Federal Tax Procedure Book - Acronyms and Initialisms (8/1/22)

I formerly presented a list of various acronyms, initialisms and short-handisms as Appendix B to the Federal Tax Procedure Book.  I decided to put the list on the blog.  

I sometimes refer to these collectively as acronyms.  Purists on the English language often articulate a difference between acronyms and initialisms, both based on the short-hand techniques (most often the initial letters of the series of words): An initialism is a word made up of initial letters that are pronounced separately as letters rather than as a word (e.g., IRS or FBI); an acronym is a word that is also made of up of initial letters that are spoken as a word rather than separate letters (e.g., NATO).    See Bryan Garner’s Law Prose Lesson #260: Acronyms and Initialisms (here, viewed 7/31/22).  Abbreviations are analogous short-hand techniques.  Similar short-hand techniques are encountered and may be variations on the theme–e.g., (i) FBAR (for Foreign Bank Account Report), pronounced F-BAR which combines initialism (the “F”) with acronym (the “BAR”) and (ii) FinCEN for the Financial Crimes Enforcement Network which combines two abbreviations. 

Of course, these techniques are often overused, but a necessary evil.

I present the acronyms without periods.  Often, they are presented with periods.  For example, IRB or I.R.B.; or FBI or F.B.I.  I have not gone back through the text to see whether I am consistent in using periods or not using periods.

AAG	Assistant Attorney General (generally in reference to DOJ Tax AAG)
ABA	American Bar Association
ACA	Affordable Care Act P.L. 111-148
ACM	Appeals Case Memorandum
ACS	Automated Collection System
ADR	Alternative Dispute Resolution
AGI	Adjusted Gross Income
AIA	Anti-Injunction Act (§ 7421(a))
AICPA	American Institute of Certified Public Accountants
AJAC	IRS Appeals Judicial Approach and Culture Project
ALJ	Administrative Law Judge (Some agencies have, but not IRS)
AOD	IRS Action on Decision
APA	IRS Advance Pricing Agreement
ASED	Assessment Statute Expiration Date
ASFR	Automated Substitute for Return
ATAT	Abusive Tax Avoidance Transaction (now ATTI)
ATG	IRS Audit Techniques Guides
ATTI	Abusive Transaction and Technical Issues
AUR	Automated Underreporter Program (Computer Matching Information Returns to Related Tax Returns)
AUSA	Assistant U.S. Attorney
BBA	Bipartisan Budget Act of 2015, Public Law 114-74 (enacted CPAR)
BBA Partnerships	Partnerships Subject to CPAR Enacted by BBA
BFP	Bonafide Purchaser
BFS	U.S. Treasury Bureau of Fiscal Services
BIA	Board of Immigration Appeals
BLIPS	Bond Linked Investment Premium Structure (an abusive tax shelter)
BSA	Bank Secrecy Act 31 U.S.C. § 5311 et seq
BTA	Board of Tax Appeals (Predecessor to U.S. Tax Court)
CAF	IRS Centralized Authorization File (for taxpayer representative identification)
CAP	Compliance Assurance Process
CAP	IRS Collection Appeals Program
CAU	Caution Upon Contact (IRM Vaccination)
CB	IRS Cumulative Bulletin (previously used for IRS important guidance)
CBI	Caribbean Basin Initiative (treaties Between U.S. and Caribbean Basin Countries)
CBT	Citizenship Based Taxation
CCA	IRS Chief Counsel Advice
CCN	IRS Chief Counsel Notice
CDP	Collection Due Process (IRS appeal and litigation of IRS collection procedures)
CES	DOJ Tax Criminal Enforcement Section
CFR	Code of Federal Regulations
CI	IRS Criminal Investigation (formerly CID)
CIC	IRS Coordinated Issue Case (renamed LCC in 2019)
CID	IRS Criminal Investigation Division (Current Name is CI)
CMIR	Currency and Monetary Instruments Report (FinCEN Form 105)
CNC	Currently Not Collectible (for unpaid assessed tax)
COD	Cancellation of Indebtedness
CPA	Certified Public Accountant
CPAR	Centralized Partnership Audit Regime (also BBA Regime)
CPEO	Certified Professional Employer Organization (§§ 3511 and 7794)
CRA	Congressional Review Act (5 USC 801-808)
CRS	Common Reporting Standard (OECD Standard, akin to FATCA)
CRS	Congressional Research Service (Branch of the Library of Congress)
CSED	Collection Statute Expiration Date (assessed tax last collect date))
CT Counsel	IRS Chief Counsel Criminal Tax Counsel
CTM	DOJ Tax Criminal Tax Manual
CTR	Currency Transaction Report (FinCEN Form 112)
DAS	Discriminant Analysis System (LB&I model for audit potential)
DATC	Doubt as to Collectibiliity (Basis for Compromise)
DATCSC or DATC-SC	Doubt as to Collectibility with Special Circumstances
DATL	Doubt as to Liability (Basis for Compromise)
DAWSON	Docket Access Within a Secure Online Network)
DCC	IRS Detroit Computing Center
DIF	Discriminant Index Function (IRS scoring potential for audit)
DISC	Domestic International Sales Corporation
DJA	Declaratory Judgment Act (28 U.S.C. § 2201(a))
DMS	BFS Debt Management Services (Used for, inter alia, FBAR Debt Collection)
DOE	Department of Energy
DOJ	Department of Justice
DOJ Tax	Department of Justice Tax Division
ECS	Electronic Communications Services (see SCA)
EFIN	Electronic Filer Identification Number
EITC	Earned Income Tax Credit
EO	Presidential Executive Order
EO	IRS Exempt Organization Branch
EPA	Environmental Protection Agency
ESOP	Employee Stock Ownership Plan
ETA	Effective Tax Administration (Basis for Compromise)
FAQ	Frequent Asked Question(s) (used sometimes for IRS guidance)
FATCA	Foreign Account Tax Compliance Act (enacted by HIRE)
FATP	Federally Authorized Tax Practitioner Privilege - § 7525
FBAR	Report of Foreign Bank and Financial Accounts (FinCEN Form 114)
FDAP	Fixed and Determinable Annual or Periodical Income
FDCPA	Federal Debt Collection Practices Act (15 U.S.C. §§ 1601 note, 1692-1692o)
FDR	Foreign Document Request (§ 982)
FEA	Fraud Enforcement Advisor (formerly Fraud Technical Advisor)
FFTF	Fraudulent Failure to File Penalty (§ 6651(f)
FinCEN	U.S. Treasury Financial Crimes Enforcement Network
FISC	Foreign International Sales Company
FLIP	Foreign Leveraged Sales Company (an abusive tax shelter)
FLP	Family Limited Partnership
FMS	Financial Management Services (former Treasury Branch, now merged into BFS)
FOIA	Freedom of Information Act
FP	Foreign Parent (used in examples)
FPA	Final Partnership Adjustment under CPAR
FPAA	Final Partnership Administrative Adjustment (under TEFRA Partnership Procedures)
FRAP	Federal Rules of Appellate Procedure
FRCP	Federal Rules of Civil Procedure
FRCrP	Federal Rules of Criminal Procedure
FRE	Federal Rules of Evidence
FSC	Foreign Sales Corporation
Fsub	Foreign Subsidiary (used in examples)
FTA	Fraud Technical Advisor (Now Fraud Enforcement Advisor)
FTA	First Time Abate (Penalty Relief)
FTCA	Federal Tort Claims Act (28 USC § 1346(b))
FTCP	Fair Tax Collection Practices, § 6304
FTF	Failure to File Penalty (§ 6651(a))
FTL	Federal Tax Lien
FTMC	IRS Fast Track Mediation-Collection
FTS	Fast Track Settlement
FY	Fiscal Year
GAO	Government Accountability Office
GATT	General Agreement on Tariffs and Trade (a multilateral trade agreement)
GCM	General Counsel Memo (Chief Counsel Guidance document No Longer Used)
GHW	Global High Worth (an IRS audit initiative)
GP	General Partner
GPO	Government Printing Office
HIRE	Hiring Incentives to Restore Employment (HIRE) Act (2010)
HITS	High Income Taxpayer Strategy (an IRS audit initiative)
IDR	Information Document Request (IRS Form 4564)
IIR	IRS Industry Issue Resolution Program
ILM	Internal Legal Memorandum (IRS internal guidance document)
INA	U.S. Immigration and Nationality Act
IR	IRS Information Release
IRB	IRS Internal Revenue Bulletin (an IRS public guidance publication)
IRC	Internal Revenue Code (Currently IRC 1986 compiled into 26 USC)
IRM	Internal Revenue Manual (an IRS internal guidance publication)
IRP	Internal Revenue Procedure (IRS public guidance document for procedures)
IRS	Internal Revenue Service (a bureau of the U.S. Treasury)
JCT	Joint Committee on Taxation (U.S. Congress joint committee)
JCX	JCT Publication
JDS	John Doe Summons (§ 7609(f))
JITSIC	OECD Joint International Taskforce on Shared Intelligence and Collaboration
LAFA	Legal Advised Issued by Field Attorneys (IRS internal guidance document)
LB&I	IRS Branch for Large Business and International
LCCI	Large Corporate Compliance Program (2019 renaming of CIC)
LCCI	IRS Last Clear Chance Initiative (voluntary disclosure foreign accounts in 1990s)
LITC	Low-Income Taxpayer Clinics (§ 7526)
LLC	Limited Liability Company
LP	Limited Partner
LPC	Large Partnership Compliance Program (Under CPAR/BBA)
LTA	Local Taxpayer Advocate
MAP	Mutual Agreement Procedure (sharing info under a Tax Treaty)
MLAT	Mutual Legal Assistance Treaty
MSSP	Market Segment Specialization Program
NAP	Notice of Audit of Partnership under CPAR
NBAP	TEFRA Procedure Notice of Beginning Administrative Proceeding
NBIG	Not In Best Interest of Government (Collection Term)
NCOA	USPS National Change of Address Database
NDWC	Notice of Determination of Worker Classification
NFTL	Notice of Federal Tax Lien (Form 668(Y)(c))
NOD	Statutory Notice of Deficiency (§ 6212) (also SNOD); sometimes Notice of Determination.
NOL	Net Operating Loss
Nonacq	Nonacquiesence (IRS statement of disagreement with court case)
NOPA	Notice of Proposed Adjustment
NOPPA	Notice of Proposed Partnership Adjustment (under CPAR)
NPRM	Notice of Proposed Rulemaking (a step in the regulations approval process)
NRP	National Research Program (an IRS audit program)
NTA	IRS National Taxpayer Advocate
OAS	Organization of American States
OBR	Offset Bypass Refund (under § 6402)
OECD	Organization for Economic Cooperation and Development
OFE	Office of Fraud Enforcement
OIC	Offer in Compromise
OIC-DATC	Offer in Compromise-Doubt as to Collectibility
OIC-DATC-SC	Offer in Compromise-Doubt as to Collectibility Special Circumstances
OIC-DATL	Offer in Compromise-Doubt as to Liability
OIC-ETA	Offer in Compromise-Effective Tax Administration
OMB	Office of Management and Budget (an office within the Executive Branch for budget and management)
OPA	IRS Office of Penalty Administration
OPI	Office of Promoter Investigations
OPR	IRS Office of Professional Responsibility
OTSA	IRS Office of Tax Shelter Analysis (in LB&I)
OVCI	Offshore Voluntary Compliance Initiative
OVDI	Offshore Voluntary Disclosure Initiative
OVDP	Offshore Voluntary Disclosure Program
PAM	Post-Appeals Mediation
PCA	Private Collection Agencies
PDC	Private Debt Collection
PDT	Potentially Dangerous Taxpayer (see IRM 25.4.1)
PEO	Professional Employer Organization
PFA	IRS Pre-Filing Agreement
PLR	Private Letter Ruling
PMTA	Program Manager Technical Assistance (IRS internal guidance)
PPIA	Partial Payments Installment Agreement
PSP	Payroll Service Provider
PTIN	IRS Preparer Identification Number
PTP	Publicly Traded Partnership (taxed as corporation § 7704)
QAR	Qualified Amended Return
QO	Qualified Offer (for attorneys' fees  § 7430))
RAF	Reporting Agent
RAP	IRS Rapid Appeals Process
RAP	Rapid Appeals Process
RAR	Revenue Agents Report
RBA	Restitution Based Assessment under § 6201(a)(4) and § 6213(b)(5)
RBT	Residence Based Taxation
RCP	Reasonable Collection Potential (Doubt as to Collectibility Offers)
REIT	Real Estate Investment Trust
Rev. Proc.	Revenue Procedure (IRS guidance on tax law published in the IRB)
Rev. Rul.	Revenue Ruling (IRS guidance on procedures published in the IRB)
RFA	Regulatory Flexibility Analysis
RFA	Regulatory Flexibility Act (5 U.S.C. § 601 ff.)
RPO	IRS Return Preparer Office
RRP	Return Review Program
RRP	Return Review Program
RSED	Refund Statute Expiration Date
SA	IRS CI Special Agent
SAC	Special Agent in Charge (for IRS CI)
SAUSA	Special Assistant U.S. Attorney (IRS attorneys are sometimes designated)
SB/SE	Small Business/Self-Employed
SCA	Stored Communications Act (18 USC §§ 2701 et seq.)
SCIP	IRS Simultaneous Criminal Investigation Program
SDNY	Southern District of New York
SEC	Securities and Exchange Commission
SECA	Self Employment Contributions Act
SFC	Senate Finance Committee
SFR	Substitute for Return (§ 6020(a) & §6020(b)-different procedures)
SG	Solicitor General of the U.S. (an office in DOJ)
SNOD	Statutory Notice of Deficiency (§ 6212)
SOP	Settlement Option Procedure
SOX	Sarbanes-Oxley Act of 2002, Pub. L. No. 107-204, 116 Stat. 745
Stat.	Statutes at Large
STJ	Tax Court Special Trial Judge
T.D.	Treasury Decision - document that contains final or temporary regulations
T.O.	Treasury Order (by Secretary of Treasury)
TAM	Technical Advice Memorandum
TAO	Taxpayer Advocate Taxpayer Assistance Order
TAS	Taxpayer Advocate Service
TBOR	Taxpayer Bill of Rights (several successive statutory iterations of TBOR; usually refers to § 7803(a)(3)
TBOR I	§ 7433 Remedy for Unauthorized Collection Actions
TBOR II	1996 amendment to § 7433
TBOR III	§ 7803(a)(3)
TC	Tax Court
TCJA	Tax Cuts and Jobs Act of 2017 (unofficial name for Publ. L. 115-97
TCMP	Taxpayer Compliance Measurement Program (replaced by NRP)
TD	Treasury Decision - document that contains final or temporary regulations
TEAM	Technical Expedited Advice Memorandum
TEFRA	Tax Equity and Fiscal Responsibility Act of 1982 (Replaced after 2017 by CPA)
TFA	Taxpayer First Act
TFRP	Trust Fund Recovery Penalty (§ 6672)
TIA	Tax Information Exchange Agreements (treaties for information exchange)
TIEA	Tax Information Exchange Agreements (treaties for information exchange)
TIGTA	Treasury Inspector General for Tax Administration
TIN	Taxpayer Identification Number (e.g., for individuals, the SSN)
TIPRA	The Tax Increase Prevention and Reconciliation Act of 2005, Pub. L. No. 109-222, 120 Stat. at 362
TMP	Tax Matters Partner (the person designated by partnership to handle audits)
TNT	Tax Notes Today, a prominent tax publication by Tax Analysts
TOP	Treasury Offset Program (offsets Government debts due)
TPC	Third Party Contact (§ 7602(c))
TPI	Total Positive Income
TY	Tax Year
UIDIF	Unreported Income DIF
USA	U.S. Attorney
USAO	U.S. Attorney Office
USC	U.S. Code (Compiled Law; Title 26 is IRC 1986)
USP	US Parent Company
USPS	U.S. Postal Service
USSub	US Subsidiary Company (used in examples)
UTP	Uncertain Tax Positions reported by corporate taxpayers on Schedule UTP
VCSP	Voluntary Classification Settlement Program (2012-45, 2012-51 I.R.B. 724) for Employee/Independent Contractor settlements
WB	Whistleblower
WBO	IRS Whistleblower Office
WSLA	Wartime Suspension of Limitations Act, 18 U.S.C. § 3287