The IRS and the Tax Division have implemented a nationwide guilty plea
program in administratively investigated General Enforcement Program cases.
Under this plea program, administratively investigated criminal tax cases may be
referred directly and simultaneously from the IRS to U.S. Attorneys' Offices and
the Tax Division in Washington, D.C., where only legitimate source income is
involved (e.g., no narcotics or organized crime) and where taxpayer's
counsel indicates during such early stage in the investigation taxpayer's
wish to enter a guilty plea consistent with the Tax Division's major count
policy. Following IRS consideration to ensure legal sufficiency, abbreviated
written referrals from the CID and District Counsel to both the U.S. Attorney and
Tax Division will permit an accelerated means for cases to be disposed of where
the target of the investigation does not contest criminal liability. All
authority to conduct plea negotiations rests with the U.S. Attorney
and Tax Division and not the IRS. Tax Division and U.S. Attorney liaison
attorneys for such program will ensure compliance with the Tax Division's major
count policy. See Memorandum to all U.S. Attorneys from Acting Assistant
Attorney General, Tax Division, regarding Program for Entering into Plea
Negotiations on Title 26 Offenses Prior to Formal Review by District Counsel's
Office and Tax Division (Feb. 25, 1986). See also IRM 9620.