Contract analysis

1. All bracketed fields (indicated by square brackets, e.g., "[IDR No.]," "[Date]," "[Number]") must be completed with the applicable information before the response letter is finalized and transmitted to the IRS examination team. No letter should be issued with any bracketed placeholder remaining in the text.

2. The scope limitations and objections paragraph (the fourth substantive paragraph of the letter) should be included only when PPC objects to the scope of one or more items in the IDR or provides a partial response. If PPC is providing a complete response to all items in the IDR without objection, delete this paragraph in its entirety from the final version of the letter. Do not leave the template language or bracke

3. The Privilege Log (Attachment B) should be included only when documents are withheld from production on the basis of privilege. If no documents are withheld, delete the reference to Attachment B from the "Enclosures" section of the letter and do not include Attachment B with the response. Update the text of the privilege reservation paragraph accordingly to note that no documents were identified as privileged resp

1. A copy of the signed response letter (in PDF format) must be saved to the matter file on the firm's document management system under the folder path: Matter 1018-00009 > IDR Responses > IDR [No.] Response.

2. The details of the response — including IDR number, date of response, Bates number ranges, number of documents and pages produced, and any objections or privilege assertions — must be entered into the master IDR tracker (idr-tracker-master.xlsx), which is maintained on the shared drive at: \\SCLLPShare\Tax\Matters\1018-00009\Trackers\idr-tracker-master.xlsx.

3. The Bates number ranges and document descriptions must be entered into the document production index (document-production-index.xlsx), maintained at: \\SCLLPShare\Tax\Matters\1018-00009\Trackers\document-production-index.xlsx.

4. All privilege log entries must be cross-referenced with and entered into the master privilege log (idr-privilege-log.xlsx), maintained at: \\SCLLPShare\Tax\Matters\1018-00009\Trackers\idr-privilege-log.xlsx. Care must be taken to ensure that privilege log entries are consistent across all IDR responses and that no document is logged on a privilege basis for one IDR and produced in response to another without delib

5. A hard copy of each signed response letter, together with hard copies of Attachment A and Attachment B (if applicable), must be printed and placed in the physical Matter 1018-00009 file maintained at the Philadelphia office. Communications Protocol. All communications with Revenue Agent Patricia Dunleavy, Supervisory Revenue Agent Gerald Meskill, and any other member of the IRS examination team must be coordinated