IRS Third Party Notices

IRS released Chief Counsel Advice 201621012 today, which discussed third party contacts. While the actual situation is not all that interesting, it is good to note the laws discussed in the advice.
Under IRC 7602(c), the IRS is required to provide reasonable notice that they will contact third parties when auditing or attempting to collect taxes from a taxpayer. This is usually done during the initial meeting with the taxpayer.
Practitioners need to remember IRC 7602(c)(2), which states the IRS is required to periodically provide a list of the third party contacts. The practitioner can also request the list at any time. While most of the IRS does a good job of keeping practitioners informed and following the Internal Revenue Manuel, in longer audits or situations where third party contact has occurred, it is usually good practice to keep an eye on the list of third party contacts.
The only third party contacts that do not need to be disclosed are: when the taxpayer authorized the contact, if notice would jeopardize collection of tax or threat of a reprisal against any person, and in criminal investigations.


Relevant Cites:
IRC 7602