In a chief counsel notice (CC-2012-002) dated Dec. 2, 2011, the Internal Revenue Service (IRS) instructed its attorneys to argue that a federal common-law alter-ego analysis is the most appropriate way for courts to resolve alter-ego claims in federal tax collection cases, emphasizing that the position is legally correct and consistent with the principle of uniformity of federal tax enforcement.
The notice instructs IRS attorneys, in their collection efforts, to undertake as an alternate argument a two-step analysis for determining alter-ego liability. This should include:
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