IRS memorandum for TE/GE employees, examination timelines again modified (COVID-19)

IRS memorandum for TE/GE employees

The IRS this week released guidance for employees of the Tax Exempt and Government Entities (TE/GE) Division regarding the extended “information document request” (IDR) timelines due to the coronavirus (COVID-19) pandemic.


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The memorandum—TE/GE-04-1220-0031 [PDF 126 KB]—supersedes an earlier memo (July 2020) and:

  • Extends the approval period to deviate from standard follow-up IDR and IDR enforcement timelines until June 30, 2021
  • Provides guidance regarding resumption of TE/GE exam activities post July 15, 2020, which will also be effective until June 30, 2021

The current memo (December 2020) was issued by the Commissioner of the TE/GE Division of the IRS, and supersedes a July 2020 memo that had in turn previously superseded an April 2020 memorandum that had provided IDR enforcement timelines in response to the COVID-19 situation. Today’s memo (as did the prior versions) includes this rationale for the relief:

This modification temporarily relaxes the more rigid timelines detailed within the above IRM sections that would otherwise result in enforcement actions due to untimely or incomplete IDR responses. We are issuing this modification to strict adherence of the timelines present within our IRMs in recognition of the difficulty taxpayers may face at this time due to the various challenges associated with COVID-19. The intent of this modification is to allow an increased reasonable application of business judgement by examiners and managers in the exercise of duties related to IDR requests and follow-ups. These modified IDR procedures will be effective until further notice.

The memorandum also provides that “all operations” will continue normal procedures, except that:

  • In-person contact will be allowed when necessary, but when possible, the default is to correspondence and/or virtual interactions.
  • In general, face-to-face taxpayer interactions are to be limited to only those instances when such interactions are needed, and front-line managers have been engaged.
  • Field and office examinations when it is determined that in-person interaction with a taxpayer/representative is necessary only to exchange books and records, TE/GE employees can consider conducting the meeting in a Taxpayer Assistance Center that is equipped with plexiglass barriers, if possible.
  • Virtual appointments can be conducted by teleconference. WebEx will also be an option following appropriate guidelines and subject to system availability.

For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Ruth Madrigal | +1 202 533 8817 |

Preston Quesenberry | +1 202 533 3985 |

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