Diana L. Wollman

Schedule UTP: IRS Releases Internal Guidance to LB&I Personnel: Addresses How LB&I Personnel Should Use Schedule UTP as Part of the Tax Return Examination Process
Donald L. Korb,Eugenio Labadie,Andrew S. Mason,Andrew P. Solomon,S. Eric Wang,Diana L. Wollman, November 14, 2011
On November 1, 2011, the Commissioner of the Large Business and International Division (“LB&I”) of the Internal Revenue Service (the “IRS”) issued internal guidance to all LB&I employees regarding the use of Schedule UTP in LB&I examinations.

Economic Substance Doctrine: New Directive for IRS Examiners and Managers: LB&I Directive Sets Out Detailed Substantive and Procedural Standards for IRS Examiners to Follow - This Provides Valuable Information to Taxpayers and Their Advisors
David P. Hariton,Eliyahu D. Jacobson,Donald L. Korb,Andrew S. Mason,S. Eric Wang,Diana L. Wollman, July 28, 2011
The Commissioner of the Large Business and International Division of the IRS (“LB&I”) recently issued a directive (the “Directive”) to LB&I examiners and managers setting out specific analytical steps that the examiners must complete before asserting the newly codified...