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Tax Litigation

34.1.1  Organization of General Litigation Division

The following is the organization of the General Litigation Division and its branches responsibilities.

34.1.1.1  (08-23-1988)
General Litigation Division

  1. This section sets forth the organization of the General Litigation Division and the responsibilities of its branches. The delegations of authority from the Chief Counsel to the Director, General Litigation Division, and to Regional Counsel for general litigation matters are contained in CCDM 30.3.1.
  2. General Litigation Division
    1. The General Litigation Division is composed of the Director, Assistant Director, Assistant to the Director, two Technical Assistants, and three Branch Chiefs.
    2. The division is divided into three branches with each branch exercising primary responsibility for all of the division's activities with respect to certain geographic regions. Each branch is also allocated some responsibility for giving legal advice to National Office functions. The final work product of a branch is sent above the division level only when appropriate or necessary.
    3. The division's activities may encompass giving legal advice concerning suit, defense, appeal recommendations, and advisory opinions on the following subject matters:
      1. proceedings under the Bankruptcy Act and the Bankruptcy Code;
      2. general receiverships;
      3. decedents' and incompetents' estates;
      4. other types of insolvencies;
      5. erroneous refunds;
      6. actions on bonds;
      7. actions to open safe deposit boxes;
      8. establishing fiduciary liability under 31 U.S.C. § 3713(a) and (b); asserting priority under 31 U.S.C. § 3713;
      9. actions by the U.S. to quiet title;
      10. I.R.C. § 3505 suits, Miller Act, etc.;
      11. actions asserting 100 percent penalty liability under I.R.C. § 6672;
      12. delinquent revenue employees—I.R.C. § 7803(d);
      13. liability of banks on checks—I.R.C. § 6311(b)(2);
      14. forfeiture cases;
      15. injunctions;
      16. summons enforcement;
      17. mandamus;
      18. declaratory judgment actions not authorized by Title 26;
      19. wrongful levy;
      20. review of jeopardy and termination assessments;
      21. centralized court cases;
      22. tax return preparers;
      23. reducing tax claims to judgment;
      24. foreclosure of tax lien;
      25. setting aside a fraudulent conveyance;
      26. establishing transferee liability;
      27. enforcing a levy;
      28. all actions under 28 U.S.C. § 2410;
      29. intervention; and
      30. offers in compromise.

       

    4. The division will be responsible for all interpretative work relating to general litigation matters.
    5. The division will be responsible for all legislation and regulation work relating to general litigation matters.

     

  3. Branch Responsibility. All work transmitted from regions will be reviewed and processed as follows:
    1. Branch No. 1 North-Atlantic and Southwest Regions
    2. Branch No. 2 Western and Mid-Atlantic Regions
    3. Branch No. 3 Central, Midwest, and Southeast Region

 

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