General Attorney (Tax) - Senior Technician Reviewer (Branch 7)

Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves. For positions with an education requirement, or if you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. An official transcript will be required if you are selected.

A college or university degree generally must be from an accredited (or pre-accredited) college or university recognized by the U.S. Department of Education. For a list of schools which meet these criteria, please refer to Department of Education Accreditation page.

FOREIGN EDUCATION: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. For further information, visit: http://www.ed.gov/about/offices/list/ous/international/usnei/us/edlite-visitus-forrecog.html.

The Office of the Associate Chief Counsel (Passthroughs and Special Industries) provides legal advice, litigation services, and litigation support on tax matters involving passthrough entities, the classification of entities, passive activity losses, excise taxes, estate and gift taxes, oil and gas and other natural resources, at-risk rules, and tax credits to the Internal Revenue Service, the Office of Chief Counsel, the Department of Justice, Treasury, and where appropriate or required, to other government agencies and the public.

As Senior Technician Reviewer, the incumbent is responsible for some of the most complicated, difficult, and unusual assignments and projects in Passthroughs and Special Industries. In consultation with the Branch Chief, the Senior Technician Reviewer is responsible for the assignment of selected cases and projects to the attorneys within the Branch and for review of the work products. The primary work of the Branch involves developing and considering recommendations for enactment of Internal Revenue legislation and the promulgating published guidance (regulations, revenue rulings, and revenue procedures) preparing of private letter rulings, technical advice memoranda, and other written legal advice based on tax issues submitted by taxpayers and their representatives, state and federal agencies, and other Chief Counsel and IRS offices.

In addition, the Branch performs activities in the assigned subject area including providing legal assistance and advice to trial attorneys in the field in connection with actions on decisions, preparation of briefs, handling of unusual technical problems, preparation for the trial of cases involving complicated technical issues, and appeal recommendations in Tax Court and refund cases. Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere. Problems presented cover a broad range involving numerous questions requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases and other technical materials.

As a General Attorney (Tax) Senior Technician Reviewer, you will:

• Act as a legal and technical consultant to the Branch Chief, Deputy Associate Chief Counsel, Associate Chief Counsel, and to other officials in the Office of Chief Counsel on the legal and policy matters concerned with the work of the Branch, or which may affect the work of other branches of the office, or other components of the Office of Chief Counsel. These matters involve the Senior Technical Reviewer in detailed and extensive research on complicated legal problems, and the development of recommendations as to the positions to be taken by the Branch and the Office.
• Act as a reviewer, and in some cases as the initiating attorney, for assignments and projects involving the development and drafting of Internal Revenue legislation and regulations, considering recommendations for enactment of legislation and the promulgation of regulations, private letter rulings, revenue rulings, technical advice memoranda, and other advice memoranda dealing with tax problems submitted by taxpayers and their representatives, state and federal agencies, and other Chief Counsel and IRS offices.
• Act as principal attorney in charge of recommending the policies and developing the procedures and regulations implementing new or amended legislation for specific areas of tax law and be responsible for ensuring that these policies, procedures, and regulations are consistent with the intent of the law and are administratively sound, efficient, and economical in operations.
• Mentor, train, and develop attorneys in the technical subjects of the Branch and the day-today workflow of the organization and the IRS.
• Perform activities in the subject area of the Branch including legal assistance, document review, appellate recommendations, and litigation support. Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere. Problems presented cover a broad range of tax law issues involving numerous questions requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases and other technical materials.
• Make recommendations on the need for initiating, consolidating, or eliminating projects. Act as project manager, assign (in consultation with the Branch Chief) work to the attorneys within the Branch, advise them on the approach to take, review work products, and provide the Branch Chief with performance feedback on work performed.

This is not an all-inclusive list.

In order to qualify, you must meet the education and/or experience requirements described below. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.

To qualify for this position of General Attorney (Tax) Senior Technician Reviewer you must meet the qualification requirements listed below by the closing of this announcement:

Basic Requirements for General Attorney (Tax) Senior Technician Reviewer:

• Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; AND
• Applicants must be an active member in good standing of the bar of a State, U.S. Commonwealth, U.S. territory, the District of Columbia, or the Commonwealth of Puerto Rico;

GS-15 Experience Requirements:

• 1 year of general professional legal experience from any area of expertise; plus
• 3 years of professional legal tax experience

Professional Legal Tax Experience is defined as: Comprehensive knowledge of Internal Revenue tax laws and the regulations and decisions applicable thereto, including particular knowledge and experience relating to one or more of the following areas of passthrough taxation:

• Excise taxes, including but not limited to those imposed under Chapter 31 (retail excise taxes on fuel, heavy truck and trailers, etc.), Chapter 32 (manufacturers' excise taxes on tires, motor and aviation fuels, coal, sporting goods, medical devices, etc.), Chapter 33 (facilities and services excise taxes on communications, air transportation, etc.), Chapter 35 (wagering excise taxes), Chapter 36 (certain other excise taxes on water transportation, highway vehicle use, etc.), Chapter 38 (environmental excise taxes), Chapter 49 (excise tax on cosmetic services), and Chapter 51 (designated drugs) of the Internal Revenue Code
• The fuel, aviation, heavy vehicle, chemical, pharmaceutical, or other relevant industry, including related federal government agency experience
• Tax litigation

At least one year of this experience must be equivalent to the work performed at the next lower grade/level position in the federal service (GS-14).

Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience.

Education Substitution: An LL.M. degree in the field of the position (tax, GLS-related, orP&A- FOIA/Disclosure related field) may be substituted for the one year of the general legal experience listed above.

Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. One year of experience refers to full-time work; part-time work is considered on a prorated basis. To ensure full credit for your work experience, please indicate dates of employment by month/year, and indicate number of hours worked per week, on your resume.