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Early Referral to Appeals

Description:

Taxpayer requests early referral to Appeals of developed unagreed issue in an open audit (prior to 30-day letter)

Taxpayer and Team Manager agree issue should be referred early

Remaining issues are not expected to be complete before Appeals resolve early referral issue

Certain issues excluded but includes Industry Specialists Program (ISP) and Appeals Coordinated Issues

Closing Agreements executed if agreement is reached

If agreement is not reached, taxpayer may request mediation or will be issued a statutory notice of deficiency

Revenue Procedure 99-28
Section 4.46.5.6.10 of IRM 4.46.5.6 – Early Referral to Appeals

Page Last Reviewed or Updated: 14-Feb-2014