The Internal Revenue Service (IRS) has issued a number of internal directives to staff instructing employees on procedures and making allowances for taxpayers adversely affected by the coronavirus.  

On April 2, 2020, the Tax Exempt/Government Entities (TE/GE) Division instructed its staff to ease enforcement of its existing Information Document Request (IDR) procedures effective through July 15, 2020. "The temporary deviation relaxes the more rigid timelines...that would otherwise result in enforcement actions due to untimely or incomplete IDR responses," the TE/GE directive explains. "This memorandum allows an increased reasonable application of business judgement by examination agents and managers in the exercise of duties related to IDR requests and follow-ups."

The text of the TE/GE memorandum is posted here.

In a similar move, the Large Business and International (LB&I) Division late last month issued a temporary reprieve from its Information Document Request (IDR) enforcement process as outlined in IRM Exhibit 4.46.4-2. In a memorandum to LB&I employees, the IRS notes that its IDR procedures are suspended through July 15, 2020. It explains that examiners can continue issuing and receiving certain IDRs and that "managers retain the discretion to continue with the IDR enforcement process when in their judgment the interests of tax administration warrant, for example for cases with short statutes, listed transactions or fraud development." 

The text of the LB&I directive is posted here.

​The IRS also announced last week that all public hearings on proposed rulemakings will be held by phone until further notice. The text of IRS Announcement 2020-04 is posted here.

Additional IRS and Treasury Department guidance issued in response to the coronavirus is posted in our Resource Library described below.

Miller & Chevalier Coronavirus Task Force
The outbreak of COVID-19 is creating significant business and legal challenges for companies throughout the world. In response to client demand, the firm has formed an interdisciplinary task force to help businesses navigate these issues.

COVID-19 Resource Library
We also maintain a resource library of legislative responses and regulatory guidance related to COVID-19.

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