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IRS Divisions and Risk     Management ©        Michael GregoryMichael Gregory Consulting LLC for  NACVA CPE December 2, 2011
Presenter• Michael Gregory, Chief Manager, Michael  Gregory Consulting LLC since September  12, 2011• Formerly IRS 28 Year...
Michael Gregory Consulting LLC•   Risk Management•   Alternative Dispute Resolution•   Will Go Over Some Examples•   Could...
Disclaimer• The opinions presented here are those of Michael  Gregory. Michael Gregory does not represent the  IRS. Any op...
IRS            Michael Gregory Consulting LLC12/2/2011                                    5                 www.mikegreg.com
IRS•   Eleven Divisions•   Compliance – Four Divisions•   Appeals•   Counsel – IRS and DOJ Tax Litigation Division•   Your...
IRS.gov•   Businesses•   Starting a Business•   Operating a Business•   Closing a Business•   Employer ID Numbers•   Small...
Large Business and International• Six Industries and One Support Function• CTM, FS, HMT, NRC, RFPH, GHW,• Field Specialist...
Engineering and Valuation•   Internal Consultants to All Divisions•   Four Territory Managers•   32 Managers•   320 Techni...
Small Business and Self Employed• Examination      – General      – Estate and Gift            • Classification Process   ...
Tax Exempt and Governmental Entities•   ESOP’s•   Related for Profit Entities•   Gifts in Kind•   Services Provided•   Rea...
Appeals• Case Closes Out of Examination Unagreed and  Goes to the Internal IRS Appeals Divsions• Goal to Settle Cases• 85%...
Counsel• IRS Office of Chief Counsel      – Appointed by the President            • Operations            • Technical     ...
Let’s Have Some Fun                 Michael Gregory Consulting LLC12/2/2011                                         14    ...
What Do You Think?•   Who Owns the Case?•   Who Manages the Case?•   What is the Role of the Valuer?•   Let’s Discuss Some...
Discuss Some Examples•   SBSE Examination Case with E&G on Exam•   SBSE Examination Case with Counsel•   SBSE Case with DO...
Discuss Some Examples Continued•   LB&I 409A•   LB&I Stock Options and Stock Valuations•   LB&I Purchase Price Allocations...
Important Take Away Information•   Know Who Your Working with at the IRS•   Understand the Role of Participants•   Seek to...
What Are Your Thoughts and                    Questions                    Michael Gregory Consulting LLC12/2/2011        ...
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Nacva december 2, 2011 presenation

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Presentation to NACVA
Plymouth, MN
December 2, 2011

This presentation presents how the IRS is organized and offers several examples of how to work with the IRS

Published in: Business, Economy & Finance
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Nacva december 2, 2011 presenation

  1. 1. IRS Divisions and Risk Management © Michael GregoryMichael Gregory Consulting LLC for NACVA CPE December 2, 2011
  2. 2. 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 Michael Gregory Consulting LLC12/2/2011 2 www.mikegreg.com
  3. 3. Michael Gregory Consulting LLC• Risk Management• Alternative Dispute Resolution• Will Go Over Some Examples• Could be of Service to You and Your Clients• mg@mikegreg.com• 651-633-5311 Michael Gregory Consulting LLC12/2/2011 3 www.mikegreg.com ©
  4. 4. 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. Michael Gregory Consulting LLC12/2/2011 4 www.mikegreg.com
  5. 5. IRS Michael Gregory Consulting LLC12/2/2011 5 www.mikegreg.com
  6. 6. IRS• Eleven Divisions• Compliance – Four Divisions• Appeals• Counsel – IRS and DOJ Tax Litigation Division• Your Primary Interest as Valuers – LB&I – SBSE – TEGE Michael Gregory Consulting LLC12/2/2011 6 www.mikegreg.com
  7. 7. 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 Wine Michael Gregory Consulting LLC12/2/2011 7 www.mikegreg.com
  8. 8. 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 Michael Gregory Consulting LLC12/2/2011 8 www.mikegreg.com
  9. 9. 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 Michael Gregory Consulting LLC12/2/2011 9 www.mikegreg.com
  10. 10. Small Business and Self Employed• Examination – General – Estate and Gift • Classification Process • Owner• Collection• Counsel Michael Gregory Consulting LLC12/2/2011 10 www.mikegreg.com
  11. 11. Tax Exempt and Governmental Entities• ESOP’s• Related for Profit Entities• Gifts in Kind• Services Provided• Reasonable Compensation Michael Gregory Consulting LLC12/2/2011 11 www.mikegreg.com
  12. 12. 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 Michael Gregory Consulting LLC12/2/2011 12 www.mikegreg.com
  13. 13. 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 Division Michael Gregory Consulting LLC12/2/2011 13 www.mikegreg.com
  14. 14. Let’s Have Some Fun Michael Gregory Consulting LLC12/2/2011 14 www.mikegreg.com
  15. 15. 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 Michael Gregory Consulting LLC12/2/2011 15 www.mikegreg.com
  16. 16. 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 Michael Gregory Consulting LLC12/2/2011 16 www.mikegreg.com
  17. 17. Discuss Some Examples Continued• LB&I 409A• LB&I Stock Options and Stock Valuations• LB&I Purchase Price Allocations• 6695A Appraiser Penalties Michael Gregory Consulting LLC12/2/2011 17 www.mikegreg.com
  18. 18. 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 Michael Gregory Consulting LLC12/2/2011 18 www.mikegreg.com
  19. 19. What Are Your Thoughts and Questions Michael Gregory Consulting LLC12/2/2011 19 www.mikegreg.com

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