No IDR Enforcement During COVID-19
Yesterday, the Internal Revenue Service (IRS) announced in a memorandum to all Large Business & International (LB&I) division employees that it was suspending the normal Information Document Request (IDR) procedures. The letter suspends enforcement until July 15, 2020; however, LB&I managers will have the discretion to continue with the IDR enforcement process when in their judgment the interests of tax administration warrant (e.g., cases with short statutes, listed transactions or fraud development). The memorandum, however, does not tell examining agents to stop issuing IDRs or working on their cases as the suspension relates only to enforcement of IDRs.
Practice Point: The suspension of the IDR enforcement procedures is welcome news to taxpayers with ongoing audits. With tax professionals displaced in their homes while mandatory self-isolation continues, meeting IDR deadlines has been challenging. We suggest, however, that taxpayers try to continue to work on their responses to IDRs the best they can so that when the world goes back to normal, responding to IDRs will not be high on the list of things to be done.