Partner Tom Linguanti spoke with Tax Notes about the Internal Revenue Service’s (IRS’s) strategy of focusing enforcement efforts on specific areas, providing examples of issues this may cause—including transfer pricing cases being held up while revenue agents look for intercompany services because of the IRS’s focus on this matter—meaning issues that should be resolved on audit instead have to be elevated. But by focusing on high-risk noncompliance areas, the IRS is both carefully allocating resources that Congress has made scarce and giving taxpayers valuable information for their own resource allocations, Tom explained.
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