One of the ways that the student attorney resolves the client’s case is to submit to the IRS documents and a memorandum explaining the client case. We refer to this submission as a Notebook. The notebook is similar regardless of the type of case. Whether the student attorney submits an Offer in Compromise, a protest of a 30 day letter, a notebook to the Appeals Division or Chief Counsel in response to a Notice of Deficiency or a request to the IRS to place a client in currently not collectable status the format and procedure are similar. Under the various substantive and administrative sections found on this web site are specific examples of the memorandum that must accompany each of these submissions. The samples are customized to provide a more specific example and provide in red the elements that must be included in the memorandum as a type of check list of items to include.
In each office there is a redacted sample of several types of completed notebooks, with exhibits. However, these are not to be relied on except as an example of what the completed product should resemble. Additional copies of notebooks are saved to the “T” drive under “sample bank of notebooks” for the student attorney’s. The T drive is not open to the public so there is no unauthorized disclosure of client information.
Completing the Notebook
Once the memorandum is reviewed and approved by one of the Directors, the notebook must be assembled. Exhibits that support statements contained in the memorandum should be included. These exhibits may be either provided by the client or you have independently secured them during the course of investigating the facts of the case. From the sample you will see that the exhibits are referenced in the memorandum and then tabbed in the original package A-Z etc. If the exhibits contain multiple pages, then number the pages within the exhibit as A-1, A-2 etc. Below is a link to pre-typed exhibit letters for your use. This provides easy reference to the reader and provides a specific way for the student to identify a specific page and item in the memorandum.
As is specified throughout the website, always make an exact copy of the complete notebook that is sent out. This copy is referred to as the “file” copy. The only difference in the file copy and the original is that prior to each exhibit place a sheet of paper with the annotation of the exhibit to follow rather than using tabs. The Directors will initial the file copy of all notebooks before mailing. The use of exhibit letters allows ease of scanning.
Once the file copy is initialed, the student attorney should scan the entire package into the “T” drive under the client’s number and under the sub folder “IRS”. This allows for an electronic historical record of all our files.
The Directors will categorize each notebook and save a separate copy to a “T” drive “sample bank of notebooks.
