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Michael GregoryMichael Gregory Consulting LLC for     CRM Minnesota April 27, 2012
 Michael  Gregory, Chief Manager, Michael  Gregory Consulting LLC since September  12, 2011 Formerly IRS 28 Years as Eng...
 Risk Management with IRS Alternative Dispute Resolution - Mediation Strategic Planning Could be of Service to You and...
 The  opinions presented here are those of  Michael Gregory. Michael Gregory does not  represent the IRS. Any opinions pr...
 Background   on IRS Mediation Officially at the IRS Some Case Examples of Conflicts Mediation Defined and Applied fro...
 What  Does the IRS look like to you?  Mailbox with a slit to receive your tax return?  A tax collector and what does tha...
 Eleven             Divisions – Note all of this material   on the IRS can be obtained at irs.gov Compliance            ...
 Businesses Starting a Business Operating a Business Closing a Business Employer ID Numbers Small Business Events I...
 Six Industries and One Support Function CTM, FS, HMT, NRC, RFPH, GHW, Field Specialists      Engineering and Valuatio...
 Examination      General      Estate and Gift          Classification Process          Owner Collection Counsel Mi...
 ESOP’s Related  for Profit Entities Gifts in Kind Services Provided Reasonable Compensation Michael Gregory Consulti...
 Case Closes Out of Examination Unagreed  and Goes to the Internal IRS Appeals Divisions Goal to Settle Cases 85% Targe...
   IRS Office of Chief Counsel       Appointed by the President           Operations           Technical             ...
 At Least One in Every State –St. Paul Independent Organization to Help Taxpayers  with Problems Address – economic har...
 Formerly               Equal Employment Opportunity and  Diversity Mike on EEOD Advisory Counsel for the  Commissioner ...
 Who  Owns the Case? Who Manages the Case? Let’s Discuss Some ExamplesMichael Gregory Consulting LLC   www.mikegreg.com...
 SBSE Examination Case with E&G on Exam SBSE Examination Case with Counsel SBSE Case at Appeals TEGE Case with Related...
Michael Gregory Consulting LLC   www.mikegreg.com ©   4/27/2011
 Officially                  at Appeals – Hazards of Litigation       Revenue Procedure 2009-44       Fast Track Mediat...
 Budget  Division Chiefs Research Credit 4 Days Valuation Issue Relief From Royalty Method     Royalty Rate, Discount ...
 Know Who Your Working with at the IRS Understand the Role of Participants Seek to Understand Interests       Model:  ...
 IRS official and unofficial workings at the IRS Classification Technical Chapters on Engineering and  Valuation Issues...
 Realizing Many Issues in Corporate Tax are  Gray by Design Listening to Both Parties Looking for Common Ground by Aski...
Michael Gregory Consulting LLC   www.mikegreg.com ©   4/27/2011
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Crm minnesota 4 27-2011

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Transcript of "Crm minnesota 4 27-2011"

  1. 1. Michael GregoryMichael Gregory Consulting LLC for CRM Minnesota April 27, 2012
  2. 2.  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, AVA, MBA, PE, Qualified Neutral Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  3. 3.  Risk Management with IRS Alternative Dispute Resolution - Mediation Strategic Planning Could be of Service to You and Your Clients mg@mikegreg.com 651-633-5311 Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  4. 4.  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.Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  5. 5.  Background on IRS Mediation Officially at the IRS Some Case Examples of Conflicts Mediation Defined and Applied from a Practical Perspective at the IRS DiscussionMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  6. 6.  What Does the IRS look like to you? Mailbox with a slit to receive your tax return? A tax collector and what does that mean? An agency there to help you? Taxes are what we pay for a free society thank goodness the agency promotes voluntary compliance?Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  7. 7.  Eleven Divisions – Note all of this material on the IRS can be obtained at irs.gov Compliance – Four Divisions Appeals Counsel – IRS and DOJ Tax Litigation Division Taxpayer Advocate Office Equity Diversity and Inclusion Others Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  8. 8.  Businesses Starting a Business Operating a Business Closing a Business Employer ID Numbers Small Business Events Industry Professions Audit Technique Guides – Aerospace to Wine Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  9. 9.  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 Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  10. 10.  Examination  General  Estate and Gift  Classification Process  Owner Collection Counsel Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  11. 11.  ESOP’s Related for Profit Entities Gifts in Kind Services Provided Reasonable Compensation Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  12. 12.  Case Closes Out of Examination Unagreed and Goes to the Internal IRS Appeals Divisions Goal to Settle Cases 85% Target (Historically) Independent Ex Parte Rules Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  13. 13.  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 Division Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  14. 14.  At Least One in Every State –St. Paul Independent Organization to Help Taxpayers with Problems Address – economic harm, delay over 30 days, not received by date promised by the IRS Free, Confidential, Listen, Help 1-877-777-4778 or TTY/TTD 1-800-829-4059;Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  15. 15.  Formerly Equal Employment Opportunity and Diversity Mike on EEOD Advisory Counsel for the Commissioner for Four Years Promote Diversity and Address Diversity Issues Example LaterMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  16. 16.  Who Owns the Case? Who Manages the Case? Let’s Discuss Some ExamplesMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  17. 17.  SBSE Examination Case with E&G on Exam SBSE Examination Case with Counsel SBSE Case at Appeals TEGE Case with Related Entities  Credit Counseling, Reasonable Compensation  Hospitals, Physician Practices, Universities LB&I Stock Options and Stock Valuations LB&I Purchase Price AllocationsMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  18. 18. Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  19. 19.  Officially at Appeals – Hazards of Litigation  Revenue Procedure 2009-44  Fast Track Mediation• Officially with SBSE - Recommendations IRSAC Unofficially During Examination – Manager  Legally Focused  Client Based Specialists Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  20. 20.  Budget Division Chiefs Research Credit 4 Days Valuation Issue Relief From Royalty Method  Royalty Rate, Discount Rate, Time Period Reasonable Compensation EEOD Manager EmployeeMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  21. 21.  Know Who Your Working with at the IRS Understand the Role of Participants Seek to Understand Interests  Model: Facts, Issues, Feelings, Interests, Alternatives, Solutio ns either Client Based or Legally Focused Do Not Be Afraid to Ask Questions Consider Options  Ask for Appropriate Party  Ask to Elevate in Management as a Neutral Party Given Ownership of the Issue by the RA or ETA Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  22. 22.  IRS official and unofficial workings at the IRS Classification Technical Chapters on Engineering and Valuation Issues Issue Resolution and Mediation Strategic Thinking and Growth Areas for Business Valuers and Mediators Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  23. 23.  Realizing Many Issues in Corporate Tax are Gray by Design Listening to Both Parties Looking for Common Ground by Asking Questions Client Based Focus Remaining Neutral Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  24. 24. Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
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