In internal guidance to employees, the IRS LB&I Division announced that it will no longer manage issues through the Tiered Issue Process. In place of the Tiered Issue Process, LB&I is developing a knowledge management network through the use of Issue Practice Groups (IPGs) for domestic issues and International Practice Networks (IPNs) for international issues. IPGs and IPNs are designed to provide examination teams with the technical advice they need to manage their cases efficiently, consistently and with a high degree of technical proficiency. The Tiered Issue Process has been in use since 2006.
Large Business & International Division Memorandum: Tiered Issues, LB&I-4-0812-010, 2012FED ¶46,438
Other References:
Code Sec. 7804
CCH Reference – 2012FED ¶43,266.3184
Tax Research Consultant
CCH Reference – TRC IRS: 3,106
