Scott William Katz - Page 12




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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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Last modified: May 25, 2011