83 FR 13206 - Certain Non-Government Attorneys Not Authorized To Participate in Examinations of Books and Witnesses as a Section 6103(n) Contractor
DEPARTMENT OF THE TREASURY
Internal Revenue Service Federal Register Volume 83, Issue 60 (March 28, 2018)
Internal Revenue Service
Federal Register Volume 83, Issue 60 (March 28, 2018)
| Page Range | 13206-13208 | |
| FR Document | 2018-06242 |
[Federal Register Volume 83, Number 60 (Wednesday, March 28, 2018)] [Proposed Rules] [Pages 13206-13208] From the Federal Register Online [www.thefederalregister.org] [FR Doc No: 2018-06242] ======================================================================== Proposed Rules Federal Register ________________________________________________________________________ This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules. ======================================================================== Federal Register / Vol. 83, No. 60 / Wednesday, March 28, 2018 / Proposed Rules [[Page 13206]] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 301 [REG-132434-17] RIN 1545-B012 Certain Non-Government Attorneys Not Authorized To Participate in Examinations of Books and Witnesses as a Section 6103(n) Contractor AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. ----------------------------------------------------------------------- SUMMARY: This document contains proposed regulations to amend regulations under section 7602(a) of the Internal Revenue Code relating to administrative proceedings. Current regulations permit any person authorized to receive returns and return information under section 6103(n) and the regulations thereunder to receive and review summoned books, papers, and other data, and, in the presence and under the guidance of an IRS officer or employee, participate fully in the interview of a witness in a summons interview. These proposed regulations significantly narrow the scope of the current regulations by excluding non-government attorneys from receiving summoned books, papers, records, or other data or from participating in the interview of a witness summoned by the IRS to provide testimony under oath, with a limited exception. These proposed regulations affect taxpayers involved in a federal tax examination and other persons whose books and records or testimony are sought to be examined by the IRS under section 7602(a). DATES: Written or electronic comments and requests for a public hearing must be received by June 26, 2018. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-132434-17), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG- 132434-17), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC, or sent electronically via the Federal eRulemaking Portal at www.regulations.gov (IRS-REG-132434-17). FOR FURTHER INFORMATION CONTACT: Concerning submission of comments, Regina Johnson, (202) 317-6901; concerning the proposed regulations, William V. Spatz at (202) 317-5461 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background These proposed regulations amend Procedure and Administration Regulations (26 CFR part 301) under section 7602(a) of the Internal Revenue Code relating to participation by persons described in section 6103(n) and Treas. Reg. Sec. 301.6103(n)-1(a) in receiving and reviewing summoned books, papers, records, or other data and in interviewing a summoned witness under oath. These proposed regulations narrow the scope of the current regulations by providing that certain non-government attorneys hired by the IRS are not authorized to participate in an examination. On June 18, 2014, temporary regulations (TD 9669) regarding participation in a summons interview of a person described in section 6103(n) were published in the Federal Register (79 FR 34625). A notice of proposed rulemaking (REG-121542-14) cross-referencing the temporary regulations was published in the Federal Register (79 FR 34668) the same day. No public hearing was requested or held. The Internal Revenue Service received two comments on the proposed regulations. One comment recommended that the regulations be revised to remove the provision permitting a contractor to question a witness under oath or to ask a witness's representative to clarify an objection or assertion of privilege. The other comment recommended that the proposed and temporary regulations be withdrawn. After consideration of these comments, the proposed regulations were adopted in final regulations (TD 9778) published in the Federal Register (81 FR 45409) on July 14, 2016 (``Summons Interview Regulations''). The only change from the temporary regulations in the final regulations was to replace the word ``examine'' with ``review'' in the phrase describing what contractors may do with books, papers, records, or other data received by the IRS under a summons. The preamble to the final regulations explains that this was intended to clarify that the regulations do not authorize contractors to direct audits of a taxpayer's return. See 81 FR 45410. Description of Summons Interview Regulations The United States tax system relies upon taxpayers' self-assessment and reporting of their tax liability. The expansive information- gathering authority that Congress granted to the IRS under the Code includes the IRS's broad examination and summons authority, which allows the IRS to determine the accuracy of that self-assessment. See United States v. Arthur Young & Co., 65 U.S. 805, 816 (1984). Section 7602(a) provides that, for the purpose of ascertaining the correctness of any return, making a return where none has been made, or determining the liability of any person for any internal revenue tax, the IRS is authorized to examine books and records, issue summonses seeking documents and testimony, and take testimony from witnesses under oath. These provisions have been part of the revenue laws since 1864. Use of outside specialists is appropriate to assist the IRS in determining the correctness of the taxpayer's self-assessed tax liability. The assistance of persons from outside the IRS, such as economists, engineers, appraisers, industry specialists, and actuaries, promotes fair and efficient administration and enforcement of the laws administered by the IRS by providing specialized knowledge, skills, or abilities that the IRS officers or employees assigned to the examination may not possess. Section 6103(n) and Treas. Reg. Sec. 301.6103(n)-1(a) authorize the IRS to disclose returns and return information to these contractors. The regulations under Sec. 301.7602- 1(b)(3) were issued to clarify that persons described in section 6103(n) and Treas. Reg. Sec. 301.6103(n)-1(a) may receive and review books, papers, records, or other data summoned by the IRS and, in the presence and under the guidance of an [[Page 13207]] IRS officer or employee, participate fully in the interview of a person who the IRS has summoned as a witness to provide testimony under oath. See 81 FR 45410. Executive Order 13789, Notice 2017-38, and the Reports to the President Executive Order 13789, issued on April 21, 2017 (E.O. 13789, 82 FR 19317), instructs the Secretary of the Treasury (the Secretary) to review all significant tax regulations issued on or after January 1, 2016, and to take appropriate action to alleviate the burdens of regulations that (i) impose an undue financial burden on U.S. taxpayers; (ii) add undue complexity to the Federal tax laws; or (iii) exceed the statutory authority of the IRS. E.O. 13789 further instructs the Secretary to submit to the President within 60 days a report (First Report) that identifies regulations that meet these criteria. Notice 2017-38 (2017-30 I.R.B. 147 (July 24, 2017)) included the Summons Interview Regulations in a list of eight regulations identified by the Secretary in the First Report as meeting at least one of the first two criteria specified in E.O. 13789. E.O. 13789 further instructs the Secretary to submit to the President a second report (Second Report) that recommends specific actions to mitigate the burden imposed by regulations identified in the First Report. In response to Notice 2017-38, the Treasury Department and the IRS received seven comments from professional and business associations addressing the Summons Interview Regulations. All but one of these comments recommended removal of the regulations based primarily on the commentators' perception that the regulations create longer and less efficient examinations by improperly delegating authority to outside law firms to conduct examinations. The one commenter that did not recommend removal of the regulations in their entirety requested removal of the provisions permitting a contractor to directly question a witness during a summons interview. As explained in the preamble to the final Summons Interview Regulations, the regulations do not delegate authority to conduct examinations or summons interviews. Rather, the regulations permit contractors authorized under section 6103(n) to review books and records and be present and ask questions during summons interviews, all under the supervision of IRS officers and employees. See 81 FR 45410- 45412. Comments in response to Notice 2017-38 also raised concerns that the regulations permit the IRS to hire law firms to receive and review summoned information and fully participate in a summons interview on behalf of the government. On October 16, 2017, the Secretary published the Second Report in the Federal Register (82 FR 48013) stating that the Treasury Department and the IRS are considering proposing a prospectively effective amendment to the Summons Interview Regulations to narrow their scope to prohibit non-government attorneys from questioning witnesses on behalf of the IRS, reviewing summoned records, or playing a behind-the-scenes role in an examination, such as consulting on IRS legal strategy, with a limited exception. The Code provides IRS officers and employees with significant and broad powers under its summons authority to question witnesses under oath and to require the production of books and records. The Summons Interview Regulations require the IRS to retain authority over important decisions when section 6103(n) contractors question witnesses, but there is a perceived risk that the IRS may not be able to maintain full control over the actions of a non-government attorney hired by the IRS when such an attorney, with the limited exception described below, questions witnesses. The actions of the non- governmental attorney while questioning witnesses could foreclose IRS officials from independently exercising their judgment. Managing an examination or summons interview is therefore best exercised solely by government employees, including government attorneys, whose only duty is to serve the public interest. These concerns outweigh the countervailing need for the IRS to use non-government attorneys, except in the limited circumstances set forth in proposed paragraph (b)(3)(ii). Treasury and the IRS remain confident that the core functions of questioning witnesses and conducting examinations are well within the expertise and ability of government attorneys and examination agents. Explanation of Provisions Proposed Sec. 301.7602-1(b)(3)(i) retains the rule from the Summons Interview Regulations authorizing section 6103(n) contractors to receive and review summoned information and fully participate in the summons interview, including questioning witnesses. However, proposed Sec. 301.7602-1(b)(3)(ii) is added to prohibit contractors who are attorneys, with the limited exception described below, from participating in the administrative process contemplated by section 7602(a). Under this prohibition, a non-government attorney, with the limited exception described below, may not review summoned books, papers, records or other data or question summoned witnesses on behalf of the IRS unless the attorney is hired by the IRS for a permitted purpose. As a limited exception to that prohibition, proposed Sec. 301.7602-1(b)(3)(ii) permits the IRS to hire a non-government attorney if the attorney is being hired for specialized substantive subject matter expertise in an area other than federal tax law. Specifically, proposed Sec. 301.7602-1(b)(3)(ii) permits the IRS to hire an attorney who has specialized knowledge of foreign, state, or local law, including tax law, or who is a specialist in non-tax substantive law such as patent law, property law, or environmental law. It would not permit IRS to hire an attorney for non-substantive specialized knowledge, such as civil litigation skills. Proposed Sec. 301.7602- 1(b)(3)(ii) also permits the IRS to hire a contractor who may happen to be an attorney, but who is hired for knowledge, skills, or abilities other than providing legal services as an attorney. Further, proposed Sec. 301.7602-1(b)(3)(ii) permits the IRS to hire an entity that employs or is owned by attorneys so long as the expertise they are providing is not prohibited by proposed Sec. 301.7602-1(b)(3)(ii). These changes are proposed to be effective for examinations begun and summonses served by the IRS on or after the date that these proposed regulations are published in the Federal Register. Special Analyses Certain IRS regulations, including these, are exempt from the requirements of Executive Order 12866, as supplemented and affirmed by Executive Order 13563. Therefore, a regulatory assessment is not required. Because the proposed regulations would not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Therefore, a regulatory flexibility analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the IRS will submit the proposed regulations to the Chief Counsel for Advocacy of the Small Business Administration for comments about the regulations' impact on small businesses. Comments and Request for a Public Hearing Before these proposed regulations are adopted as final, the IRS will consider any written (signed original and 8 [[Page 13208]] copies) or electronic comments timely submitted. The IRS requests comments on all aspects of these proposed regulations. All comments will be available for public inspection and copying. The IRS will schedule a public meeting if one is requested, in writing, by a person who submits written comments. If the IRS does schedule a public hearing, the IRS will publish notice of the date, time, and place for the public hearing in the Federal Register. Drafting Information The principal author of these regulations is William V. Spatz of the Office of Associate Chief Counsel (Procedure and Administration). List of Subjects in 26 CFR Part 301 Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income taxes, Penalties, Reporting and recordkeeping requirements. Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is proposed to be amended as follows: PART 301--PROCEDURE AND ADMINISTRATION 0 Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * 0 Par. 2. Section 301.7602-1 is amended by revising paragraphs(b)(3) and (d) to read as follows: Sec. 301.7602-1 Examination of books and witnesses. * * * * * (b) * * * (3) Participation of a person described in section 6103(n). (i) In general. Except as provided in paragraph (b)(3)(ii) of this section, for purposes of this paragraph (b), a person authorized to receive returns or return information under section 6103(n) and Sec. 301.6103(n)-1(a) of the regulations may receive and review books, papers, records, or other data produced in compliance with a summons, and, in the presence and under the guidance of an IRS officer or employee, participate fully in the interview of a witness summoned by the IRS to provide testimony under oath. Fully participating in an interview includes, but is not limited to, receipt, review, and use of summoned books, papers, records, or other data; being present during summons interviews; and questioning the person providing testimony under oath. (ii) Exception for certain non-governmental attorneys. An attorney who is not an officer or employee of the United States may not be hired by the IRS to perform the activities described in paragraph (b)(3)(i) of this section unless the attorney is hired by the IRS as a specialist in foreign, state, or local law, including tax law, or in non-tax substantive law that is relevant to an issue in the examination, such as patent law, property law, or environmental law, or is hired for knowledge, skills, or abilities other than providing legal services as an attorney. * * * * * (d) Applicability date. This section is applicable after September 3, 1982, except for paragraphs (b)(1) and (2) of this section which are applicable on and after April 1, 2005 and paragraph (b)(3) of this section which applies to examinations begun or administrative summonses served by the IRS on or after March 27, 2018. For rules under paragraphs (b)(1) and (2) of this section that are applicable to summonses issued on or after September 10, 2002 or under paragraph (b)(3) of this section that are applicable to summons interviews conducted on or after June 18, 2014 and before July 14, 2016, see 26 CFR 301.7602-1T (revised as of April 1, 2016). For rules under paragraph (b)(3) of this section that are applicable to administrative summonses served by the IRS before March 27, 2018, see 26 CFR 301.7602- 1 (revised as of April 1, 2017). Kirsten Wielobob, Deputy Commissioner for Services and Enforcement. [FR Doc. 2018-06242 Filed 3-27-18; 8:45 am] BILLING CODE 4830-01-P
![13206
Proposed Rules Federal Register
Vol. 83, No. 60
Wednesday, March 28, 2018
This section of the FEDERAL REGISTER Washington, DC 20044. Submissions The only change from the temporary
contains notices to the public of the proposed may be hand-delivered Monday through regulations in the final regulations was
issuance of rules and regulations. The Friday between the hours of 8 a.m. and to replace the word ‘‘examine’’ with
purpose of these notices is to give interested 4 p.m. to CC:PA:LPD:PR (REG–132434– ‘‘review’’ in the phrase describing what
persons an opportunity to participate in the 17), Courier’s Desk, Internal Revenue contractors may do with books, papers,
rule making prior to the adoption of the final
rules.
Service, 1111 Constitution Avenue NW, records, or other data received by the
Washington, DC, or sent electronically IRS under a summons. The preamble to
via the Federal eRulemaking Portal at the final regulations explains that this
DEPARTMENT OF THE TREASURY www.regulations.gov (IRS–REG– was intended to clarify that the
132434–17). regulations do not authorize contractors
Internal Revenue Service FOR FURTHER INFORMATION CONTACT: to direct audits of a taxpayer’s return.
Concerning submission of comments, See 81 FR 45410.
26 CFR Part 301 Regina Johnson, (202) 317–6901; Description of Summons Interview
[REG–132434–17]
concerning the proposed regulations, Regulations
William V. Spatz at (202) 317–5461 (not
RIN 1545–B012 toll-free numbers). The United States tax system relies
SUPPLEMENTARY INFORMATION: upon taxpayers’ self-assessment and
Certain Non-Government Attorneys reporting of their tax liability. The
Not Authorized To Participate in Background expansive information-gathering
Examinations of Books and Witnesses These proposed regulations amend authority that Congress granted to the
as a Section 6103(n) Contractor Procedure and Administration IRS under the Code includes the IRS’s
Regulations (26 CFR part 301) under broad examination and summons
AGENCY: Internal Revenue Service (IRS),
section 7602(a) of the Internal Revenue authority, which allows the IRS to
Treasury.
Code relating to participation by determine the accuracy of that self-
ACTION: Notice of proposed rulemaking. assessment. See United States v. Arthur
persons described in section 6103(n)
and Treas. Reg. § 301.6103(n)–1(a) in Young & Co., 65 U.S. 805, 816 (1984).
SUMMARY: This document contains
receiving and reviewing summoned Section 7602(a) provides that, for the
proposed regulations to amend
books, papers, records, or other data and purpose of ascertaining the correctness
regulations under section 7602(a) of the
in interviewing a summoned witness of any return, making a return where
Internal Revenue Code relating to
under oath. These proposed regulations none has been made, or determining the
administrative proceedings. Current
narrow the scope of the current liability of any person for any internal
regulations permit any person
regulations by providing that certain revenue tax, the IRS is authorized to
authorized to receive returns and return
non-government attorneys hired by the examine books and records, issue
information under section 6103(n) and
IRS are not authorized to participate in summonses seeking documents and
the regulations thereunder to receive
an examination. testimony, and take testimony from
and review summoned books, papers,
On June 18, 2014, temporary witnesses under oath. These provisions
and other data, and, in the presence and
regulations (TD 9669) regarding have been part of the revenue laws since
under the guidance of an IRS officer or
participation in a summons interview of 1864.
employee, participate fully in the
interview of a witness in a summons a person described in section 6103(n) Use of outside specialists is
interview. These proposed regulations were published in the Federal Register appropriate to assist the IRS in
significantly narrow the scope of the (79 FR 34625). A notice of proposed determining the correctness of the
current regulations by excluding non- rulemaking (REG–121542–14) cross- taxpayer’s self-assessed tax liability. The
government attorneys from receiving referencing the temporary regulations assistance of persons from outside the
summoned books, papers, records, or was published in the Federal Register IRS, such as economists, engineers,
other data or from participating in the (79 FR 34668) the same day. No public appraisers, industry specialists, and
interview of a witness summoned by the hearing was requested or held. The actuaries, promotes fair and efficient
IRS to provide testimony under oath, Internal Revenue Service received two administration and enforcement of the
with a limited exception. These comments on the proposed regulations. laws administered by the IRS by
proposed regulations affect taxpayers One comment recommended that the providing specialized knowledge, skills,
involved in a federal tax examination regulations be revised to remove the or abilities that the IRS officers or
and other persons whose books and provision permitting a contractor to employees assigned to the examination
records or testimony are sought to be question a witness under oath or to ask may not possess. Section 6103(n) and
examined by the IRS under section a witness’s representative to clarify an Treas. Reg. § 301.6103(n)–1(a) authorize
7602(a). objection or assertion of privilege. The the IRS to disclose returns and return
daltland on DSKBBV9HB2PROD with PROPOSALS
other comment recommended that the information to these contractors. The
DATES: Written or electronic comments proposed and temporary regulations be regulations under § 301.7602–1(b)(3)
and requests for a public hearing must withdrawn. After consideration of these were issued to clarify that persons
be received by June 26, 2018. comments, the proposed regulations described in section 6103(n) and Treas.
ADDRESSES: Send submissions to: were adopted in final regulations (TD Reg. § 301.6103(n)–1(a) may receive and
CC:PA:LPD:PR (REG–132434–17), Room 9778) published in the Federal Register review books, papers, records, or other
5203, Internal Revenue Service, P.O. (81 FR 45409) on July 14, 2016 data summoned by the IRS and, in the
Box 7604, Ben Franklin Station, (‘‘Summons Interview Regulations’’). presence and under the guidance of an
VerDate Sep<11>2014 16:35 Mar 27, 2018 Jkt 244001 PO 00000 Frm 00001 Fmt 4702 Sfmt 4702 E:\FR\FM\28MRP1.SGM 28MRP1](https://thefederalregister.org/doc/83_FR_13266/page/1.svg)
![13208 Federal Register / Vol. 83, No. 60 / Wednesday, March 28, 2018 / Proposed Rules
copies) or electronic comments timely (ii) Exception for certain non- order to avoid interference with the law
submitted. The IRS requests comments governmental attorneys. An attorney enforcement functions and
on all aspects of these proposed who is not an officer or employee of the responsibilities of OIG. For the reasons
regulations. All comments will be United States may not be hired by the provided below, the Department
available for public inspection and IRS to perform the activities described proposes to amend its Privacy Act
copying. The IRS will schedule a public in paragraph (b)(3)(i) of this section regulations by establishing an
meeting if one is requested, in writing, unless the attorney is hired by the IRS exemption for records in this system
by a person who submits written as a specialist in foreign, state, or local from certain provisions of the Privacy
comments. If the IRS does schedule a law, including tax law, or in non-tax Act. Public comment is invited.
public hearing, the IRS will publish substantive law that is relevant to an DATES: Comments must be received by
notice of the date, time, and place for issue in the examination, such as patent April 27, 2018.
the public hearing in the Federal law, property law, or environmental ADDRESSES: You may send comments by
Register. law, or is hired for knowledge, skills, or any of the following methods:
abilities other than providing legal • Email: privacy.compliance@
Drafting Information
services as an attorney. usdoj.gov. To ensure proper handling,
The principal author of these * * * * * please reference the CPCLO Order
regulations is William V. Spatz of the (d) Applicability date. This section is Number in the subject line of the
Office of Associate Chief Counsel applicable after September 3, 1982, message.
(Procedure and Administration). except for paragraphs (b)(1) and (2) of • Fax: 202–307–0693. To ensure
List of Subjects in 26 CFR Part 301 this section which are applicable on and proper handling, please reference the
after April 1, 2005 and paragraph (b)(3) CPCLO Order Number on the
Employment taxes, Estate taxes,
of this section which applies to accompanying cover page.
Excise taxes, Gift taxes, Income taxes,
Penalties, Reporting and recordkeeping
examinations begun or administrative • Mail: United States Department of
summonses served by the IRS on or after Justice, Office of Privacy and Civil
requirements.
March 27, 2018. For rules under Liberties, ATTN: Privacy Analyst,
Proposed Amendments to the paragraphs (b)(1) and (2) of this section National Place Building, 1331
Regulations that are applicable to summonses issued Pennsylvania Avenue NW, Suite 1000,
Accordingly, 26 CFR part 301 is on or after September 10, 2002 or under Washington, DC 20530. All comments
proposed to be amended as follows: paragraph (b)(3) of this section that are sent via regular or express mail will be
applicable to summons interviews considered timely if postmarked on the
PART 301—PROCEDURE AND conducted on or after June 18, 2014 and day the comment period closes. To
ADMINISTRATION before July 14, 2016, see 26 CFR ensure proper handling, please
301.7602–1T (revised as of April 1, reference the CPCLO Order Number in
■ Paragraph 1. The authority citation 2016). For rules under paragraph (b)(3) your correspondence.
for part 301 continues to read in part as of this section that are applicable to • Federal eRulemaking Portal:
follows: administrative summonses served by https://www.regulations.gov. When
Authority: 26 U.S.C. 7805 * * * the IRS before March 27, 2018, see 26 submitting comments electronically,
CFR 301.7602–1 (revised as of April 1, you must include the CPCLO Order
■ Par. 2. Section 301.7602–1 is
2017). Number in the subject box. Please note
amended by revising paragraphs(b)(3)
and (d) to read as follows: Kirsten Wielobob, that the Department is requesting that
electronic comments be submitted
Deputy Commissioner for Services and
§ 301.7602–1 Examination of books and Enforcement. before midnight Eastern Time on the
witnesses. day the comment period closes.
[FR Doc. 2018–06242 Filed 3–27–18; 8:45 am]
* * * * * Posting of Public Comments: Please
BILLING CODE 4830–01–P
(b) * * * note that all comments received are
(3) Participation of a person described considered part of the public record and
in section 6103(n). (i) In general. Except made available for public inspection
as provided in paragraph (b)(3)(ii) of DEPARTMENT OF JUSTICE online at https://www.regulations.gov
this section, for purposes of this and in the Department’s public docket.
28 CFR Part 16
paragraph (b), a person authorized to Such information includes personally
receive returns or return information [CPCLO Order No. 003–2018] identifying information (such as name,
under section 6103(n) and address, etc.) voluntarily submitted by
§ 301.6103(n)–1(a) of the regulations Privacy Act of 1974; Implementation the commenter. If you want to submit
may receive and review books, papers, AGENCY: Office of Inspector General, personal identifying information as part
records, or other data produced in United States Department of Justice. of your comment, but do not want it to
compliance with a summons, and, in ACTION: Notice of proposed rulemaking. be posted online or made available in
the presence and under the guidance of the public docket, you must include the
an IRS officer or employee, participate SUMMARY: Elsewhere in this issue of the phrase ‘‘PERSONAL IDENTIFYING
fully in the interview of a witness Federal Register, the Office of Inspector INFORMATION’’ in the first paragraph
summoned by the IRS to provide General (OIG), a component within the of your comment. You must also place
daltland on DSKBBV9HB2PROD with PROPOSALS
testimony under oath. Fully United States Department of Justice all personal identifying information that
participating in an interview includes, (DOJ or Department), has published a you do not want posted online or made
but is not limited to, receipt, review, new system of records notice, ‘‘Data available in the public docket in the first
and use of summoned books, papers, Analytics Program Records System,’’ paragraph of your comment and identify
records, or other data; being present JUSTICE/OIG–006. In this notice of what information you want redacted.
during summons interviews; and proposed rulemaking, OIG proposes to If you want to submit confidential
questioning the person providing exempt this system of records from business information as part of your
testimony under oath. certain provisions of the Privacy Act in comment, but do not want it to be
VerDate Sep<11>2014 16:35 Mar 27, 2018 Jkt 244001 PO 00000 Frm 00003 Fmt 4702 Sfmt 4702 E:\FR\FM\28MRP1.SGM 28MRP1](https://thefederalregister.org/doc/83_FR_13266/page/3.svg)
Document Created: 2018-11-01 08:55:23
Document Modified: 2018-11-01 08:55:23
| Category | Regulatory Information | |
| Collection | Federal Register | |
| sudoc Class | AE 2.7: GS 4.107: AE 2.106: | |
| Publisher | Office of the Federal Register, National Archives and Records Administration | |
| Section | Proposed Rules | |
| Action | Notice of proposed rulemaking. | |
| Dates | Written or electronic comments and requests for a public hearing must be received by June 26, 2018. | |
| Contact | Concerning submission of comments, Regina Johnson, (202) 317-6901; concerning the proposed regulations, William V. Spatz at (202) 317-5461 (not toll-free numbers). | |
| FR Citation | 83 FR 13206 | |
| RIN Number | 1545-B012 | |
| CFR Associated | Employment Taxes; Estate Taxes; Excise Taxes; Gift Taxes; Income Taxes; Penalties and Reporting and Recordkeeping Requirements |
2024 Federal Register | Disclaimer | Privacy Policy
USC | CFR | eCFR