Location: Burlington,VT, USA
This job was posted by : For more information, please see: IS THE SMALL BUSINESS/SELF EMPLOYED (SB/SE)DIVISION? \ \ A description of the business units can be found at:\ \ Vacancies will be filled in the following specialty areas:\ SB/SE DEPUTY COMMISSIONER EXAM\ \ The following are the duties of this position at the full working level. If this vacancy includes more than one grade and you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and receive training to help you grow in this position.Conducts independent examinations of the most complex estate and gift returns with a considerable number of complex and unusual issues requiring extensive tax law research, investigation, and analysis.Determines the issues and audit techniques needed to resolve issues. Determines the nature of included assets, analyzes transactions, investigates underlying facts, evaluates the fair market value of real estate, business interests, and other type of financial and investment assets for assigned returns. The incumbent must conduct extensive legal research. The incumbent analyzes the taxpayer\'s legal documents to identify the transferred interest. The incumbent relies on knowledge of state laws (i.e. property, contracts, business, inheritance, and probate) to determine the application of federal estate and gift tax laws. The incumbent may need to recharacterize transactions based upon an analysis of legal instruments and fact patterns.Determines the value of transferred property using investigative and valuation techniques: including reviewing appraisals and valuation data, analyzing complicated legal documents, transactions, and case law, and applying Federal, state, and foreign laws.Coordinates with SBSE Counsel employees and IRS Office of Chief Counsel to develop audit techniques, legal arguments, and litigation strategy for significant cases with novel issues.Assists SBSE Counsel in trial preparation for estate and gift tax cases of significant importance. Contributes to Program objectives by identifying emerging issues and requesting SBSE Counsel collaboration. Collaborates with assigned SBSE Counsel to develop examination requirements and analysis to resolve the estate and gift tax impact of the emerging issue.QualificationsBASIC REQUIREMENT : \ All GRADES -- SELECTIVE PLACEMENT FACTOR: To be eligible for this position, at any grade level, applicants must demonstrate the following: Knowledge of Legal Industry, including legal practices, federal codes and regulations, and application of complex legal principles to facts. This knowledge may be met through experience and/or education. To meet this requirement, the applicant must demonstrate the following experience: Substantive knowledge of state and federal laws, judicial decisions and precedents, legal codes, court procedures, legal practices, legal instruments and documents, government regulations, executive orders, and agency rules specific to tax administration and compliance. Exceptional skill in researching, interpreting, examining, analyzing and applying relevant state and federal laws, regulations, related statutes, and sub-regulatory guidance, sufficient to produce written reports, relevant forms, instructions, explanatory publications, legal memoranda, proposed legislation, and other materials, sufficient to address taxpayer rights and responsibilities, propose tax legislation or regulation, and issue opinions and/or decisions specific to tax administration or compliance.\ \ In addition to meeting the basic requirement above, to qualify for this position you must also meet the q alification requirements listed below:\ \ Specialized Experience GS-11: You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-09 grade level in the Federal service. Specialized experience for this position includes: Experience working in a legal environment whereby you provided technical advice on legal requirements, conducted legal research and analysis, drafted/authored written opinions, decisions, and/or proposals on matters involving federal tax laws, rules, regulations, and practices. Experience must be sufficient to demonstrate- Knowledge of Federal tax laws, various State and foreign laws, judicial decisions, and precedents; Organizing, analyzing, and managing voluminous case information; Skill in researching and evaluating complex legal questions involving state and federal laws; Ability to reach a determination and take appropriate action to impact compliance with federal laws.\ \ OR \ Three (3) full years of progressively higher level graduate education in Law from an Accredited College or University\ \ OR \ a Ph.D., or equivalent doctoral degree education in Law from an Accredited College or University\ \ OR \ an LL.M from a ful