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George Hani Quoted in Tax Notes Regarding LMSB Guidance on Tier Status of Settlements

Subtitle
"LMSB Backtracks on Tier Status of Settlements"

Tax Notes

George Hani is quoted in an article discussing the IRS' clarification in a November 13 Web posting. In that posting, the IRS stated that government settlements have not been removed as a Tier I issue but rather are on monitored status instead of active coordination; this is a revision to an October 3 IRS Large and Midsize Business Division memorandum that stated government settlements had been taken off the Tier I list and moved to Tier II. Hani said that despite this news, he expects that there is even more coordination of the issue than before given the time the IRS has had to develop its issue strategy. "There is likely less flexibility now for revenue agents to handle these cases," he said, characterizing the applicable procedures as "on autopilot."