META DATA SUBJECT TO SUMMONS

The IRS Chief Counsel's Office has issued a memorandum indicating that the relevancy requirement imposed upon summons issued administratively can be met by agents seeking a document's original meta data insofar as the credibility of the document may be in issue, as to the time place and manner of document authorship and modification.  The memorandum was issued 11/18/11 (See No. 201146017).  Taxpayers and their representatives might expect to see more requests for meta data files in future IRS examinations.