Service functions and other Government agencies.

Performs such other functions as may be prescribed from time to time by the Division Counsel/Associate Chief Counsel (CT).

Supervises the Senior Counsel and division attorneys assigned to the Criminal Tax function in the Area and local offices.

Assigns, reassigns, and transfers Area Counsel (CT) and Division Counsel (CT) personnel under his or her jurisdiction among any of the Area's subordinate offices, as necessary.

Prepares evaluations and appraises the performance of subordinate personnel, taking personnel actions as necessary for those under his/her supervision.

Assigns and reviews work products, establishes work assignment priorities, monitors workload balances, and transfers work among docket attorneys to ensure a proper workload balance.

Ensures performance and program goals, strategy, and organizational policies are clearly communicated to employees.

Approves travel and travel vouchers and manages other assigned budgetary functions for the area.

Prepares and maintains records and reports with respect to the work of the CT function in the area.

Designates an Acting Area Counsel (CT) or other manager for the function for the temporary absence of the incumbent.

Redelegates his/her authority as necessary, except where such redelegation is expressly restricted or otherwise restricted by law, regulation, or policy.

Signs on behalf of the Chief Counsel by the use of the by-line or in his/her own name (whichever is appropriate) correspondence and other papers pertaining to the functions of Counsel and which are considered in the course of the official duties of the Area Counsel (CT).

Represents the Commissioner in the litigation of cases pending in the U.S. Tax Court.

Prepares enforcement, defense, and settlement letters in summons enforcement and refund litigation cases, and leading the coordination of these Department of Justice cases with other Counsel functions.

Makes recommendations of acquiescence and nonacquiescence in adverse decisions in litigation, providing on-going services to Department of Justice and coordinating with Associate Chief Counsels on recommendations to the Chief Counsel and Department of Justice regarding appeals of adverse decisions, rehearing and rehearing en banc, the filing of amicus curiae briefs, petitions for writ of certiorari to the U.S. Supreme Court, and any other appropriate judicial action pertaining to matters under the jurisdiction of LMSB.

Provides pre-filing and post-filing legal advice to LMSB examination teams, either in the audit of returns or in the consideration of claims for refund.

Coordinates input from the LMSB Commissioner with the Deputy Chief Counsel (Technical), Associate Chief Counsels and Treasury officials with respect to the need for and the administrability of published guidance, including regulations, notices, revenue rulings, revenue procedures, actions on decision and other items of published guidance.

Coordinates key issues and cases with the Chief Counsel, Deputies Chief Counsel, Associate Chief Counsels, and other members of the Chief Counsel organization.

Oversees the Industry Counsel and International Field Counsel Programs, which are the counterparts to the Industry Technical Advisor and International Technical Advisor Programs in LMSB Pre-Filing and Technical Guidance.

Works in concert with the LMSB Office of Tax Shelter Analysis to identify and address abusive tax avoidance transactions.

Supports the Division Counsel (SB/SE) in bankruptcy matters.

Provides legal advice on Advance Pricing Agreements, Pre-filing Agreements and other closing agreements.

Provides internal and external training on issues.

Conducts public outreach to taxpayer organizations.

The Area Counsel for Financial Services (Area 1), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Financial Services.

The Area Counsel for Heavy Manufacturing and Transportation (Area 2), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Heavy Manufacturing and Transportation.

The Area Counsel for Retailers, Food, Pharmaceuticals and Health Care (Area 3), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Retailers, Food, Pharmaceuticals and Health Care.

The Area Counsel for Natural Resources (Area 4), who serves as the principal legal advisor to, and is collocated with, the Industry Director, Natural Resources.

The Area Counsel for Communications, Technology and Media, (Area 5) who serves as the principal legal advisor to, and is collocated with, the Industry Director, Communications, Technology and Media.

Docketed Cases. To process and handle cases docketed in the Tax Court involving SB/SE or W&I taxpayers.

Statutory Notices. To perform the duties and functions relating to the consideration and review, prior to issuance, of proposed statutory notices of deficiency and statutory notices of claim disallowance prepared by SB/SE or W&I

Subpoenas. To approve on behalf of the Chief Counsel actions to be taken with respect to Tax Court subpoenas and disclosure of information in Tax Court litigation within the jurisdiction of the division.

Adverse Decisions. To make recommendations to the Chief Counsel respecting adverse Tax Court decisions within the jurisdiction of the division.

Cases in the Tax Court. To dispose of Tax Court cases within the jurisdiction of the division by trial, settlement, or dispositive motion.

Refund Matters. To authorize or sanction counterclaims, third-party complaints, or the commencement of collection suits with respect to refunds suits of taxpayers within the jurisdiction of SB/SE or W&I pending in the district courts or the Court of Federal Claims and to perform necessary legal services on behalf of the Service as directed in connection with taxpayer suits for refund of taxes.

Legal Advice and Opinions. Upon request, to furnish collection advice and opinions to SB/SE personnel or other functions of the Service responsible for collection matters in any matter (court and noncourt).

Actions. To advise SB/SE Field personnel, handle the legal work, and assist US Attorneys in cases involving:

Bankruptcy Matters. To handle legal work pertaining to the collection and protection of tax claims and liens of the United States in proceedings under the bankruptcy law.

Bankruptcy Plans. To accept or reject plans where the United States is a creditor or equity security holder, including municipal debt adjustment plans, reorganization plans, and railroad reorganization plans (11 U.S.C. §§ 901(a) and 1126(a)). This covers proceedings where the United States possesses solely an IRS claim (a Treasury claim), as well as proceedings in which there are other claims of the United States in addition to the claim of the IRS. A non-Treasury claim of the United States includes any department, agency, federally chartered corporation, or instrumentality of the United States. To the extent that an agreement cannot be reached between the Chief Counsel, IRS, and the holder of a non-Treasury claim of the United States, the matter will be referred to the General Counsel of the Treasury for resolution.

Suits. To determine what civil actions shall be brought by the Government in connection with the collection with the collection of internal revenue taxes and to authorize or sanction commencement of such actions.

Offers-in-Compromise. To review and dispose of offers-in-compromise.

Leases, Bonds, and Escrow Agreements. To handle legal matters arising within the regions with respect to leases, bonds, escrow agreements, and other similar matters relating to the collection of taxes.

Appeals. To make recommendations to the Chief Counsel respecting appeals of court decisions in general litigation matters.

Disclosure of Information. To assist, when called upon, Service field personnel in matters involving the disclosure of information. The Associate Chief Counsel (P&A), Branches 6 and 7, however, retains primary responsibility for disclosure matters.

Jeopardy and Termination Assessments and Jeopardy Levies. To approve in writing the making of jeopardy and termination assessments and jeopardy levies. This authority may be redelegated no lower than Associate Area Counsel.

Summons Matters. To review, upon request, proposed summonses, and to recommend enforcement or defense in summons litigation matters, involving SB/SE & W&I taxpayers.

Writs of Entry. To review, upon request, proposed writs of entry, and to recommend the filing of motions to obtain writs of entry in collection matters.

Writs Ne Exeat. To review, upon request, and to recommend the filing of writs ne exeat in collection matters.

Represents the Commissioner in the litigation of significant cases pending in the U.S. Tax Court.

Prepares enforcement, defense, and settlement letters in significant summons enforcement and refund litigation cases and leads the coordination of these Department of Justice cases with other Counsel functions.

Makes recommendations of acquiescence and non-acquiescence in adverse decisions in significant case litigation, providing on-going services to Department of Justice and coordinating with Associate Chief Counsels on recommendations to the Chief Counsel and Department of Justice regarding appeals of adverse decisions, rehearing and rehearing en banc, the filing of amicus curiae briefs, petitions for writ of certiorari to the U.S. Supreme Court, and any other appropriate judicial action pertaining to matters under the jurisdiction of SL.

Manages the Significant Case Program, which allows for coordination of significant cases approaching litigation, and docketed in the U.S. Tax Court and other federal courts.

Manages the Strategic Litigation Program, which includes a nationwide staff of Special Trial Attorneys and Paralegals, and which provides the primary support for the litigation of significant cases in the U.S. Tax Court.

Provides pre-filing and post-filing legal advice to examination teams, either in the audit of significant and complex returns or in the consideration of significant and complex claims for refund.

Coordinates input from the Commissioner with the Deputy Chief Counsel (Technical), Associate Chief Counsels and Treasury officials with respect to the need for and the administrability of published guidance, including regulations, notices, revenue rulings, revenue procedures, actions on decision and other items of published guidance.

Coordinates key issues and cases with the Chief Counsel, Deputies Chief Counsel, Associate Chief Counsels, and other members of the Chief Counsel organization.

Provides internal and external training on issues.

Conducts public outreach to taxpayer organizations.

Prepares recommendations concerning defense, settlement, concession, appeal, or certiorari

Furnishes advice and assistance in pending litigation including suits for declaratory judgment for exempt organizations arising under IRC § 7428 in the U.S. District Court for the District of Columbia and the Court of Federal Claims

Authorizes or sanctions counterclaims, third party complaints, or the commencement of collections suits in the district courts, bankruptcy courts, or the U.S. Court of Federal Claims pertaining to matters under his/her jurisdiction

If the sole issue or primary issue is a TEGE issue and the notice of deficiency, liability, or other determination was issued by the Appeals Division after Appeals' consideration of all petitioned issues;

If the notice of deficiency, liability, or final adverse determination letter was issued by the TEGE Operating Division and is based upon a TEGE ruling or TEGE technical advice in that case involving a qualification of an employee plan or tax exemption and/or foundation status of an organization (but only to the extent the case involves such issue); or,

If the case was docketed under IRC §§ 7428, 7476, or 7478, except as provided in paragraph 3 of Delegation Order 8-1, Appeals Functions. Settlement of Cases Docketed in the United States Tax Court (IRM 1.2.47.2. Jurisdiction vests with Counsel at the time such cases are docketed with the court. See 26 CFR § 301.6020-1, 26 CFR § 301.6201-1, 26 CFR § 301.7701-9; Treasury Department Order No. 150-10; General Counsel Order No. 4; and Delegation Order 8-1.

Upon delegation by the Division Counsel/Associate Chief Counsel (TEGE), any deputy may supervise all or any Special Counsel, Technical Assistants, and staff not otherwise directly supervised by the DC/ACC (TEGE).

As prescribed by the DC/ACC (TEGE), the deputies may serve as Acting Division Counsel/Associate Chief Counsel (TEGE) in the absence of the DC/ACC (TEGE) and may act for or represent the DC/ACC (TEGE) in the development of policies governing the office.

The deputies will perform such additional duties as may, from time to time, be assigned by the DC/ACC (TEGE).

Planning, directing, supervising technical subject experts, and coordinating operational policies and programs with respect to legislation, regulations, and other guidance

Interpretations of rulings and opinions to assure the uniform interpretation and application of federal tax laws involving income tax and other tax aspects of executive compensation, employee benefits programs ( including employer-provided medical plans), and nonqualified deferred compensation plans.

Planning, directing, supervising technical subject experts, and coordinating operational policies and programs with respect to legislation, regulations and other guidance.

Interpretations of rulings and opinions to assure the uniform interpretation and application of federal tax laws involving employment taxes and taxes on self-employment income, exempt organizations (other than those within the jurisdiction of the Commissioner, TEGE Division), fringe benefits, Indian tribal governments, and federal, state, and local governments.

Works closely with the Commissioner and Deputy Commissioner (W&I), in formulating short and long range program policies, strategies, and objectives for the Division to implement overall Service strategy and vision. Participates as an executive member of Commissioner (W&I) Planning Council. Participates in the design and development of integrated policies, programs, systems, and strategies that effectively provide superior customer service and ensure fairness and equity in enforcement of the Division's delivery of service and accountability to taxpayers.

Sets Division Counsel (W&I) business unit strategy and goals in alignment with overall organizational and research strategy. Establishes performance targets and business unit goals.

Provides program direction to the Division Counsel (SB/SE) relative to tax litigation and other legal services associated with W&I cases and taxpayers. Provides feedback to the Division Counsel (SB/SE) for the annual performance evaluations of SB/SE Area Counsel, based on continuing assessments of delivery of service related to W&I cases and taxpayers.

Allocates Division Counsel (W&I) resources as required and manages operating unit budget process and investment process.

Coordinates strategy and positions with appropriate officials throughout the W&I Division, other Division Counsel offices, and Associate Chief Counsel offices. Coordinates questions concerning litigation and/or settlement of issues and cases of W&I taxpayers.

Directs and oversees the overall management of the Division Counsel (W&I) staff. In this regard, provides continuing coordination, control, and direction of Division Counsel (W&I) operations to assure that Chief Counsel objectives, policies, procedures, and programs are implemented fully and effectively, including the development of programs and their evaluation in terms of effectiveness, efficiency, comprehensiveness, and timeliness.

Assures that Division Counsel (W&I) staff operates as an effective team, and that all functions are handled equitably and in a manner that is responsive to the needs of all programs that Division Counsel (W&I) supports. Assures sound position management policy and takes positive steps in support of all merit system principles.

Assures the full range of personnel activities are properly and timely addressed as necessary (i.e., recruitment, training, performance evaluation, disciplinary or adverse action, and management reporting), and performs all needful activities to effectively manage the organization and personnel within the Division Counsel (W&I) organization.