Freedom of Interpretation: IRS Data, Access, and Case Strategy
Frost Law brings decades of proven results to every case we take. We fight for clients who need counsel they can trust.
Every taxpayer generates an extensive digital record inside IRS systems, much of which practitioners can request once they know the correct channel. Getting the records is only part of the work. Account data arrives as transaction codes, module entries, and date sequences that only make sense to a reader familiar with the underlying conventions.
This session opens with the sources of data the IRS collects through third-party reporting and generates internally, then covers the authorization and disclosure routes that make those records available to practitioners. That includes transcript requests and Freedom of Information Act requests, and how account structures such as mirrored assessments determine the scope a Form 2848 or Form 8821 must cover.
From there, the session turns to interpretation. Rebecca Sheppard, Esq., and Peter Haukebo, Esq., walk through account transcript and tax module entries, including TC 971 action codes, and apply Document 6209, the IRS's public reference guide to transaction and account codes, to show what a record establishes about notice timing, statute computation, and the procedural history of a matter. The session also addresses third-party contact requirements under the Taxpayer First Act, along with the changes proposed under the pending Taxpayer Assistance and Service Act, as part of how the IRS gathers information it does not already hold.

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