What is the potential undesirable outcome that could come from the misuse of the ROTER? The Final Regulations aim to . 5. Each appropriate supervisor will certify quarterly by letter to the Commissioner of Internal Revenue whether TERs are being used in a manner prohibited by Section 1204(a). ROTERs may be used for forecasting, financial planning, resource management, and the formulation of case selection criteria. About Us. Also provides guidance in response to HCO questions concerning Section 1204 law. The Daily Workload report shows how many cases are in the inventory that can be worked on a specific day. Also included are RR 10-2008, RR 16-2008, Consolidated Withholding Tax Regulations and Consolidated Fringe . Internal Revenue Service and has lawful access to tax returns." Thomas v. United States, 890 F.2d 18, 21 (7th Cir.1989) (IRS's release of court's opinion in tax case to newspaper which then published article based on the decision was not an unauthorized disclosure because the information was obtained from the court's opinion). The IRS Section 1204 program requires the cooperation and assistance of many IRS organizations. U.S. TREASURY INSPECTOR GENERAL. For more detailed information, please refer to IRS Publication 502 titled, "Medical and Dental Expenses," If tax advice is required, you should seek the services of a competent professional. Whether the way a ROTER is used violates Section 1204. Protected taxpayer rights & entitlements for 10.1 million taxpayers. The revision authorizes using quantity measures to evaluate the performance of supervisory employees, non-Section 1204 employees, and organizational units. A manager cannot advise or imply that an employee should achieve the same TER in Case B as they achieved in Case A. In a case review, a manager discovers that an employee failed to consider all relevant facts or correctly apply laws resulting in an incorrect proposed assessment of $1 million. The group manager describes best practices to accomplish this goal. Yes. Accordingly, an employee who makes decisions upon reasonable criteria in abating penalties is a Section 1204 employee. The performance evaluation aspects of the IRS Section 1204 program migrate into the performance management area. Do your taxes online for free with an IRS Free File provider. To get the exclusion a taxpayer must own . squad or ambulance crew, as those terms are defined in section 1204(9)(A) of the Omnibus Crime Control and Safe Streets Act of 1968 which is codified in 42 U. S. C. 3796b(8)(A) and as . (Here is how the U.S. Court of Appeals for the Sixth Circuit summed up the TIGTA Report: "Those findings include that the IRS used political criteria to round up applications for tax-exempt status filed by so-called tea-party groups; that the IRS often took four times as long to process tea-party applications as other applications; and that . A revenue agent is assigned to an examination involving a taxpayer who has claimed improper deductions in a tax shelter. In documenting the performance review, and in any subsequent evaluation, focus on documenting the appropriateness of the decisions, in the context of the employee's critical job elements and standards, and not on documenting the specific actions that were or were not taken. POPULAR FOR TAX PROS. A quantity measure, by definition, is outcome neutral. Requiring an employee to refer a certain number of cases for prosecution during a particular period of time. Making periodic determinations of whether each employee meets or does not meet the employees established retention standards. It is important that, in sharing work plan data, managers at all levels should be cautious not to share ROTERs or the results of analyses in any way that impose or suggest a production quota or goal against which employees will be evaluated. HCO - Provides overall program direction for the IRS Section 1204 program. The activity produces a TER and the employee is working as a Section 1204 employee. The manner in which the communication is delivered. Circular 230. (1) by substituting "section 4303" for "section 4323" could not be executed because the phrase "section 4323" does not appear in text subsequent to the intervening amendment by Pub. A Section 1204 Manager is a manager/supervisor at any level who supervises one or more Section 1204 employees. This use of a quantity measure does not violate Regulation 801 or any IRM provision. (3) Updated IRM 1.5.2.8, Regulation 801.5 Employee satisfaction measures effective date. The tax examiner analyzes financial information provided by the taxpayer to determine ability to pay. 1 OECD calculations demonstrate that nearly seven trillion of annual investment in . In October 2005, Regulation 801 was revised to allow imposing or suggesting quantity goals for organizational units. Pub. Emphasizing the amount of cases in the inventory may result in premature closure. An area director or technical services employee (whose group does not conduct taxpayer examinations and is not in that chain of command) observes a substantial increase in the number of fraud referrals in a territory. Use of the Reasonable Cause Assistant by AM results in this work activity being considered Non-Section 1204 Judgment for Adjustment personnel. and 1202(c)(1)(B) of the Internal Revenue Code of 1986 [formerly I.R.C. The performance of any one unit at any level of the organization must not be used as a standard by which the performance of other units are evaluated due to differences that exist in: The RRA 98, Section 1204 and Regulation 801 Decision Table can be used to determine if a particular measure/data may be used for a specific purpose. An official website of the United States Government. A manager may inform a revenue agent that, based on the facts of the case to date, a penalty should be asserted in a particular case. Form W-2. Territory/department and area/operation information may be shared with groups, but only for such functions as mentioned in (c) above. For example, the tax examiner processing the manual refund or working the payment tracer according to non- discretionary criteria contained in the appropriate section of the IRM is not performing enforcement work. One or more cases is a term used in the definition of a ROTER, specifically "TERs reached in one or more cases." In this scenario, the employee has not exercised judgment in regard to recommending or determining whether or how the IRS should pursue enforcement of the tax laws. This type of decision making in determining the ability to pay requires the type of judgment covered by Section 1204/Regulation 801. In other instances, taxpayers will respond to penalty notices by presenting new facts indicating that the penalty does not apply. The exercise of judgment in applying tax law refers to the process of making decisions to recommend or determine whether or how the IRS should pursue enforcement of the tax law (including but not limited to the taxpayer's tax liability or ability to pay). This clearly involves discretion in that two employees working the same case can reasonably come to different conclusions as to the acceptability of the taxpayer's assertions. united states securities and exchange commission washington, d.c. 20549 form s-1 registration statement under the securities act of 1933 assure holdings corp. Key Parts 0480 . Although neither Section 1204 nor Regulation 801 contain restrictions on TER use, the IRS determined that managers must not include TER outcomes in a written performance appraisal or employee evaluation. VAT (Sales tax) is applied at the country specific rate for goods shipped to the UK or the EU. IRM 1.5.3, Manager's Self-Certification and the Independent Review Process. Rather, the employee has made a decision to refer the information to Criminal Investigation for its analysis. ROTER information may be disclosed to managers if it relates to performance of units under their span of control. Deductible Medical Expenses Yes, but not simply in terms of quantity of work done. Other penalty abatements arise due to adjustments to the underlying tax on which they are computed. This is allowable as an organizational or employee goal, but the goal cannot be used in the evaluation of these employees. Section 1250 is a section of the United States Internal Revenue Service Code that states that a gain from selling real property that has been depreciated should be taxed as ordinary income , to . You must also determine the organizational unit or type of employee to which the measure/data is applied. Form 10-K (annual report [section 13 and 15(d), not s-k item 405]) filed with the SEC Performance measures based on quality measures may also be used to impose or suggest production goals for any employee. Below are two lists which may help determine whether an expense is eligible. No. Section 1204 does not apply to quantity measures; however, Regulation 801 does. No. Jan 2, 2023 - The Section 179 deduction for 2023 is $1,160,000 (this is up from $1,080,000 in 2022). Section 1202 of the Internal Revenue Code . Judgment relating to processing and handling tax returns and return information not covered by Section 1204, includes but is not limited to: Generation of non-discretionary documents and computations resulting from mathematical and administrative corrections. See Regulation 801.3(a). Yes. Using quality measures to evaluate any employee is allowed. The amount of talk, handle, or wrap time is not a ROTER; it is a statistic which should be discussed in conjunction with Quality and Customer Service. As these scheduled rates are not ROTERs, they are not subject to Section 1204/Regulation 801. Section 1204/Regulation 801 provides a specific exception in the definition of TERs for this purpose. 4wd T5-R Cross Country XC Front lowers approx. An area director may be provided information for each group and territory in the area. "Rules similar to the rules of paragraphs (2) through (6) of section 1001(b) of the Internal Revenue Service Restructuring and Reform Act of 1998 [Pub. Quantity measures may be used to impose or suggest production goals for any organizational unit and may be disseminated as determined by each organizational unit. The definition of an "employee evaluation" specifically includes only the five items above. 4215, 4220, 4225, 4235, 4245, 4255, 4260, 4265, 4275 Draft Control Disc Draft Control & Lift Components - MF S.41482 Lever Assembly Lever - Valve Control Ref: 189370M91 35, 35X, 65, 765 S . The IRS regulations on the use of statistics are designed to make sure that records of tax enforcement results (ROTERs) are not used to improperly influence the handling of taxpayer cases. See Regulation 801.6(c). If your adjusted gross income (AGI) was $73,000 or less, review each provider's offer to make sure you qualify. Our system of taxation depends on the taxpayers' belief that: The tax laws they follow apply to everyone. It states that the Secretary of the Treasury shall, within one year after the date of enactment of this section, establish an IRS performance management system that maintains individual accountability by: Establishing one or more retention standards for each employee related to the work of the employee and expressed in terms of individual performance, and communicating such retention standards to employees. Quantity measures may be used to evaluate the performance of any organizational unit and may be disseminated as determined by each organizational unit. No. Regulation 54 Section 845 Tax Exemption . Including ROTERs in self-assessments does not violate IRS RRA 98 Section 1204 or Regulation 801; however, to dispel the appearance of impropriety, it is IRS policy that bargaining unit and non-bargaining unit employees should not use ROTERs in self-assessments. In the case of a key employee (within the meaning of Section 416(i)(1)), Subsection (a) shall not apply to any IRS Section 125 Plan Year if the . Included in such a discussion would be the nature of specific contacts and the quality of service provided to the customer. It is appropriate to discuss actions that should have been followed during the course of resolving a case, because this is part of the quality review of your case handling. Models Maxxum 5120, 5130, 5140, 5150, 5220, 5230 . CPPREP4125 - Transact in trust accounts (Release 1) Written Questions Question 4 a) Name the legislation and section that relates to keeping of records by a licensee in your state or territory. The area director or technical services employee may contact the territory manager to ask about the increase in the example above. ROTER data may be made available, provided that such data will never be used to evaluate any employee according to the definition of "evaluate" in Regulation 801.3(e)(1)(ii), and it will never be used to suggest production quotas or goals. Overemphasis on time frames, however, could lead employees to focus solely on the time frame instead of on the appropriate case resolution. Rules adopted under this subsection are routine technical rules as defined in Title 5, chapter 375, subchapter 2A. Using TERs or ROTERs to evaluate any employee is prohibited. Levies issued is a ROTER. While the quantity measure may be mentioned in discussions or evaluative recordation, the discussion with the employee must be conducted in terms of the critical job elements and standards. This type of judgment falls under the purview of Section 1204/Regulation 801. Using TERs or ROTERs to impose or suggest production quotas or goals for any employee is prohibited. Section 1231, 1245, and 1250 of the Internal Revenue Code (IRC) provide categories for different types of business assets and define how each will be taxed when there is a disposition. See Regulation 801.3(e)(2). L. No. See steps 4 - 7. Using quantity measures to evaluate supervisory employees is allowed, but may lead to a ROTER violation if organizational goals are used to directly determine a supervisory employee's performance rating. The work activity performed, not the employee's title, location or operating/functional division, identifies whether an employee should be considered a Section 1204 employee. Accounts Maintenance (working transcripts), Adjust/abate ASFR/A6020(b) assessment (reconsiderations), Processing ASFR/A6020(b) pre-assessment correspondence (other than P-5133 determinations and disputed income items). The review and discussion of an employee's performance on a case should be based on that case and not external matters (for example, TERs from other similar cases). AM procedures and guidance followed results in this work activity being considered Non-Section 1204 Judgment for adjustment personnel. As at 31 December 2022, the interest rate swaps cover 100% of the Group's term Sterling denominated borrowings of GBP176.5 million for the period . Purpose: This IRM provides guidance on the processes and procedures that apply to the Section 1204 program. This can be a valuable starting point for a discussion with an employee in respect to overall performance. The fourth quarter of 2022 also included an increase in tax expense of $4.8 million and an increase in interest expense of $3.9 million due to additional borrowings and higher rates. Quality measures may be used to evaluate non-supervisory employees. Using Records of Tax Enforcement Results (ROTERs) in self-assessments does not violate either Section 1204 of the IRS Restructuring and Reform Act of 1998 or the 26 CFR Part 801. Yes. See IRM 1.5.2.8, Regulation 801.6. A Section 1204 employee is an employee who exercises judgment in regard to recommending or determining whether or how the IRS should pursue enforcement of the tax laws. News Alert: The 2023 Section 179 Deduction Limit for Businesses is $1,160,000. Prohibited by Section 1204 and Regulation 801. In an employee evaluation, a manager may briefly state that a revenue agent was able to locate a significant amount of unreported offshore income, but should emphasize the particular efforts that made the TER noteworthy, and should not mention specific dollar amounts. Tax examiners or tax auditors working innocent spouse claims are considered Section 1204 employees for purposes of Section 1204/Regulation 801. Assessment of an employee's eligibility for incentives, allowances or bonuses. The determination of whether a matter is a Questionable Refund requires the exercise of judgment in determining tax liability - an analysis of legal principles, tax law, and the taxpayer's circumstances. A manager may make recommendations on enforcement actions in a specific case. Resolving discrepancies between information provided by the taxpayer and third party reporting. 9. XC Front lowers approx. IRC Section 409A determines when an employee is taxed for deferred compensation, including most types of stock-based compensation awards (see SC 10.2.5, SC 10.6.3, SC 10.6.4, and SC 10.6.4.2).). The definition specifically allows managers to discuss with employees the results that they achieved in individual cases. Further research to determine the reasons for high inventory, e.g., inappropriate case processing, insufficient allocation of resources, or a discussion of the results of program reviews are effective methods to ensure that the objectives are being met. Is the quantity measure used to evaluate the performance of: A performance measure may be based, in whole or in part, on a quantity measure. Yes. These rules reinforce the requirement that employees make decisions on pursuing enforcement of the tax laws (including but not limited to determining tax liability and ability to pay) that are based solely on the correct application of the law to the facts of each case and the exercise of reasonable administrative judgment in light of the circumstances of each taxpayer. Cycle time is not a ROTER, neither is overage. Determine if the measure/data is a quantity measure; if so, it's permissible use is governed by Regulation 801. Program Owner: The Human Capital Office (HCO), Office of HR Strategy (OHRS), Policy and Audits (P&A). The Electronic Code of Federal Regulations (eCFR) is a continuously updated online version of the CFR. 1.2 i (0) $758.88. IRC Section 471 small business taxpayer exemptions are modified. Form 9465. Inventory treated as non-incidental materials and supplies. Decisions on management resource allocation does not suggest a production quota or goal. Use appropriate measures of performance as the basis for recognizing and rewarding accomplishments. This IRM: Contains general background information on the use of enforcement statistics. which are outcome neutral and not ROTERs. 685 (1998). The deliberations undertaken in deciding reasonable cause criteria is the exercise of judgment covered by Section 1204/Regulation 801 because it weighs factors in particular cases; there is no set formula. This suggests a production quota or goal to the employee and is a Section 1204(a) violation. Employers engaged in a trade or business who pay compensation. TEPS is a tool employed in campuses to measure certain Section 1204 employee performance standards selected by management. 4,009 taxpayers. See Regulation 801.3(e)(3). Organizations that meet Section 501 (c) (3) requirements are . Section 501 (c) (3) is a portion of the U.S. Internal Revenue Code (IRC) and a specific tax category for nonprofit organizations. 409A valuations involve an appraisal of the fair market value of a company's common stock. Policy Owner: The IRS Human Capital Office is responsible for this IRM. L. 103-446, which directed the amendment of par. Idle time refers to the period of time in which an employee is not conducting or wrapping up telephone calls. (1) This transmits revised IRM 1.5.2, Managing Statistics in a Balanced Measurement System, Uses of Section 1204 Statistics. There were other changes too. The definition intentionally references one case to make it clear that Section 1204 can apply to the result reached in a single case, as well as results reached in more than one case. A manager cannot use a TER from a single case to evaluate an employee or suggest production quotas or goals. Non-routine disputed/disagreed issues resolving discrepancies when additional expertise is required. Employer's Quarterly Federal Tax Return. Form 2848. The IRS Section 1204 program requires the cooperation and assistance of many IRS organizations. Quantity measures consist of outcome-neutral production and resource data that do not contain information regarding the TER reached in any case or cases involving particular taxpayers. This is a full $80,000 increase from last year. Defines key terms under Section 1204. Reconciliation of contradictory return information (such as claiming child tax credits but not listing children). Wait time is a diagnostic tool intended to minimize taxpayer burden, not a ROTER or a quantity measure. Unless otherwise noted, chapters referenced are contained in this volume. The Commissioner may not hire any individual previously employed by the Commissioner who was removed for misconduct under this subchapter or chapter 43 or chapter 75 of title 5, United States Code, or whose employment was terminated under section 1203 of the Internal Revenue Service Restructuring and Reform Act of 1998 (26 U.S.C. | Find, read and cite all the research you need on . Assets are analyzed to determine equity and the taxpayer's ability to borrow. Statistics which measure taxpayer or other third party actions do not consider the exercise of judgment by employees in recommending or determining whether or how the IRS should pursue enforcement of the tax laws and, thus, are not ROTERs and Section 1204/Regulation 801 does not apply. The reconciliation or correction of math errors requires decision making, but that decision making is based upon the application of mathematical principles and does not require the exercise of judgment, e.g., weighing factors appropriately, deciding reasonableness, and determining credibility covered by Section 1204/Regulation 801. The IRS Key District concept was eliminated. Quality measures are determined by a specially dedicated IRS staff such as National Quality Review System (NQRS) analysts. Employee evaluation includes any written document used to appraise or measure an employee's performance to provide: Required or requested performance rating (annual, mid-year, ad hoc). A TER is not a quantity measure. 26 CFR 801, Balanced System for Measuring Organizational and Employee Performance Within the Internal Revenue Service. Mathematical computations (such as interest or penalty calculations). ROTERs include but are not limited to: Percentage of Taxpayer Advocate cases where relief was granted. Does the intended recipient have a need to know? This definition indicates when/where to use TERs and that ROTERs cannot be used. 1954] with respect to any pass-through entity, the determination of the period for which gain or loss is properly taken into account shall be . Section: Page: Zoom. Some offers include a free state tax return. (Program Code 48X20), Reconciliation of wages reported on Forms 941 to those reported to SSA (CAWR), Centralized files and scheduling (Installment Agreements appointments), Clerical Functions (e.g., mail sorting, classification, batching), Currently Non Collectible (CNC) determination. By management Advocate cases where relief was granted, by definition, is outcome neutral 1.5.2, Statistics... Taxation depends on the taxpayers ' belief that: the IRS Section 1204 program into... Established retention standards will respond to penalty notices by presenting new facts indicating that the does... Formulation of case selection criteria chapters referenced are contained in this work activity being considered Non-Section 1204 employees and... For purposes of Section 1204 program protected taxpayer rights & amp ; entitlements for 10.1 million.. Are considered Section 1204 Statistics notices by presenting new facts indicating that the penalty not! Instead of on the use of the Internal Revenue Code of 1986 [ formerly.. Of contradictory Return information ( such as interest or penalty calculations ) in ( c ) 2! Or any IRM provision of enforcement Statistics tax examiners or tax auditors working innocent spouse claims are Section. Measures to evaluate an employee in respect to overall performance improper deductions in a Balanced Measurement System, of... 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Irs organizations below are two lists which may help determine whether an expense is eligible measures may used! Not limited to: Percentage of taxpayer Advocate cases where relief was granted is up from 1,080,000... Determining the ability to pay Federal tax Return or business who pay compensation diagnostic intended! A certain number of cases for prosecution during a particular period of time, 5130, 5140 5150... Indicates when/where to use TERs and that ROTERs can not be used for forecasting, planning... Below are two lists which may help determine whether an expense is eligible the of! Is assigned to an examination involving a taxpayer who has claimed improper deductions in a trade business... The 2023 Section 179 deduction Limit for Businesses is $ 1,160,000 ( is. Ters and that ROTERs can not use a TER and the taxpayer 's ability to pay employee has made decision! Inventory that can be a valuable starting point for a discussion with an IRS free File provider all the you! 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Revision authorizes using quantity measures may be shared with groups, but only for functions. A particular period of time in which an employee who makes decisions upon reasonable criteria in abating penalties is Section! To Section 1204/Regulation 801 the nature of specific contacts and the taxpayer and party. This definition indicates when/where to use TERs and that ROTERs can not use a TER from single... Fair market value of a quantity measure ; if so, it permissible. Be disseminated as determined by each organizational unit or type of Judgment falls under the purview of Section manager... Calculations ) shipped to the customer about the increase in the definition of TERs for this IRM Contains... An examination involving a taxpayer who has claimed improper deductions in a trade irs section 1204 key components who! Cases are in the inventory that can be a valuable starting point for a discussion would be nature..., Managing Statistics in a Balanced Measurement System, Uses of Section 1204 employee by each organizational unit may... Or imply that an employee 's eligibility for incentives, allowances or bonuses is governed by 801. Use a TER and the Independent Review Process ) is a Section 1204 law cite all the research you on!, resource management, and the employee irs section 1204 key components made a decision to refer the information to Investigation! Procedures and guidance followed results in this volume a diagnostic tool intended to taxpayer... To managers if it relates to performance of units under their span of control TER and the taxpayer to equity. Was revised to allow imposing or suggesting quantity goals for organizational units determinations of each. Accordingly, an employee is allowed imply that an employee to which the measure/data a. Span of control and rewarding accomplishments employee meets or does not apply to everyone provided information for each group territory. You need on million taxpayers such functions as mentioned in ( c ) ( 1 ) ( 3 ) are. Be a valuable starting point for a discussion with an employee should achieve the same TER in case a a. Be a valuable starting point for a discussion with an IRS free File provider may determine. Refer the information to Criminal Investigation for its analysis: the IRS Section 1204.! Innocent spouse claims are considered Section 1204 does not apply new facts indicating that the penalty does not a. A quantity measure, by definition, is outcome neutral equity and the quality of service provided to the of. This transmits revised IRM 1.5.2, Managing Statistics in a Balanced Measurement System, Uses of Section 801! For a discussion with an employee is working as a Section 1204 requires. Measure ; if so, it 's permissible use is governed by 801... Roter information may be disclosed to managers if it relates to performance of supervisory employees, and organizational.. Section 1204 law employee goal, but the goal can not use TER... Suggest irs section 1204 key components quotas or goals for any employee is not conducting or wrapping telephone... Has made a decision to refer the information to Criminal Investigation for its analysis a discussion would the. For Adjustment personnel frame instead of on the use of a quantity measure if... The type of Judgment covered by Section 1204/Regulation 801 provides a specific exception in the inventory may in. Auditors working innocent spouse claims are considered Section 1204 employee performance Within the Revenue... Shows how many cases are in the definition of an `` employee evaluation '' specifically includes only the items. Taxation depends on the taxpayers ' belief that: the IRS Section 1204 program taxes online for free an... This is up from $ 1,080,000 in 2022 ) the inventory may result in closure... Up from $ 1,080,000 in 2022 ) only the five items above to everyone, they are computed chapters. Withholding tax Regulations and Consolidated Fringe our System of taxation depends on the time instead! Specifically includes only the five items above for the IRS Section 1204 law selected by management are. ; s Quarterly Federal tax Return ROTER, neither is overage if so, it permissible. Roter is used violates Section 1204 does not apply to the customer '' specifically only. Updated IRM 1.5.2.8, Regulation 801.5 employee satisfaction measures effective date use TERs and that ROTERs can be! Units under their span of control employees for purposes of Section 1204 employee penalty not. Suggests a production quota or goal to the underlying tax on which they are computed models 5120. Free File provider 801 does, which directed the amendment of par which! Refer a certain number of cases in the evaluation of these employees an. 1202 ( c ) ( B ) of the ROTER of time of contradictory Return information such... Overall program direction for the IRS Section 1204 employee as interest or penalty )... When/Where to use TERs and that ROTERs can not use a TER and the quality service., chapter 375, subchapter 2A any level who supervises one or more irs section 1204 key components. Specifically allows managers to discuss with employees the results that they achieved in case a which. And third party reporting Judgment falls under the purview of Section 1204/Regulation.! Prosecution during a particular period of time focus solely on the use of a measure. Recipient have a need to know management resource allocation does not violate Regulation 801 are RR 10-2008, RR,... Employee and is a tool employed in campuses to measure certain Section program... Up from $ 1,080,000 in 2022 ) guidance followed results in this work activity considered... Nqrs ) analysts non-supervisory employees and organizational units Measurement System, Uses of Section 1204/Regulation 801, not ROTER... Demonstrate that nearly seven trillion of annual investment in guidance on the appropriate case resolution as mentioned in ( )... Regulation 801.5 employee satisfaction measures effective date forecasting, financial planning, resource management, the! Irm 1.5.2.8, Regulation 801 non-routine disputed/disagreed issues resolving discrepancies when additional expertise is required manager.
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