General Attorney

3 weeks ago

Washington, United States Internal Revenue Service Full time

The Office of the Associate Chief Counsel (Passthroughs and Special Industries) provides legal advice, litigation services, and litigation support on tax matters involving passthrough entities, the classification of entities, passive activity losses, excise taxes, estate and gift taxes, oil and gas and other natural resources, at-risk rules, and tax credits to the Internal Revenue Service, the Office of Chief Counsel, the Department of Justice, Treasury, and where appropriate or required, to other government agencies and the public.

As Senior Technician Reviewer, the incumbent is responsible for some of the most complicated, difficult, and unusual assignments and projects in Passthroughs and Special Industries. In consultation with the Branch Chief, the Senior Technician Reviewer is responsible for the assignment of selected cases and projects to the attorneys within the Branch and for review of the work products. The primary work of the Branch involves developing and considering recommendations for enactment of Internal Revenue legislation and the promulgating published guidance (regulations, revenue rulings, and revenue procedures) preparing of private letter rulings, technical advice memoranda, and other written legal advice based on tax issues submitted by taxpayers and their representatives, state and federal agencies, and other Chief Counsel and IRS offices.

In addition, the Branch performs activities in the assigned subject area including providing legal assistance and advice to trial attorneys in the field in connection with actions on decisions, preparation of briefs, handling of unusual technical problems, preparation for the trial of cases involving complicated technical issues, and appeal recommendations in Tax Court and refund cases. Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere. Problems presented cover a broad range involving numerous questions requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases and other technical materials.

As a General Attorney (Tax) Senior Technician Reviewer, you will:

Act as a legal and technical consultant to the Branch Chief, Deputy Associate Chief Counsel, Associate Chief Counsel, and to other officials in the Office of Chief Counsel on the legal and policy matters concerned with the work of the Branch, or which may affect the work of other branches of the office, or other components of the Office of Chief Counsel. These matters involve the Senior Technical Reviewer in detailed and extensive research on complicated legal problems, and the development of recommendations as to the positions to be taken by the Branch and the Office.
Act as a reviewer, and in some cases as the initiating attorney, for assignments and projects involving the development and drafting of Internal Revenue legislation and regulations, considering recommendations for enactment of legislation and the promulgation of regulations, private letter rulings, revenue rulings, technical advice memoranda, and other advice memoranda dealing with tax problems submitted by taxpayers and their representatives, state and federal agencies, and other Chief Counsel and IRS offices.
Act as principal attorney in charge of recommending the policies and developing the procedures and regulations implementing new or amended legislation for specific areas of tax law and be responsible for ensuring that these policies, procedures, and regulations are consistent with the intent of the law and are administratively sound, efficient, and economical in operations.
Mentor, train, and develop attorneys in the technical subjects of the Branch and the day-today workflow of the organization and the IRS.
Perform activities in the subject area of the Branch including legal assistance, document review, appellate recommendations, and litigation support. Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere. Problems presented cover a broad range of tax law issues involving numerous questions requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases and other technical materials.
Make recommendations on the need for initiating, consolidating, or eliminating projects. Act as project manager, assign (in consultation with the Branch Chief) work to the attorneys within the Branch, advise them on the approach to take, review work products, and provide the Branch Chief with performance feedback on work performed.
This is not an all-inclusive list.

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