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district other than the closest Service office.
(ii) Exception. If the office within the
assigned district closest to an individual taxpayer’s
residence * * * does not have an examination group or
the appropriate personnel to conduct the examination,
it generally is reasonable for the Service to require
the taxpayer to attend an examination at the closest
Service office within the assigned district that has an
examination group or the appropriate personnel.
(iii) Travel Considerations. In scheduling
office examinations, the Service in appropriate
circumstances will take into account the distance a
taxpayer would have to travel.
In section 301.7605-1(e)(1), Proced. & Admin. Regs., the
Secretary further provides:
The Service will consider, on a case-by-case basis,
written requests by taxpayers or their representatives
to change the place that the Service has set for an
examination. In considering these requests, the
Service will take into account the following factors–
(i) The location of the taxpayer’s current
residence;
(ii) The location of the taxpayer’s current
principal place of business;
(iii) The location at which the taxpayer’s books,
records, and source documents are maintained;
(iv) The location at which the Service can
perform the examination most efficiently;
(v) The Service resources available at the
location to which the taxpayer has requested a
transfer; and
(vi) Other factors that indicate that conducting
the examination at a particular location could pose
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