Part I - Taxpayer Information Section (Examination Arrangements LCC/LPC cases)

Two-fold purpose - The Taxpayer Information Section has a two-fold purpose. One is to formalize the groundwork for an examination consistent with the concepts of LB&I. The other is to prevent misunderstandings of commitments made and agreements reached. It should be sufficiently detailed and complete so that team members and taxpayers will not unknowingly create a sensitive situation by acting contrary to the agreements. Form 4764, LB&I Examination Plan, should be used in preparing this part of the plan.

Preparation of Part I - Part I should be prepared following the opening conference and should clearly identify, in writing, the agreements reached with the taxpayer. The preparation of this part of the plan is the responsibility of the case and issue manager(s); however, the examination plan is a shared responsibility of the case and issue manager(s) and the TC.

Signatures on Part I - Acknowledgment regarding the matters covered and agreements reached at the opening conference is best evidenced by signatures of both the case manager and a duly authorized corporate officer of the taxpayer in spaces provided on the last page of Part I.