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Internal Revenue Service General Attorney (Tax) in San Francisco, California

As a Chief Counsel attorney, the incumbent is assigned to a group providing legal counsel to Small Business/Self-Employed (SB/SE) and other Counsel and IRS activities, which are responsible for serving specific groups of taxpayers. Chief Counsel attorneys represent the government in Tax Court and provide advice to IRS field staff on issues in which Service position is established. Attorneys in the SB/SE organization specialize in tax litigations in the U.S. Tax Court, primarily involving tax issues impacting individuals, including individual international tax issues, partnerships, S corporations, LLCs, LLPs, estate and gift, and whistleblower awards.As a General Attorney (Tax), you will:Receive assignments of the most difficult and complex types of work in one or more of the following functions within the office depending upon the specialty of tax to which assigned - Tax Litigation or General Litigation.Tax Litigation:You will be assigned cases docketed in the United States Tax Court. Duties may include preparation of answers to petitions, replies, motions and any other documents germane to proper handling of the case.Ascertain the legal correctness of the position(s) determined in the statutory notice of deficiency as well as preparation for the case for trial and settlement.Provide legal advice and assistance to the IRS, Independent Offices Appeals and other Division Counsel concerning issues within their area of topical jurisdiction. Research, analyze facts, and write legal opinions in response to questions.For District Court and Claims Court: Review pleadings and files and prepare defense letters to the Department of Justice, Tax Division setting out the Commissioner's position on defense of a suit involving merits of the tax, etc., including in appropriate cases, discussing the propriety of jurisdiction, any suggested motions that may be appropriate, the particular defense that is recommended and whether or not the case is one that the Department of Justice may settle without further coordination.General Litigation:Furnish advice and opinions to the IRS, the Department of Justice, etc., in any matter (court and non-court) incident to the assessment and collection of taxes. Advise field administrative officers, handle the legal work, and assist the Department of Justice and United States Attorneys in cases involving tax matters.Recommend which suits should be brought or interventions or counterclaims filed by the Government in connection with the collection of internal revenue taxes or the recovery of erroneous refunds thereof and the basis for defense of tax litigation suits against the United States.This is not an all-inclusive list. If selected at a lower grade level, you will have the opportunity to learn to perform the duties of the position and will receive training to help you grow in the position.This is an open-continuous/standing register announcement that is open 02/22/2024 to 09/30/2024. Applicants will be referred to the selecting officials and referral lists issued as vacancies occur.Cutoff for receipt of applications will be midnight EST on the date a vacancy has been determined. Applications received after that date may be considered on future referral lists. Notifications will be sent to applicants when application has been referred or not referred. The announcement may close prior to 09/30/2024 if management has succeeded in filling all vacancies and has no further use for a standing register.

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