Crm minnesota 4 27-2011

Michael Gregory
Michael 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 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

 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


 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.

 Background on IRS
 Mediation Officially at the IRS
 Some Case Examples of Conflicts
 Mediation Defined and Applied from a
Practical Perspective at the IRS
 Discussion


 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?


 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


 Businesses
 Starting a Business
 Operating a Business
 Closing a Business
 Employer ID Numbers
 Small Business Events
 Industry Professions
 Audit Technique Guides – Aerospace to Wine


 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


 Examination
 General
 Estate and Gift
 Classification Process
 Owner
 Collection
 Counsel


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


 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


 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


 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;


 Formerly Equal Employment Opportunity and
Diversity
 Mike on EEOD Advisory Counsel for the
Commissioner for Four Years
 Promote Diversity and Address Diversity
Issues
 Example Later


 Who Owns the Case?
 Who Manages the Case?
 Let’s Discuss Some Examples


 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 Allocations


 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


 Budget Division Chiefs
 Research Credit 4 Days
 Valuation Issue Relief From Royalty Method
 Royalty Rate, Discount Rate, Time Period
 Reasonable Compensation
 EEOD
 Manager Employee


 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


 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


 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


Crm minnesota 4 27-2011

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