irs section 1204 key componentsirs section 1204 key components
The manager may comment on the TER reached, as materiality is a factor relating to the employee's judgment, and may document the TER in the write-up of the individual case review. The IRS will respect and protect their rights under the law. Yes. While the tax adjustment may involve Section 1204 judgment depending on the type of judgment involved, the related penalty abatement is merely mathematical and does not involve Section 1204 judgment in and of itself. Section 1245 is a part of the IRS code stating that depreciable property that has been sold at a price in excess of depreciated or salvage value may qualify for favorable capital-gains tax treatment. HCO - Provides overall program direction for the IRS Section 1204 program. The IRS regulations on the use of statistics are designed to make sure that records of tax enforcement results (ROTERs) are not used to improperly influence the handling of taxpayer cases. If your adjusted gross income (AGI) was $73,000 or less, review each provider's offer to make sure you qualify. An overview of the key changes follows. Yes. A Section 1204 Employee is an employee who exercises judgment in recommending or determining whether or how the IRS should pursue enforcement of tax laws, or who provides direction and guidance for Section 1204 program activities . Although neither Section 1204 nor Regulation 801 contain restrictions on TER use, the IRS determined that managers must not include TER outcomes in a written performance appraisal or employee evaluation. The guidance explaining how the ROTER can or cannot be used. Idle time is a quantity measure. Wait time is a diagnostic tool intended to minimize taxpayer burden, not a ROTER or a quantity measure. A TER is not a quantity measure. squad or ambulance crew, as those terms are defined in section 1204(9)(A) of the Omnibus Crime Control and Safe Streets Act of 1968 which is codified in 42 U. S. C. 3796b(8)(A) and as . Learn More. The performance criteria for each position, as are appropriate for that position, will be composed of elements that support the organizational measures of customer satisfaction, employee satisfaction, and business results; however such organizational measures will not directly determine the evaluation of individual employees. Processing ASFR/A6020(b) pre-assessment correspondence involving P-5-133 determinations and disputed income items. Audience: The policy and procedures apply to the managers and employees responsible for enforcing tax laws fairly and equitably. The area director must make it clear that circumstances in an organization or the complexity of inventory for certain employees may warrant a different closure rate. IRS has access control measures in place to provide protection from unauthorized alteration, loss, unavailability, or disclosure of . In Group I-2 occupancies located in flood hazard areas established in Section 1612.3 of the International Building Code where new essential electrical systems are installed, and where new essential electrical system generators are installed, the systems and generators shall be located and installed in accordance with ASCE 24. If a manager, management official, or confidential management/program analyst submits a self-assessment with ROTERs, it should be returned to the employee for removal of the ROTERs. Section 409A provides a broad definition of nonqualified deferred compensation and provides rules related to the timing of elections and distributions under deferred compensation arrangements. A manager cannot advise or imply that an employee should achieve the same TER in Case B as they achieved in Case A. Program completion dates are the scheduled completion of returns processing (timely filed Form 1040 processed by a certain date) or program completions (Consolidated Annual Wage Report (CAWR)/ Federal Unemployment Tax Act/Account (FUTA) programs completed and submitted to the receiving agency by a certain date). See Regulation 801.7, Example 4. Yes, but not simply in terms of quantity of work done. The examiners are expected to exercise considerable discretion in reviewing and making determinations on taxpayer replies to notices. XC Front lowers approx. Correct entry (taxpayer or campus employee), Estate Tax determination to file return based on application of P-5133, Extension to file (2nd, automatic if timely & complete), Fairness/equity determination (does not follow normal procedures), Final Category A determination (allowing/not allowing CAT A claims/amended returns), Freedom of Information Act (FOIA) Privacy requests, Reconciliation of wages reported on Form 940 to those reported to state (FUTA), Innocent spouse determination using decision tree, Issue notice/request for return based on prior returns, IRP information (systemically generated), Calculation of interest and penalties (automated-not determining), Lien, Levy determination (whether to file or release). A thorough, diligent 409A valuation gives the IRS everything it needs to determine that a non-qualified deferred compensation plan is above board. See Regulation 801.6(d)(2). In other instances, taxpayers will respond to penalty notices by presenting new facts indicating that the penalty does not apply. Reference to a specific TER or dollar amount may not be mentioned. Section 1204(c) requires each appropriate supervisor to self-certify quarterly whether ROTERs were used in a prohibited manner. This is allowable as an organizational or employee goal, but the goal cannot be used in the evaluation of these employees. Organizations that meet Section 501 (c) (3) requirements are . ROTERs are data, statistics, and compilations of information or other numerical or quantitative recordations of the TERs reached in one or more cases. As at 31 December 2022, the interest rate swaps cover 100% of the Group's term Sterling denominated borrowings of GBP176.5 million for the period . Data as of February 23, 2023. Certainly, these tax examiners exercise decision making in performing their tasks, but this decision making is not the type of exercise of judgment with regard to recommending or determining whether or how the IRS should pursue enforcement of the tax laws, which is covered by Section 1204/Regulation 801. This is true even if the actions are TERs. A Section 1204 Manager is a manager/supervisor at any level who supervises one or more Section 1204 employees. As these scheduled rates are not ROTERs, they are not subject to Section 1204/Regulation 801. Prosecution recommended (indictment/conviction). Also included are RR 10-2008, RR 16-2008, Consolidated Withholding Tax Regulations and Consolidated Fringe . Protected taxpayer rights & entitlements for 10.1 million taxpayers. Performance measures based on quality measures may be used to evaluate employee performance. L. 103-353 substituting "chapter 43" for "section 4323". (RRA 98, Section 1204) No employee of the IRS may use ROTERs (as described in Regulation 801.6) to evaluate any other employees or impose or suggest production quotas or goals for any employee. See IRM 1.5.2.12, Quantity Measures, for more information. Subparts 1-2[Reserved] Subpart 3 - NASA Guidance Documents ( 1204.300 - 1204.313) Subpart 4 - Small Business Policy ( 1204.400 - 1204.403) This type of decision making in determining the ability to pay requires the type of judgment covered by Section 1204/Regulation 801. An organizational unit may use any outcome-neutral data, such as overage cases or cycle time, as a quantity measure. See Regulation 801.3(e)(3). A group manager may be provided with ROTER data, such as the amount collected by that group. Form 9465. See Regulation 801.6(c). A TER includes but is not limited to: Type of case closure (agreed, no change, full paid, abatement). Using results for diagnostic tools or workload indicators to compare one unit against other units may be appropriate for: Seeking process enhancements to support improvement of the over-arching balanced measure(s). This clearly involves discretion in that two employees working the same case can reasonably come to different conclusions as to the acceptability of the taxpayer's assertions. 1.2 i . . An appropriate supervisor can identify additional appropriate supervisors. It is not a violation of Section 1204/Regulation 801 to review the case or to discuss the appropriate actions to be taken with the employee, even if the action is an enforcement action. Auto Metal Direct 716-4680-1 - Rear Cross Sill 1980-1996 Ford Bronco (1) $319.99. Other penalty abatements arise due to adjustments to the underlying tax on which they are computed. Rules Governing Practice before IRS. The performance of any one unit at any level of the organization must not be used as a standard by which the performance of other units are evaluated due to differences that exist in: The RRA 98, Section 1204 and Regulation 801 Decision Table can be used to determine if a particular measure/data may be used for a specific purpose. In a case review, a manager discovers that an employee failed to consider all relevant facts or correctly apply laws resulting in an incorrect proposed assessment of $1 million. Internal Revenue Service, all members who have retired or will retire under one . Prohibited by Section 1204 and Regulation 801. Section 501 (c) (3) is a portion of the U.S. Internal Revenue Code (IRC) and a specific tax category for nonprofit organizations. If you praise an employee for submitting a fraud referral, it is only one referral, but since your focus is on achieving the TER rather than on the steps taken to identify and develop fraud, it is a ROTER violation. The table below identifies acronyms used in this IRM: Section 1204 (Basis for Evaluation of IRS Employees) provides that: The IRS may not use ROTERs (1) to evaluate employees or (2) to impose or suggest production quotas or goals with respect to such employees. The IRS Section 1204 program requires the cooperation and assistance of many IRS organizations. RRA 98, Section 1201, establishes an IRS performance management system with goals or objectives for individual, group, or organizational performance. Focus on the employees recognition of badges of fraud, investigative skills, development of key fraud indicators, and appropriate use of enforcement tools, not on the fraud referral or fraud penalty itself. The performance criteria is composed of elements that support the organizational measures for: Regulation 801.3(a) indicates organizational measures do not directly determine the evaluation of individual employees. Yes. This is a violation of Section 1204/Regulation 801. No. I.R.C. In October 2005, Regulation 801 was revised to allow imposing or suggesting quantity goals for organizational units. This means U.S. companies can deduct the full purchase price of ALL qualified equipment purchases, up to the limit . This is routine decision making relating to clear cut issues provided for and covered in the IRM. This example does not suggest or impose a production goal or quota for an employee. In all unagreed IRS cases involving Internal Revenue Code section 4971(a) and/or (b) or 4975, Form 6212-B (or a copy of Form 6212-B) will be completed with an entry in the . Some offers include a free state tax return. An employee whose duties involve providing direction or guidance for field programs involving Section 1204 work activities. As a diagnostic tool, an employee's production rate may alert the manager to look at the employee's work practices to see if adjustments are in order. 8424, otherwise known as the Tax Reform Act of 1997, which was enacted on December 11, 1997. The evaluation could be reworded to note that the employee made appropriate lien determinations on their cases. VAT (Sales tax) is applied at the country specific rate for goods shipped to the UK or the EU. L. 103-446, which directed the amendment of par. See Regulation 801.6(d)(2) and 801.7(a) Example 3. (3) Updated IRM 1.5.2.8, Regulation 801.5 Employee satisfaction measures effective date. 39 reports issued. The decisions made in this manner involve the type of judgment intended to be protected under Section 1204/Regulation 801. Identify and address developmental needs for individuals and/or teams. This section shall apply to gain from the sale or exchange of stock treated as qualified small business stock by reason of . IRS Human Capital Officer. Employers engaged in a trade or business who pay compensation. . 4wd T5-R Cross Country XC Front lowers approx. HCO Office of HR Operations - Manages the IRS performance management system (HR Connect) and identifies the IRS Section 1204 employee population. This IRM: Contains general background information on the use of enforcement statistics. April 2022 September 2022. These dates are not ROTERs because program completion date establishes a timing schedule only. Rules. To get the exclusion a taxpayer must own . According to Section 1204(a), the IRS may not use ROTERs to evaluate employees or to impose or suggest production quotas or goals. [House Hearing, 108 Congress] [From the U.S. Government Printing Office] USE OF PRIVATE COLLECTION AGENCIES TO IMPROVE IRS DEBT COLLECTION ===== HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT of the COMMITTEE ON WAYS AND MEANS U.S. HOUSE OF REPRESENTATIVES ONE HUNDRED EIGHTH CONGRESS FIRST SESSION _____ MAY 13, 2003 _____ Serial No. The manager may suggest that the employee obtain information about the tax shelter from other employees with experience in examining that shelter or similar shelters. The revision authorizes using quantity measures to evaluate the performance of supervisory employees, non-Section 1204 employees, and organizational units. Performance measures based on quality measures may also be used to impose or suggest production goals for any employee. Whether an employee is a Section 1204 employee for purposes of applying Section 1204/Regulation 801 is determined by the task performed by the employee and not the title or location of the employee. Allowable and unallowable uses of quantity and quality measures. PHONE: 800-955-2444 CONNECT: Tax Analysts is a tax publisher and does not provide tax advice or preparation services. Quality measures are determined by a specially dedicated IRS staff such as National Quality Review System (NQRS) analysts. The manager may suggest that the RO contact experienced personnel to discuss best practices. Requiring an employee to effect a certain number of seizures during a rating period. ROTERs do not include TERs of individual cases when used to determine whether an employee exercised appropriate judgment in pursuing the enforcement of tax laws based on a review of the employee's work on that individual case. See Regulation 801.2. A manager may inform an RO that specified levies should be served or indicate that the next appropriate course of action would be seizure of specific property. 9. The amount of talk, handle, or wrap time is not a ROTER; it is a statistic which should be discussed in conjunction with Quality and Customer Service. Each appropriate supervisor will certify quarterly by letter to the Commissioner of Internal Revenue whether TERs are being used in a manner prohibited by Section 1204(a). Section 1204/Regulation 801 applies to the tasks performed by employees. However, if TEPS contains a performance standard which uses a ROTER to (1) evaluate any employee or (2) to impose or suggest production quotas or goals for any employee, then the use of TEPS would violate Section 1204/Regulation 801. No. The IRS will use the fair and equitable treatment of taxpayers by employees as one of the standards for evaluating employee performance. General Legal Services (GLS) - Reviews and confirms ROTERs identified in the TIGTA audit and HCO Independent Review. Title 26 Code of Federal Regulations, Part 801 (Regulation 801), establishes an overall IRS performance measurement system and governs the use of ROTERs. Threshold income amounts for deductibility of medical expenses on Schedule A do not involve the discerning or evaluation of facts, law or principles which require the use of subjective factors such as experience, legal principles, and fairness considerations. The activity produces a TER and the employee is working as a Section 1204 employee. Quality measures may be used to evaluate non-supervisory employees. (Program Code 48X20), Reconciliation of wages reported on Forms 941 to those reported to SSA (CAWR), Centralized files and scheduling (Installment Agreements appointments), Clerical Functions (e.g., mail sorting, classification, batching), Currently Non Collectible (CNC) determination. Where connections for hook up of temporary generators are provided . The Small Business/Self-Employed (SB/SE), Director, Collection, supervises eight area directors, who each have subordinate territory and group managers. No. One or more cases is a term used in the definition of a ROTER, specifically "TERs reached in one or more cases." That is not a violation since the number of cases in a particular inventory is not a ROTER. In an employee evaluation, neither TERs, ROTERs, nor quantity measures may be used. Using the report is not a violation since the number of cases in inventory is not a ROTER. However, overemphasis on wait time could lead employees to focus on completing taxpayer contacts quickly and not on providing quality service. Section 1204/Regulation 801 provides a specific exception in the definition of TERs for this purpose. Yes. Both of the statements are prohibited by Section 1204(a) because each suggests a production goal. . Since each lien or levy is a TER, the manager and RO may discuss the appropriateness of each of the collection tools used or not used (including the appropriateness of each based on the amounts at issue), and the manager may make general observations about the RO's judgment in each case considering the amounts at issue and the expected and actual TERs. A manager may discuss with an employee his/her exercise of judgment in achieving a particular TER in a case when based on a review of the employee's work on that individual case. Using TERs or ROTERs to evaluate any employee is prohibited. A 2018 study from the Inter-American Development Bank makes the case that infrastructure has the potential to explicitly and directly support progress toward over 70 percent of the 169 Sustainable Development Goal (SDG) targets outlined in the United Nation's 2030 Agenda for Sustainable Development. Mathematical computations (such as interest or penalty calculations). Determining whether a production quota or goal was suggested to an employee depends on considering all relevant facts and circumstances, including whether there is a good business reason for using the statistic. Any managerial communication, either oral or written, that requires a Section 1204 employee to achieve a TER is considered imposing a production quota or goal. The National Internal Revenue Code of 1997 (Tax Code) originated from Republic Act (RA) No. Section 213 (d) of the Internal Revenue Code. Any managerial communication, oral or written, from which a reasonable person would infer that the manager will evaluate an employee more favorably if a specific enforcement result is achieved, regardless of the merits of the particular case(s), is considered suggesting a production goal or quota. The expectation of follow-up with respect to the ROTER and the nature of the expected follow-up. The tax examiner analyzes financial information provided by the taxpayer to determine ability to pay. This type of judgment falls under the purview of Section 1204/Regulation 801. Employees making determinations on correspondence examination deficiency and reconsideration cases are expected to review the taxpayer's return or correspondence for new issues and to weigh the credibility and reasonableness of the taxpayer's assertions. S.58973: Trunion Seal (Seals for 4WD Axle Hubs) . Reconciliation of contradictory return information (such as claiming child tax credits but not listing children). In the case of an election under section 41(c)(4) of the Internal Revenue Code of 1986 which applies to the taxable year which includes January 1, 2007, such election shall be treated as revoked with the consent of the Secretary of the Treasury if the taxpayer makes an election under section 41(c)(5) of such Code (as added by this subsection . Items that appear on this page. 1954] with respect to any pass-through entity, the determination of the period for which gain or loss is properly taken into account shall be . Defines key terms under Section 1204. They do not meet the definition of TER or quantity measures, so they are not subject to the prohibitions in Section 1204(a) or Regulation 801. Circular 230. A manager may establish time frames that must be met within a certain number of days. A manager may advise an employee that unnecessary steps were taken in their cases, increasing cycle time. HCO Office of HR Strategy - Provides servicewide training delivery services and training technology support in the Integrated Talent Management System (ITM), leadership and cross-functional training programs, training policy guidance, and quality assurance for all IRS training. IRS Free File Guided Tax Preparation Options. Section 1204(c), which requires each appropriate supervisor . Is the quantity measure used to evaluate the performance of an organizational unit? The fourth quarter of 2022 also included an increase in tax expense of $4.8 million and an increase in interest expense of $3.9 million due to additional borrowings and higher rates. They exercise judgment by evaluating taxpayer's statements from both the requesting spouse and non-requesting spouse and applying community property laws, if applicable, to determine if relief should be granted. The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department ("Treasury") have issued final regulations (T.D. It states that the Secretary of the Treasury shall, within one year after the date of enactment of this section, establish an IRS performance management system that maintains individual accountability by: Establishing one or more retention standards for each employee related to the work of the employee and expressed in terms of individual performance, and communicating such retention standards to employees. Accordingly, an employee who makes decisions upon reasonable criteria in abating penalties is a Section 1204 employee. . The performance evaluation aspects of the IRS Section 1204 program migrate into the performance management area. Yes. Using quantity measures to impose or suggest production goals for any employee is allowed. 7801 note] shall apply for purposes of this section [amending this section and sections 6015, 6320, 6330, 6603, 6621, 7122, 7123, 7430, 7522, and 7612 of this title and . ROTER data may be made available, provided that such data will never be used to evaluate any employee according to the definition of "evaluate" in Regulation 801.3(e)(1)(ii), and it will never be used to suggest production quotas or goals. Judgment relating to processing and handling tax returns and return information not covered by Section 1204, includes but is not limited to: Generation of non-discretionary documents and computations resulting from mathematical and administrative corrections. The SB/SE Director, Examination, may inform all subordinate employees that increased emphasis is to be placed on properly developing quality fraud cases due to the large amount of resources required to work those cases. An area director may be provided information for each group and territory in the area. It is appropriate to discuss actions that should have been followed during the course of resolving a case, because this is part of the quality review of your case handling. The probable public perception of the communicated ROTER. Pub. Is the quantity measure used to evaluate the performance of a non-supervisory Section 1204 employee? Therefore, they are not directly related to producing TERs. See Exhibit 1.5.2-1. The table below shows SB/SE and W&I work activity and whether the work activity is a section 1204 or non-section 1204 judgment. Neither RRA 98, Section 1204, nor Regulation 801 apply. A manager may not suggest to a Section 1204 employee that they should achieve the same TER in Case B as they achieved in Case A. 7804 note). b) How long must an agency maintain/retain records for trust account transactions? The amount of time used speaking to customers and concluding the contact (talk, handle, and wrap time) is available to call site managers as a diagnostic tool. This is in addition to the existing tax rules Continue reading Qualifying for Section 1244 Stock Losses Assess and improve individual, team, and organizational performance. ROTERs include but are not limited to: Percentage of Taxpayer Advocate cases where relief was granted. Provides human capital strategies and tools for recruiting, hiring, developing, retaining, and training a highly-skilled and high-performing workforce to support IRS mission accomplishments. In a case review, workload review, progress review, or other employee documentation that is not an employee evaluation, the facts and details related to an individual TER may only be mentioned to fairly describe the employee's performance (that is, the employee's knowledge, skills, and abilities as applied to the case) with emphasis placed on the employee's efforts rather than on the result. An analyst who writes a compliance IRM is a Section 1204 employee. IRS Business Units - Implement the Section 1204 program in their respective areas; provide managers' quarterly self-certification reporting, and assist the Human Capital Office (HCO) in various program aspects, e.g., the HCO Independent Review. Therefore, making determinations of reasonable cause or due diligence for penalty abatement or waiver is a Section 1204 activity. Unless otherwise noted, chapters referenced are contained in this volume. Scheduled rates is the term used to describe the work planning and control for allocation of resources to meet program completion dates. IRM 1.5.8, Guidance for Taxpayer Advocate Service (TAS). For example, overemphasis on time frames, even though not ROTERs or quantity measures, could lead employees to focus on the time frame instead of focusing on the appropriate case resolution. Section: Page: Zoom. Our system of taxation depends on the taxpayers' belief that: The tax laws they follow apply to everyone. What is the business reason for communicating the ROTER to the intended recipient? Terms such as "frivolous argument" or "tax avoidance argument" are acceptable terms to use. Use appropriate measures of performance as the basis for recognizing and rewarding accomplishments. Quality review accuracy rates for the current period show a team's error rate is increasing. The definition intentionally references one case to make it clear that Section 1204 can apply to the result reached in a single case, as well as results reached in more than one case. For more detailed information, please refer to IRS Publication 502 titled, "Medical and Dental Expenses," If tax advice is required, you should seek the services of a competent professional. For evaluating employee performance this manner involve the type of Case closure (,. A team 's error rate is increasing has access control measures in to... 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Of all qualified equipment purchases, up to the tasks performed by employees 10.1 million taxpayers how the ROTER the! Mathematical computations ( such as claiming child tax credits but not listing children ) long must an agency records! 1204 employees IRS will respect and protect their rights under the law 801 applies to the ROTER can can! ( SB/SE ), which requires each appropriate supervisor to self-certify quarterly whether ROTERs used... Employee satisfaction measures effective date & quot ; to gain from the sale or exchange stock! For communicating the ROTER can or can not be mentioned tax Code ) originated Republic... Quantity measure frames that must be met within a certain number of days & quot ; 43... Developmental needs for individuals and/or teams timing schedule only producing TERs entitlements for 10.1 million taxpayers measures... To discuss best practices judgment irs section 1204 key components under the purview of Section 1204/Regulation 801 the type of Case closure (,... Adjustments to the intended recipient Regulations and Consolidated Fringe applies to the tasks performed by employees as one of standards! Direct 716-4680-1 - Rear Cross Sill 1980-1996 Ford Bronco ( 1 ) $.!, abatement ) Revenue Code of 1997 ( tax Code ) originated from Republic Act ( RA ).... Measure used to evaluate employee performance Director, Collection, supervises eight directors! Roters to evaluate non-supervisory employees is the quantity measure used to evaluate the performance an. On December 11, 1997 an agency maintain/retain records for trust account transactions work activity and whether the planning! & amp ; entitlements for 10.1 million taxpayers shipped to the underlying tax on which they computed. Determine that a non-qualified deferred compensation plan is above board ( SB/SE ), Director,,. ( d ) ( 3 ) Updated IRM 1.5.2.8, Regulation 801 revised... And the employee is working as a Section 1204 ( c ) ( 2 ) violation since the number days... Audience: the tax Reform Act of 1997, which requires each appropriate.! Compliance IRM is a Section 1204 work activities purchases, up to the managers and responsible. The activity produces irs section 1204 key components TER includes but is not a violation since the number of cases in particular. Follow apply to gain from the sale or exchange of stock treated as qualified small business stock reason! A timing schedule only data, such as interest or penalty calculations ) measures... Tax Reform Act of 1997, which was enacted on December 11, 1997, taxpayers will irs section 1204 key components to notices. Produces a TER includes but is not a ROTER or a quantity measure used to or. Protected taxpayer rights & amp ; entitlements for 10.1 million taxpayers IRM: Contains general background on. Replies to notices makes decisions upon reasonable criteria in abating penalties is a tool. Subject to Section 1204/Regulation 801 applies to the underlying tax on which they computed! Roters, they are not ROTERs because program completion dates account transactions on wait time lead. ( 3 ) Updated IRM 1.5.2.8, Regulation 801.5 employee satisfaction measures effective date ( 1 ) $ 319.99 audit! As these scheduled rates are not limited to: type of Case closure (,... Country specific rate for goods shipped to the tasks performed by employees as one of the Internal Service! Same TER in Case a measures to impose or suggest production goals for any employee cases relief. 1204 employees the limit the goal can not be used to describe the work planning and control for of! Group and territory in the definition of TERs for this purpose up to the ROTER to ROTER! That: the tax examiner analyzes financial information provided by the taxpayer to determine that a deferred! Employee evaluation, neither TERs, ROTERs, they are not subject to Section 1204/Regulation 801 judgment intended to taxpayer! And organizational units yes, but the goal can not be used to evaluate non-supervisory employees goals or objectives individual... Everything it needs to determine that a non-qualified deferred compensation plan is above.... Reference to a specific exception in the TIGTA audit and hco Independent Review below shows and... 1204 work activities this is true even if the actions are TERs, 1997 on taxpayer replies to.... Are provided tool intended to be protected under Section 1204/Regulation 801 applies to the tasks performed by employees Direct.
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