Appeals Settlement Guidelines (ASG)
NOTE: Coordinators may have changed since settlement guidelines were published. Please refer to the Technical Guidance - International Index (PDF) for the latest coordinator contact information.
Abusive Tax Avoidance Transactions
- Business Directory for Visually impaired
- Deductions for Contributions to 401(k) or Defined Contribution Plans during Grace Period, Related Change of Accounting Adjustments, and Penalties;
- Domestic Abusive Trust Schemes
- Home Based Business Promotions
- IRC Section 302/318 Basis Shifting Transactions
- IRC Section 351/Contingent Liability
- IRC Section 44 Disabled Access Credit Tax Avoidance Schemes
- Intermediary Transaction Tax Shelters and Penalties
- Internet Shopping Portal
- Lease in, lease out (LILO)
- Notice 2000-15 Abusive Charitable Remainder Trusts
- Notice 2000-44 Transactions - Described as generating losses resulting from artificially inflating the basis of partnership interests
- Notice 2002-21 Transaction involving the use of a Loan Assumption agreement to claim an inflated basis in assets acquired from another party
- Notice 2002-35 Involves the use of a National Principal Contract to claim current deductions for periodic payments while disregarding the accrual of a right to receive offsetting payments in the future
- Notice 2002-50 Transactions involving the use of a straddle, a tiered partnership structure, a transitory partner, and the absence of a sec 454 election to claim a permanent noneconomic loss
- Notice 2002-65 Pass-through Entity Straddle Tax Shelter Transactions and Penalties
- Notice 2003-47 Transfers of Compensatory Stock Options to Related Persons
- Notice 2003-22 Certain arrangements involving employee leasing companies that have been used to avoid or evade federal income and employment taxes.
- Notice 2003-35 Tax Exempt Small Insurance Company Transactions
under 501(c)(15) and related penalties - Notice 2003-77 IRC 461(f) Contested Liabilities Transactions
- Preparer/Promoter Penalties
- Sale in, lease out (SILO)
- Telecommunication System for Hearing Impaired
Air Transportation
Cafeteria Plans
COLI (Corporate Owned Life Insurance)
Commercial Banking
- Accrual of interest on non-performing loans (see Banking - Savings and Loan)
- Foreign Withholding Taxes (Cross Border Loans)
- Interchange Merchant Discount Fee
Construction/Real Estate
Employment Tax
- Medical Resident FICA Refund Claims
Environmental
- IRC 1341 Environmental Remediation Costs
Excise Tax
- Virtual Private Networks
Food Industry
Forest Products
Fuel from a Nonconventional Source (FNS)
Gaming
- The Applicable Recovery Period Under IRC 168(a) for Slot Machines, Video Lottery Terminals and Gaming Furniture, Fixtures and Equipment
- Class Life of Floating Gaming Facilities
I.R.C. § 118 SALT
- State and Local Location Tax Incentives (I.R.C. § 118 SALT)
- Exclusion of Income: Non-Corporate Entities and Contributions to Capital, I.R.C. § 118
Insurance – Life
- IRC 807 Basis Adjustment – Change in Basis vs. Correction of Error
- Loss Utilization in a Life-nonlife Consolidated Return Separate v. Single Entity Approach
Intangibles
Interest Computations
- Net Rate Interest Netting - Requirement that Both Statutes be Open for Pre-98 Act Years
- Overpaid Estimated Taxes
International
- Foreign Sales Corporations (FSC) Advance Payment Transactions
Inventory
- Dollar Value LIFO: Segments of Inventory
- Dollar Value LIFO: Bargain Purchase Inventory
- Dollar-value LIFO: Earliest Acquisition Method
Leasing Promotions
- Lease Stripping Transactions
- Losses Reported from Inflated Basis Assets from Lease Stripping Transactions
- Intermediary Transactions Tax Shelters
Mare Leasing
Primary issue of whether expenses were incurred in carrying on a trade or business. Alternatively, whether individuals were materially participating and at risk; whether expenses were ordinary and necessary; and whether expenses should be capitalized or currently deducted.
Maquiladora
- IRC Section 1504(d) Election
- IRC Section 168(g)
Media/Communications
- Investment Tax Credit - Transition Property
Military
Mining
- Strike Costs
- Excess Moisture
- Receding Face Deduction
- The Effect of Costs Incurred During a Strike on the Percentage of Depletion Computation
Motor Vehicle
- Dollar-Value LIFO - Definition of an Item
- Remanufacturers' Inventory of Cores
- Excess Parts Inventory
Notional Principal Contracts
Partnerships
Petroleum
Pharmaceutical
- Medicaid Rebates
- Research and Experimentation Expenditures (Reg. 1.861-17(a)(4)
Research Credit
- Extraordinary Expenditures for Utilities
- R&E Credit - Self-Constructed Supplies
- Qualifying Wages Under Section 41 in Determining the Tax Credit or Increasing Research Activities
- Wages of Technical Writers and the Research Credit
Retail
- ACRS and ITC for Suspended Ceilings
- Contributions to 401(k) Plans Attributable to Compensation Paid After Year End Under 401(a)(6);
- Tenant's Rent Leveling IRC 467 Lease Agreements
- Valuation of an Acquired Retailer's Inventory
S Corporations
Savings and Loans
- Supervisory Goodwill
- Accrual of Interest on Non Performing Loans (see Banking)
- Validity of Regulations Sec. 1.593-6A(b)(5)(vi)
- Supervisory Goodwill
Securities & Financial Services
- Transfer or Sale of Compensatory Options or Restricted Stock to Related Persons- Notice 2003-47
Shipping
- Federal Income Tax Witholding on Conpensation Paid to Nonresident Alien Crew by a Foreign Transportation Entity (See Air Transportation)
- Income Tax Withholding on Wages Paid to U.S. Crew
Sports Franchises
State Refundable Credits
Telecommunications
Utilities
- Investment Credit Transition Property
- Membership Payments Made to Industry-created Research Organizations
Page Last Reviewed or Updated: 2013-04-29
