CCA 201403006 (Sept. 26, 2013)

(IRS Small Business/Self-Employed (SB/SE) examination unit can disclose to Office of Professional Responsibility (OPR) an audit report and unagreed case package of practitioner engaging in practice before IRS before case is resolved at Appeals or via statutory notice of deficiency when OPR referred practitioner to SB/SE exam unit for examination; thus, for practitioners referred to IRS for examination of practitioner's own return as result of Circular 230 investigation, OPR can obtain copy of revenue agent's report before Appeals completes review of case).