Law360, New York (June 25, 2014, 4:17 PM EDT) -- The new Large Business & International (LB&I) information document request (IDR) operating procedures, outlined in a series of directives released within the last year,[1] have generated a tepid response from taxpayers and practitioners. Many suggest that the new approach will foster increased acrimony in the audit process and will ineluctably lead, in many if not most circumstances, to summons enforcement proceedings. The most recent directive, LB&I-04-0214-004 (Feb. 28, 2014), however, improves upon the perceived defects of the new IDR procedures, offering taxpayers opportunities to maneuver within the constraints of the regime and to respond to IDRs before and during escalation in the enforcement process....
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