Justice Manual § 6-5.210

The Tax Division will handle summons cases involving sensitive or novel issues, including summonses issued to or involving:

attorneys

tax practitioners, as defined in 26 U.S.C. § 7525

any entity operated exclusively for religious purposes (see 26 U.S.C. § 501(c)(3))

the press or members of the news media (see 28 C.F.R. § 50.10 (setting out Department policy regarding obtaining information from, or records of, members of the news media))

tax accrual workpapers

foreign document requests

treaty partners or other matters with international implications

“John Doe” summonses

section 6050I

novel or complex Fifth Amendment claims

computer software and other non-traditional items

state and local agencies and courts

“designated summonses”

consent directives

tax shelter promoters

tax scheme and scam promoters

examinations regarding institution of summons proceedings

examinations into potential liabilities for penalties under 26 U.S.C. §§ 6700, 6701, 6707, and 6708

offshore records

FBAR penalties under 31 U.S.C. § 5314

other unique issues that may arise

The IRS will also refer to the Tax Division petitions to quash foreign document requests issued under 26 U.S.C. § 982. Litigation relating to these requests is similar to summons litigation.

The Tax Division may also refer to the United States Attorney’s Office for handling a summons that the IRS counsel has referred to the Tax Division. See Summons Enforcement Manual, https://www.justice.gov/tax/foia-library.