Deputy Associate Chief Counsel

2 weeks ago

Washington, United States US Internal Revenue Service Full time

**Duties**:
The Deputy Associate Chief Counsel (Guidance), PSI, serves as one of two principal advisors to the Associate Chief Counsel (PSI), the Internal Revenue Service (IRS), and the Office of Chief Counsel on all matters relating to the Passthroughs and Special Industries organization. Assists the Associate Chief Counsel (PSI), who is responsible for coordinating and directing all activities of the PSI organizational component of the IRS, Office of Chief Counsel. Provides executive leadership and management on the issuance of published and other technical guidance. Assists the Associate in implementing and overseeing guidance aimed at improving compliance and reducing tax abuses by partnerships and high net worth individuals, and shares responsibility with the Associate, the Deputy Associate, and Division Counsel for the direction and oversight of the Counsel-wide litigation program involving passthroughs and special industries matters. The incumbent works closely with Treasury officials and IRS Division Commissioners, PSI's other Deputy Associate Chief Counsel, and other Associate and Division Counsel on program matters (e.g., identifying and prioritizing emerging issues and published guidance needs).

**As a Deputy Associate Chief Counsel (Guidance), the incumbent of this position**:

- Assists the Associate in representing the IRS and Treasury on sensitive and controversial issues, including as they relate to published and other technical guidance. Has delegated authority to act as a full assistant, including authority to sign on behalf of the Associate Chief Counsel (PSI).
- Assists and acts for the Associate Chief Counsel (PSI) in the overall executive direction to staff engaged in drafting revenue rulings, revenue procedures, notices, announcements, and news releases to be published for the guidance of taxpayers and IRS personnel; issuing technical advice memoranda responding to questions raised by IRS examiners; issuing private letter rulings and general technical information letters in response to requests from taxpayers; and preparing 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. Has delegated authority to act as a full assistant, including authority to sign finally on matters falling within assigned program responsibilities.
- Assists the Associate and the Division Counsel, consistent with the Chief Counsel Directives Manual, in formulating and directing programs and policies with respect to litigation of PSI issues in the U.S. Tax Court consistent with the Chief Counsel Directives Manual. Assures IRS-wide consistency of approach in PSI tax litigation; prepares and approves Chief Counsel Actions on Decision; consults with the Division Counsel as to the defense or settlement of PSI cases pending in U.S. Tax Court and, together with the Division Counsel, reviews and coordinates pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving passthroughs and special industries.
- Except with respect to certiorari matters, in consultation with the Division Counsel and the Associate, 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. In consultation with the Division Counsel and the Associate, directs preparation of recommendations concerning defense, settlement, or concession, and authorizes or sanctions counterclaims, third-party complaints, or the commencement of collection suits with respect to refund suits pending in PSI cases in the U.S. District Courts or the Court of Federal Claims. Coordinates appellate and certiorari litigation with the Chief Counsel and Commissioner of Internal Revenue, as appropriate.
- Assists the Associate in coordinating 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 passthroughs and special industries issues under examination in the audit of returns, or in the consideration of claims for refund.
- Participates with the Associate in developing and monitoring performance measures and program goals for the provision of legal services and published guidance, and the implementation, compliance, and outreach initiatives on passthroughs and special industries issues. Ensures that performance and program goals, strategy, and organizational policies are clearly communicated to employees.

**Requirements**:
**Conditions of Employment**:

- Refer to "Additional Information"
- Click "Print Preview" to review the entire announcement before applying.
- Must be a U.S. Citizen or Nationa

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