In a memorandum, the IRS Large Business and International (LB&I) Division has temporarily suspended, through July 15, 2020, information document request (IDR) enforcement procedures with respect to certain taxpayers who may be unable to respond timely to IDR requests because of the coronavirus (COVID-10) pandemic.
Background.
On March 13, 2020, the President issued an emergency declaration under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) in response to the ongoing coronavirus (COVID-19) pandemic (Emergency Declaration). The Emergency Declaration instructed the IRS “to provide relief from tax deadlines to Americans who have been adversely affected by the COVID-19 emergency, as appropriate.”
Enforcement procedures suspended.
According to the memorandum, the IDR enforcement procedures found in Internal Revenue Manual 4.46.4-2 are temporarily suspended through July 15, 2020.
Examiners can continue issuing and receiving IDRs; the memorandum only applies to the IDR enforcement process for taxpayers who are unable, due to the COVID-19 pandemic, to respond timely to an IDR.
Also, examiners may continue with the IDR enforcement process, even against taxpayers who are unable, due to the COVID-19 pandemic, to respond timely to an IDR when, in the examiner’s judgment, the interests of tax administration warrant, for example, when the statute of limitations will be expiring soon.
To continue your research on IRS Large Business & International (LB&I) Division’s process for issuing information document requests (IDRs), see FTC 2d/FIN ¶T-1181.1.
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