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United States Claims Chart for Compromises in Partnership Proceedings

This chart outlines the acceptance or rejection criteria for claims on behalf of the United States, excluding refund suits involving income, estate, or gift taxes. It includes compromises in partnership proceedings exceeding $2 million in Government concessions. The roles of Civil Chief, Associate AG, AAG Office of Review, DAAG for Review, and IRS Chief Counsel1 are defined. Recommendations from Chief Counsel are necessary for full concessions, except in certain cases.

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United States Claims Chart for Compromises in Partnership Proceedings

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  1. Reject Accept This chart applies to claims on behalf of the United States (non-refund suits) and claims against the United States other than refund suits involving income, estate or gift taxes; includes compromises in § 6226 Partnership Proceedings, where the Government concession exceeds $2 million. Yes CivilChief Yes/No Associate AG Yes Yes AAG Office of Review Yes/No DAAG for Review Yes/No IRS Chief Counsel1 Yes No No No CivilChief No 1The Chief Counsel’s recommendation is not required in SOP cases that are compromised. However, when full concession of an issue or a case is proposed, the Trial Attorney must obtain a recommendation from Chief Counsel, except in cases involving liability under IRC § 6672.

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