Clarification from the agency

U.S. Citizens or U.S. Nationals; no prior Federal experience is required.

The incumbent of this position serves as an Attorney assigned to a Field Office within the Tax Exempt and Government Entities Division Counsel (TEGEDC) office. Attorneys are responsible for performing detailed complex legal research to analyze law and facts involved in a case; drafting defense letters to the Department of Justice (DOJ) and serves as the primary Chief Counsel contact and advisor for the DOJ Attorney litigating these suits; litigates alone or with assistance, complex TEGEDC cases before the United States Tax Court and cross-divisional cases when assigned; establishes trial positions and evaluates hazards of litigation based upon all facts and applicable law; provides complex technical legal advice in the areas of Employee Plans, Exempt Organizations, Employment Tax, Executive Compensation, Health and Welfare Benefits, Federal, State and Local Governments, Indian and Tribal Governments, and Tax Exempt Bonds; and effectively advises internal revenue agents regarding technical requirements.

The following are the duties of this position at the GS-14.   These are not all inclusive:

• Incumbent receives assignments of the most difficult and complex types of work in one or more of the following functions within the office depending up on the specialty area of tax to which assigned – Tax Litigation, General Litigation, and/or Tax Exempt/Government Entities. 
• For Tax Litigation the incumbent may be assigned cases docketed in the United States Tax Court.  Duties may include preparation of answers to petitions, replies, motions and any other documents germane to proper handling of the case.  Assignment of a case pending in the Tax Court also includes responsibility for ascertaining the legal correctness of the position(s) determined in the statutory notice of deficiency as well as preparation for the case for trial and settlement.
• Provides legal advice and assistance to the IRS, Appeals offices, Service Centers and other Division Counsel concerning issues within his/her area of topical jurisdiction.  Researches, analyzes facts and writes legal opinions in response to questions. 
• For District Court and Claims Court:  Reviews pleadings and files and prepares defense letter to the Department of Justice, Tax Division, Setting out the Commissioner’s position on defense of a suit involving merits of the tax, etc., including in appropriate cases, discussing the propriety of jurisdiction, any suggested motions that may be appropriate, the particular defense that is recommended and whether or not the case is one that the Department of Justice may settle without further coordination.
• For General Litigation work the incumbent:  Furnishes advice and opinions to the IRS, the Department of Justice, etc., in any matter (court and non-court) incident to the assessment and collection of taxes.  Advises field administrative officers, handles the legal work, and assists the Department of Justice and United States Attorneys in cases involving tax matters.  Recommends what suits should be brought or interventions or counterclaims filed by the Government in connection with the collection of internal revenue taxes or the recovery of erroneous refunds thereof and the basis for defense of tax litigation suits against the United States.

NOTE: This is an open-continuous announcement. Applicants will be referred to the selecting officials and referral lists issued as vacancies occur.

Referral Lists: Cutoff for receipt of applications will be midnight EST on the date a vacancy has been determined. Applications received after that date, may be considered on future referral lists. Notifications will be sent to applicants when application has been referred or not. The announcement may close prior to the closing date, if management has succeeded in filling all vacancies and has no further use for a standing register. Applications may be updated and/or resubmitted to continue receiving consideration till the closing date of this announcement.

Conditions of employment

• Please refer to "Conditions of Employment".
• Click "Print Preview" to review the entire announcement before applying.
• Must be U.S. Citizens or U.S. Nationals.

CONDITIONS OF EMPLOYMENT:

• A one-year trial period is required.
• Must successfully complete a background investigation.
• Complete a Declaration for Federal Employment to determine your suitability for Federal employment, at the time requested by the agency
• If you are a male applicant born after December 31, 1959, please certify that you have registered with the Selective Service System or are exempt from having to do so.
• Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
• Go through a Personal Identity Verification (PIV) process that requires two forms of identification from the Form I-9. Federal law requires verification of the identity and employment eligibility of all new hires in the U.S.
• Obtain and use a Government-issued charge card for business-related travel.
• Sign a 3 year Tenure Commitment Letter
• Undergo an income tax verification.
• The employment of any candidate, including a current employee or a new hire, selected for this position may be conditional upon classification and/or audit of federal tax returns. This audit may include up to two years of returns.
• Because of its tax-related mission, the Office of Chief Counsel requires fingerprinting, tax verification, and a background security investigation as part of the pre-employment process.

Qualifications

You must meet the following requirements by cutoff dates or closing date of this announcement, whichever comes first:

For GS-14: Possess a J.D. and 1 year of general legal experience, plus 2 years of legal tax experience (1 year of legal tax experience must have been comparable to the GS-13 level) Or an LL.M. plus 2 years of legal tax experience (1 year of legal tax experience must have been comparable to the GS-13 level).

Specialized experience: 　In addition, at least 52 weeks of the legal tax experience must have involved expertise in the complete range of concepts, principles and practices in the area of tax law both substantive and procedural, including a full knowledge and understanding of the Internal Revenue Code and related rules and regulations and expertise in Tax Court practice and procedure and/or refund litigation. Expertise also includes Federal Rules of Evidence, the Federal Civil Rules of Procedure, and the rules governing ethics for attorneys. General knowledge of other areas of the law and legal concepts particularly as they impact the tax laws with an expertise in one or more of the following: employee pension, welfare benefits, executive compensation, fringe benefits, exempt organizations, employment tax, tax exempt bonds, Indian Tribal Government issues, and federal, state, and local government issues. 

• The J.D. and/or the LL.M must be from an ABA-accredited law school.
• Candidates must be admitted to practice law before the highest court of a state or territory of the United States; the District of Columbia; or the Commonwealth of Puerto Rico.
• One year of professional legal experience refers to full-time work after admittance to the bar.  Part-time work is considered on a prorated basis. 
• The experience may have been gained in either the public or private sector.
• To ensure full credit for your work experience, please indicate dates of employment by month/year, and indicate number of hours worked per week, on your resume.

How you will be evaluated

You will be evaluated for this job based on how well you meet the qualifications above.

Applicants will be considered based on their overall background as it relates to the position to be filled. Interviews may be held at the option of the office. All application materials and interviews, if conducted, will be used in the final evaluation and selection process.

Referral: Professional Order will be used to refer and select eligible candidates. Veterans' preference is applied after applicants are assessed. Preference-eligibles will be listed at the top of the certificate in alphabetical order and considered before non-preference-eligibles. All other candidates will be listed in alphabetical order.

If you are among the top qualified candidates, you may be required to participate in a selection interview. We will not reimburse costs related to the interview, such as travel to and from the interview site.

Bargaining Unit Chief Counsel employees will be given first consideration. To receive first consideration, Bargaining Unit Chief Counsel employees seeking reassignment must be on the Master First Consideration List (MFCL). In regard to this announcement, the MFCL is only for reassignments of employees currently occupying Bargaining Unit positions. If you are applying for a promotion, please apply to the announcement.