Examination of Books and Witnesses

ID:
UILC:
CCA_2023121011592548
7602.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 202352020
Release Date: 12/29/2023
From: ---
Sent: Wednesday, November 15, 2023 1:35:47 PM
To: ---
Cc: ---
Bcc:
Subject: RE: Third Party Contact Report Guidelines - TAS non-concur
Hey ---,
We maintain our position that third-party contact reports should be issued to the taxpayer only upon request and not periodically. The preamble to Procedure and Administration Regulation § 301.7602-2(e)(1) states: “[T]he IRS determined that the issuance of periodic reports may result in harm to third parties and, accordingly, has determined that periodic reports should not be issued. Taxpayers will continue to receive pre-contact notice and may specifically request from the IRS reports of persons contacted.” Thanks, ------------