TAS Act

(6) Access to information and meetings

(A) In general. Upon request, the Commissioner shall provide the Office of the Taxpayer Advocate with access to any of the following:

(i) In the case of any request made by a taxpayer for assistance by the Office of the Taxpayer Advocate which is open and pending—

(I) any return or return information (as such terms are defined in section 6103(b)) which the National Taxpayer Advocate determines is necessary to assist such taxpayer,

(II) any legal advice provided by the staff of the Office of Chief Counsel to any employee of the Internal Revenue Service (including any legal advice prepared in contemplation of litigation) which the National Taxpayer Advocate determines is necessary to assist such taxpayer, regardless of whether such legal advice cannot be disclosed to such taxpayer, and

(III) any meeting between such taxpayer and any employee of the Internal Revenue Service.

(ii) To the extent necessary to perform a full and substantive analysis included in any report described in paragraph (2)(B)—

(I) any relevant document, data, or statistical information, and

(II) any legal advice provided by the staff of the Office of the Chief Counsel to any employee of the Internal Revenue Service (including any legal advice prepared in contemplation of litigation).

(iii) Legal advice from the staff of the Office of Chief Counsel on any matter or issue.

(B) Deadline. Access to any information, advice, or meeting described in subparagraph (A) shall be provided by the Commissioner not later than—

(i) the date which is 2 weeks after the date on which a written request submitted by the Office of the Taxpayer Advocate has been received by the Commissioner, or

(ii) such date as is otherwise agreed to by the Commissioner and the Office of the Taxpayer Advocate.

(C) Meetings. For purposes of subparagraph (A)(i)(III), the Commissioner shall be deemed to have satisfied the requirement under such subparagraph if the Commissioner has extended an invitation to attend the meeting to the Office of the Taxpayer Advocate, without regard to whether such an invitation was declined by any employee of the Office of the Taxpayer Advocate.

(D) Privilege. Any access provided to the Office of the Taxpayer Advocate pursuant to this paragraph with respect to information or legal advice from the staff of the Office of Chief Counsel shall have no effect on any privilege which otherwise applies to such information or legal advice.

(XIV) identify any failure by the Commissioner to provide access to any information, advice, or meeting described in subparagraph (A) of paragraph (6) by the date required under subparagraph (B) of such paragraph.