About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

24 Taxes 238 (1946)
The Chief Counsel's Office

handle is hein.journals/taxtm24 and id is 248 raw text is: THE CHIEF COUNSEL'S OFFICE
Its Organization . . .Its Work
Attorney in Nev York City

S ECTION 512 of the Revenue Act of
1934 (now section 3931 (a) of the In-
ternal Revenue Code) provides for appoint-
ment by the President, with the advice and
consent of the Senate. of an Assistant Gen-
eral Counsel for the Bureau of Internal
Revenue at a salary not in excess of $10,000
per annum. This Assistant General Counsel,
is now known as the Chief Counsel of the
Bureau of Internal Revenue.
The word Chief Counsel implies two
things: First, that he is the head counsel
and second, that he is the counselor attor-
ney for the Bureau. That is exactly his
status. The present Chief Counsel is Mr.
J. P. Wenchel, who has been associated
with the Bureau of Internal Revenue for a
number of years.
In addition to a Chief Counsel, there are
four Assistant Chief Counsel. They are Mr.
J. W. Burrus, in charge of Personnel; Mr.
M. B. Leming, who usually acts as Chief
Counsel when the Chief Counsel is not in
Washington; and Messrs. R. H. Dwan and
Lawrence S. Lesser. There are also five
Special Assistants to the Chief Counsel.
Other attorneys in the employ of the Office
of the Chief Counsel are known as Special
There is also a Chief Counsel's Committee
and eight divisions in the Office of the Chief
Counsel. Some of these divisions are further
divided into sections and there is an addi-
tional section which is independent of any
division. The divisions are:
The Appeals Division headed by Mr.
Owen W. Swecker; the Interpretive Division
over which Mr. Ellis W. Manning presides;
the Legislation and Regulations Division,

whose Chief is Mr. George E. Adams; a
Claims Division, presided over by Mr. Ray-
mond F. Brown; a Civil Division, headed
by Mr. Ray E. Williamson; and the Review
Division having at its head Mr. Henry A.
Cox. In addition, there is a Penal Division,
supervised by Mr. E. Riley Campbell, and
an Alcohol Tax Division, of which Mr.
Vincent DeP. Simonton is the head. The
independent section, not under any division,
is known as the Engineers and Auditors
Section and is headed by Mr. F. T. Donahue.
Appeals Division
I have listed the Appeals Division first,
because in my opinion, attorneys of that
division come in contact with counsel for
taxpayers more frequently than do attorneys
of any of the other divisions. Appeals has
charge of situations having to do with in-
come, excess profits, unjust enrichment, and
estate and gift taxes where cases of this
type are pending before the Tax Court of
the United States or before any of the
Technical Staff Divisions of the Bureau of
Internal Revenue. Most readers know, I
am sure, that in each divisional office of the
Technical Staff and in many of the sub-
divisional offices, there are attorneys of the
Chief Counsel's Office. These attorneys are
in the Appeals Division.
When a case has been referred to the
Technical Staff by the Internal Revenue
Agent in Charge, the taxpayer is frequently
given an opportunity for a conference prior
to the issuance of a ninety-day letter. If
the case involves a principle of law and a
question of fact is not the sole issue, it is
referred to the Local Counsel of the Ap-

March, 1946 0 T A X E S-The Tax Magazine

What Is HeinOnline?

HeinOnline is a subscription-based resource containing nearly 3,000 academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.

Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline with pricing starting as low as $29.95

Contact us for annual subscription options:

Already a HeinOnline Subscriber?

profiles profiles most