Chief Counsel Signature Block Modified

Date: January 19, 2021

Subject:
Chief Counsel Signature Block

Cancel Date:
Until Further Notice

The purpose of this Notice is to advise all Chief Counsel employees of a necessary modification to the signature block on all documents signed and filed with the United States Tax Court, correspondence sent to the Department of Justice, and other documents prepared on behalf of the Chief Counsel, effective after noon on January 20, 2021.

Chief Counsel Signature Block

I.R.C. § 7452 provides that the Commissioner shall be represented by the Chief Counsel for the Internal Revenue Service or his delegate in proceedings in the United States Tax Court. Michael J. Desmond tendered his resignation as Chief Counsel effective as of noon on January 20, 2021. Commencing after noon on January 20, 2021, William M. Paul is the Acting Chief Counsel. Accordingly, the following signature block should be used on all documents to be filed with the Tax Court that are signed and dated after noon on January 20, 2021:

A similar signature block should be used on all other documents and correspondence signed and dated after noon on January 20, 2021, for which the appropriate titular authority is the Chief Counsel, e.g., letters addressed to the Department of Justice. If a Tax Court document has been signed by a petitioner or petitioner's representative (e.g., stipulated decision, stipulation of facts, or joint motion), but has not been sent to or e-filed with the Tax Court before noon on January 20, 2021, the document need not be reexecuted. Instead, a sticker or label with the new Acting Chief Counsel signature block may be affixed over the old signature block. For other documents, the signature page should be modified and reexecuted to reflect the new signature block.

For those cases in which Mr. Paul previously represented the taxpayers and other cases from which he is recused, the following signature block should be used:

Local counsel should advise local Appeals offices of the need for the new signature block in decision documents that will be signed and dated after noon on January 20, 2021.

If you have any questions regarding the matters discussed in this Notice, please contact the Office of the Associate Chief Counsel (Procedure & Administration) at (202) 317-3400.

Kathryn A. Zuba
Associate Chief Counsel
(Procedure & Administration)