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Charles Ruchelman Comments on IRS Unprecedented Hiring of Private Law Firm

April 6, 2015, Law360

Charles M. Ruchelman spoke with Law360 concerning the IRS' unprecedented move to hire litigators from Quinn Emanuel to "assist with the evaluation, analysis, presentation and defense of claims or adjustments" related to an IRS audit of Microsoft's transfer pricing practices.  The agency published a set of temporary regulations in an attempt to allow Quinn Emanuel's participation in the examination without breaking the taxpayer privacy rules in Internal Revenue Code Section 6103 and other statutes.  The move by the IRS to engage a private law firm to participate in a taxpayer dispute in such an unprecedented way is troubling to tax practitioners.  For the full story, please visit Law360's website (subscription required).

Excerpt taken from the article.

Among tax professionals, there is "concern that this is something new and it potentially oversteps the bounds of the IRS' obligations under 6103 as well as their going beyond the mandate of what the [IRS] and the [U.S. Department of Justice] are supposed to be doing," Caplin & Drysdale Chtd.'s Charles M. Ruchelman said.

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