Deputy Associate Chief Counsel

1 month ago

Washington, Washington, D.C., United States Internal Revenue Service Full time

The Deputy Associate Chief Counsel, Energy, Credits, and Excise Tax (ECE) assists the Associate Chief Counsel (ECE), in the overall executive direction of all activities and legal services provided by the ECE Associate Office.

The Associate Office (ECE) is comprised of approximately 40 attorneys, tax law specialists, and support employees in Washington, D.C.; and provides legal advisory services that support the uniform interpretation, application, enforcement, and litigation of tax laws involving a wide range of tax matters, focused on the taxation of oil and gas and other natural resources, business and energy-related tax credits, and excise taxes.

As the Deputy Associate Chief Counsel (ECE), the incumbent of this position:

Serves as a full Deputy to the Associate Chief Counsel (ECE) in providing executive direction on all matters within the Office's jurisdiction, including delegated authority for signature on all matters on which the Associate has authority and shares responsibility with the Associate for the direction and oversight of the Counsel-wide litigation program involving the taxation of oil and gas and other natural resources, business and energy-related tax credits and excise taxes.

As assigned, acts as Acting Associate Chief Counsel (ECE) with full authority to make decisions on any problems arising in the administration of the Office and its programs.

Consistent with the Chief Counsel Directives Manual, assists in the formulation and direction of programs and policies with respect to litigation involving the taxation of oil and gas and other natural resources, business and energy-related tax credits, and excise taxes in the U.S.

Tax Court.

Except with respect to certiorari matters, in consultation with the Division Counsel and the Associate Chief Counsel, approves recommendations of acquiescence and no acquiescence in adverse decisions and orders in such cases and suits and makes recommendations to the Department of Justice (DOJ) regarding appeals, offers in compromise, or settlements in such cases or suits pending on appeal.

Supports the Associate in ensuring IRS-wide consistency of approach in tax litigation and advice involving these issues; consults with the Division Counsel as to the defense or settlement of cases pending in U.S.

Tax Court and, together with the Associate Chief Counsel (ECE) reviews and coordinates pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S.

Tax Court litigation involving the taxation of oil and gas and other natural resources, business and energy-related tax credits, and excise taxes.

Assists in the direction and preparation of recommendations concerning defense, settlement, or concession.

Assists in the executive direction to staff engaged in drafting revenue rulings, revenue procedures, announcements, and news releases to be published for the guidance of taxpayers and IRS personnel; the issuance of technical advice memoranda responding to questions raised by IRS examiners; issuance of private letter rulings and general technical information letters in response to requests from taxpayers; and preparation of Chief Counsel Advice and other legal opinions for other Chief Counsel offices and IRS functions with respect to legal questions raised in litigation and IRS programs.

In collaboration with Associate Chief Counsel, works with Treasury officials to coordinate recommendations for legislation that particularly affect matters involving the taxation of oil and gas and other natural resources, business and energy-related tax credits, and excise taxes; assists in the direction of IRS participation in this aspect of the legislative process, including the furnishing of advice and guidance with respect to the development of new or revised legislative proposals; and assists in the oversight of IRS participation with legislative staffs in the drafting of such legislation and committee reports.

Assists in the coordination of the processing and review of nondocketed cases submitted for consideration by various local, area, division, or national levels.

Renders legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning the taxation of oil and gas and other natural resources, business and energy-related tax credits, and excise tax matters under examination in the audit of returns, or in the consideration of claims for refund.

Assists in the development and monitoring of performance measures and program goals for the provision of legal services and published guidance, and the implementation, compliance, and outreach initiatives on issues involving the taxation of oil and gas and other natural resources, business and energy-related tax credits, and excise taxes.

Ensures that performance and program goals, strategy, and organizational policies are clearly communicated to employees.

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