nacva december 2, 2011 presenation

IRS Divisions and Risk Management ©

Michael GregoryMichael Gregory Consulting LLC for

NACVA CPE December 2, 2011

Michael Gregory Consulting LLC www.mikegreg.com

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Presenter

• Michael Gregory, Chief Manager, Michael Gregory Consulting LLC since September 12, 2011

• Formerly IRS 28 Years as Engineer and Valuer, Manager, Operations Team Lead, Controller, Acting Assistant District Director, Territory Manager

• ASA, CVA, MBA, PE, Qualified Neutral

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Michael Gregory Consulting LLC

• Risk Management• Alternative Dispute Resolution• Will Go Over Some Examples• Could be of Service to You and Your Clients• [email protected]• 651-633-5311

Michael Gregory Consulting LLC www.mikegreg.com ©12/2/2011

mailto:[email protected]

http://www.mikegreg.com/


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Disclaimer

• The opinions presented here are those of Michael Gregory. Michael Gregory does not represent the IRS. Any opinions presented in this seminar are those of the author and do not represent an official position of their current or previous employers. This material is offered for educational purposes only. The author and his employer expressly disclaim any liability, including incidental or consequential damages, arising from the use of this material or any errors or omissions that may be contained in it.

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IRS

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IRS

• Eleven Divisions• Compliance – Four Divisions• Appeals• Counsel – IRS and DOJ Tax Litigation Division• Your Primary Interest as Valuers– LB&I– SBSE– TEGE

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IRS.gov

• Businesses• Starting a Business• Operating a Business• Closing a Business• Employer ID Numbers• Small Business Events• Industry Professions • Audit Technique Guides – Aerospace to Wine12/2/2011


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Large Business and International

• Six Industries and One Support Function• CTM, FS, HMT, NRC, RFPH, GHW, • Field Specialists– Engineering and Valuation– Employment Tax– Computer Audit Specialists– Financial Products

• Counsel

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Engineering and Valuation

• Internal Consultants to All Divisions• Four Territory Managers• 32 Managers• 320 Technical Employees• Robin Ruegg Territory Manager• Christine Harwood Local Manager• Valuers Locally – Real Property and BV

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Small Business and Self Employed

• Examination– General – Estate and Gift• Classification Process• Owner

• Collection• Counsel

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Tax Exempt and Governmental Entities

• ESOP’s• Related for Profit Entities• Gifts in Kind• Services Provided• Reasonable Compensation

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Appeals

• Case Closes Out of Examination Unagreed and Goes to the Internal IRS Appeals Divsions

• Goal to Settle Cases• 85% Target• Independent• Ex Parte Rules

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Counsel

• IRS Office of Chief Counsel– Appointed by the President

• Operations• Technical

– All Non Litigation Work (legislative, regulation, interpretation)– Corporate– International– Technical Advice

• IRS Division Counsel• IRS Special Trial Counsel• DOJ Tax Litigation Division12/2/2011


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Let’s Have Some Fun

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What Do You Think?

• Who Owns the Case?• Who Manages the Case?• What is the Role of the Valuer?• Let’s Discuss Some War Stories

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Discuss Some Examples

• SBSE Examination Case with E&G on Exam• SBSE Examination Case with Counsel• SBSE Case with DOJ• SBSE Case at Appeals• TEGE Case with Related Entities– Credit Counseling, Reasonable Compensation– Hospitals, Physician Practices– Colleges and Universities

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Discuss Some Examples Continued

• LB&I 409A• LB&I Stock Options and Stock Valuations• LB&I Purchase Price Allocations• 6695A Appraiser Penalties

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Important Take Away Information

• Know Who Your Working with at the IRS• Understand the Role of Participants• Seek to Understand Interests• Do Not Be Afraid to Ask Questions• Consider Options– Ask for a Valuer– Ask to Elevate in Management as a Neutral Party

Given Ownership of the Issue by the RA or ETA

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What Are Your Thoughts and Questions

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