4.10.9  Workpapers

4.10.9.1  (01-12-2010)
Overview

  1. The purpose of this section is to provide guidelines for the development of workpaper content and for workpaper organization. These guidelines are provided to promote quality and consistency in examiner workpapers.

  2. Workpapers are the written records kept by the examiner which provide the principal support for the examiner’s report and document the procedures applied, tests performed, information obtained, and the conclusions reached in the examination. They should include all the information necessary to document the examination activities and support the audit results.

  3. Workpapers serve four basic purposes:

    1. Assistance in planning the audit, including the analysis of internal documents and setting the scope of the exam;

    2. Record of the evidence gathered, procedures completed, tests performed, and analyses conducted during the examination process;

    3. Provide support for technical conclusions; and

    4. Basis for review by management.

  4. Case files will be reviewed for various purposes. Well prepared workpapers facilitate the use of the file by numerous customers after the case is closed. If the workpapers are prepared well, others will be able to use the file effectively.

4.10.9.2  (01-12-2010)
Workpaper Format

  1. Form 4318 , Examination Workpapers Index, is used as a cover page for revenue agent's workpapers.

  2. Form 4700, Examination Workpapers, is used as a cover page for tax compliance officer and tax auditor's workpapers.

4.10.9.2.1  (01-12-2010)
Revenue Agents: Form 4318

  1. Form 4318 and its continuation page, Form 4318-A, Continuation Sheet for Form 4318, Examination Workpapers Index, should be used for all examinations unless otherwise specified.

  2. The examiner should follow Report Generation Software (RGS) guidelines for completing Form 4318 and Form 4318-A.

4.10.9.2.2  (02-01-2010)
Issue Lead Sheet

  1. For examination issues, examiners should utilize the lead sheet format in the Report Generation Software (RGS).

  2. Mandatory lead sheets for revenue agents are referenced on the Form 4318. See IRM 4.10.9.2.3 , Issue Lead Sheet Content, below.

  3. Mandatory lead sheets for tax compliance officers and tax auditors are as follows:

    1. Form 4700 and applicable supplemental schedules (i.e. Form 4700-B.)

    2. Lead sheet 130 Multi-Year and Related Returns Lead Sheet is required to be used in place of Form 4700-A to document actions taken with respect to required filing checks.

    3. Issue specific lead sheets

  4. A supplemental lead sheet may be used to detail multiple adjustments comprising the overall adjustment reflected on the Issue Lead Sheet.

4.10.9.2.3  (01-12-2010)
Issue Lead Sheet Content

  1. The lead sheet should contain the following:

    1. Header - See IRM 4.10.9.2.3.1

    2. Body - See IRM 4.10.9.2.3.2

    3. Footer- See IRM 4.10.9.2.3.1

    4. In some instances, additional information or comments might be required on a lead sheet. See IRM 4.10.9.2.3.3.

4.10.9.2.3.1  (01-12-2010)
Workpaper Headers and Footers

  1. Workpapers created by the examiner must include a header and footer with the following information:

  2. Header Information:

    1. Taxpayer's name,

    2. Taxpayer identification number,

    3. Tax return form numbers and years examined,

    4. Issue being examined,

    5. Examiner's name (or initials), and

    6. Date workpaper was prepared.

      Note:

      If a workpaper is prepared on multiple dates, the examiner should note each date that significant work was done.

  3. Footer Information - Indexed page number.

4.10.9.2.3.2  (01-12-2010)
Workpaper Body

  1. The lead sheets will reflect the facts, procedures and audit techniques used, management involvement, applicable law, and conclusions in the body. This information should be presented in a logical order so that any person subsequently using the file can easily determine what audit steps were taken to support the conclusion.

    Caution:

    The use of check boxes should be for the purpose of notating the applicability of an action taken with the details and supporting documentation referenced in the workpaper reference section of the lead sheet. Generally, check boxes by themselves are not adequate supporting documentation. IRM 4.10.2.6 , Pre-Contact Planning or Examination Activities , provides additional guidance regarding the use of check boxes.

  2. Adjustments -- The lead sheets will reflect the adjustments (if any) resulting from the examination. The lead sheets will detail the "Per Return," "Per Exam," and "Adjustment" amounts with the adjustment referenced and reconciled to Form 4318. A supplement lead sheet may be used to detail multiple adjustments - comprising the overall adjustment reflected on the issue lead sheet.

  3. Conclusion -- The lead sheets will contain a conclusion summarizing the disposition of all issues.

  4. Audit Steps -- The lead sheets will document the procedures and the audit techniques performed during the examination. This would include why the issue was selected or non-selected if a classified issue, the development of the audit plan, and the depth of the examination.

    Note:

    Issue specific lead sheets auto populate with audit steps that might be applicable. Examiners should customize this area for their specific cases. Steps that are not applicable should be deleted and additional steps should be added when warranted.

  5. Facts -- The lead sheets and supplemental workpapers will contain all facts relevant to the issue.

  6. Law -- The lead sheet will identify the applicable law relied upon to resolve all issues (both accepted and adjusted).

  7. Taxpayer's Position -- The lead sheet will include the taxpayer's position about the issue if provided for unagreed cases.

4.10.9.2.3.3  (01-12-2010)
Miscellaneous Lead Sheet Content

  1. Managerial Involvement -- Some lead sheets include required managerial comments and documentation of the managerial involvement in the development of the case. Documentation may include signatures, notations on Form 9984, Examining Officer's Activity Record, or summaries of discussions on the lead sheet for the issue.

  2. Penalty -- Some penalties require managerial approval. When managerial approval is required managers must complete the appropriate sections of WP-300, Penalty Approval Form.

    1. Documentation of why penalties were not asserted in a deficiency case should be made on WP-300.

    2. WP-300 Penalty Approval Form contains a Consideration of Preparer Penalty Section that should be completed when there is a paid preparer and an understatement.

4.10.9.2.4  (01-12-2010)
Supporting Workpapers

  1. Supporting workpapers are used to document the audit trail. Types of documents which support the examiner’s conclusion include, but are not limited to:

    1. A workpaper documenting a sample of specific expenditures verified and the conclusions reached. At a minimum, the workpaper should identify the documents inspected (invoices, check numbers), date, payee, and the amount.

    2. A list of questions or items raised during the examination and the conclusions reached.

    3. Photocopies of relevant documents secured from the taxpayer during the examination. Care should be given to consider the facts and circumstances of a particular case when determining relevance. For example, a complete set of bank statements would be relevant when proposing an adjustment to income based on a bank deposit method.

    4. Documents from internal sources, such as IRP or CFOL. For example, IMFOLI/BMFOLI to support conclusions relating to prior/subsequent/related return filings.

    5. Correspondence from the taxpayer and copies of taxpayer records that are pertinent to the case.

    6. Supplemental lead sheet when used to detail adjustments summarized on an issue lead sheet.

4.10.9.2.5  (01-12-2010)
Workpaper Indexing

  1. All workpapers should be numbered and cross-referenced to the specific issue lead sheet. For example, if the issue lead sheet reflects " Bad Debt Expense" as Item 402-1, then the supporting workpapers associated with the issue should be numbered in chronological order as 402-1, 402-1.1, 402-2, etc.

  2. Cross-referencing: Workpapers should be prepared using the appropriate cross-referencing. A cross-reference from the lead sheet conclusion and audit steps to the appropriate primary workpapers provides a reference to where the work was performed. It is not necessary to cross-reference all workpapers to the lead sheet - only the primary workpaper. The primary workpaper will then contain cross-references to other supporting workpapers, which provide additional information regarding the audit procedures performed, calculations, results, and conclusions reached. Cross-references should be used to reference information useful in more than one place or to other relevant information including the source of information, composition of summary totals, or other documents or examples of transactions.

  3. Tick marks: Tick marks are used to simplify documenting conditions found and work performed. Tick marks do not need to be standardized throughout the set of workpapers, but must be consistent throughout a particular workpaper. Tick mark explanations must be a part of the workpaper or included in a separate tick mark legend workpaper.

  4. Document 12278, Examination Workpaper Index Reference Tabs, should be used as part of the indexing process. These tab sets are used by SBSE General Program examiners to index examination lead sheets and workpapers to the Form 4318. The information on each tab identifies the numeric index and the associated lead sheet as depicted on the Form 4318.

  5. Document 12278 is optional for TCO but strongly recommended.

4.10.9.3  (01-12-2010)
Activity Record

  1. Form 9984, Examining Officer’s Activity Record, is used to document each action taken on the case. Documentation should include the date, location, time charged, and an explanation of each activity or contact. The activity record should provide a complete and concise case history.

  2. Recordation of events should be made by examiners or other employees responsible for activity on the case (e.g. group managers, clerical staffing, audit accounting aides, group secretaries, etc.)

  3. Information recorded on Form 9984 includes, but is not limited to:

    1. Work performed prior to, during, and subsequent to taxpayer contact;

    2. Research activities;

    3. Date, time, and place of activity;

    4. Date the tour of the business site or inspection of the taxpayer’s personal residence was conducted;

    5. Brief summaries of telephone conversations;

    6. Contacts with taxpayers, representatives, and third parties;

    7. Causes for any delays by the Service (training, details, etc.);

    8. Causes for any delay by, the taxpayer, and/or representative;

    9. Group manager involvement (including informal discussions, formal discussion, in-process case reviews, on-the-job-visitations, and workload reviews, etc.;

    10. Collateral requests and referrals;

    11. Actions with respect to the statute of limitations;

    12. The dates the case was (1) closed to the group manager, (2) closed by the group manager, and (3) closed by the clerical staff;

    13. Inadvertent or access via IDRS to cases not in an examiner's inventory.

      Note:

      When an examiner accesses via IDRS a taxpayer's account that is not in their inventory or an account is inadvertently accessed, the examiner may complete Form 11377-E, Taxpayer Data Access. See instructions for Form 11377-E for additional details. When an account has been accessed inadvertently, the examiner should not disclose any identifying taxpayer information in the file under examination.

4.10.9.3.1  (01-12-2010)
Special Situations Requiring Documentary Evidence

  1. The following situations require that special documentary evidence be contained in the case file:

    1. A fiduciary relationship is established

    2. A corporate name is changed or a corporation is reorganized

    3. A bankruptcy or receivership is involved

    Note:

    When special situations occur during any examination that may later impact processing, examiners should notate Special Features - Other Instructions section of Form 3198.

  2. Documentary evidence is needed to:

    1. Validate a return filed after one of the situations in paragraph 1 above occurred

    2. Determine the authority for the execution of waivers and reports

    3. Determine the authority for the execution of Form 872, Consent to Extend the Time to Assess Tax.

    4. Determine the authority to receive refunds

  3. To the extent that the required documentation is not already attached to the return, examiners should secure the following documentary evidence:

    1. To verify a fiduciary relationship for a decedent, obtain Form 56, Notice Concerning Fiduciary Relationship, Form 1310, Statement of Person Claiming Refund Due a Deceased Taxpayer, where a refund is due. Form 1310 should also be secured when only one of the taxpayer's filing a joint return is deceased. The above two forms should also be accompanied by a certified copy of the legal document giving the fiduciary authorization to act for the taxpayer. These legal documents include letter of testamentary and letter of guardianship.

    2. When a corporation's name has changed or a corporation has reorganized, the examiner should obtain copies of documents certifying the changes filed with, or received from, the state in which the successor corporation is incorporated.

    3. If a bankruptcy or receivership is involved, the report for the examination will contain the name of the party legally entitled to any refund which may be due.

4.10.9.3.2  (01-12-2010)
Workpapers: Disclosure

  1. Confidential information related to the case file must be safeguarded from unauthorized disclosure. If an examiner determines that information contained in a file is sensitive, the information should be placed in a confidential envelope inside the case file. If a Freedom of Information Act (FOIA) request is received on a case that contains sensitive information, a Disclosure Officer will determine if any information can be redacted. See IRM 11.3.13.7 for additional information.

  2. When a case file contains sensitive information, Document 6441, This Document Requires Protection, must be placed on the outside of the case jacket. This will alert users that there is sensitive information in the file requiring protection.

  3. Confidential information should be secured in envelopes marked "To be Opened by Addressee Only" or in envelopes with Document 6441, attached to the outside of the case jacket.

4.10.9.4  (01-12-2010)
Workpapers

  1. Many customers will use the case file; therefore, the quality and legibility of the workpapers are very important. In most instances, examination workpapers are prepared using computerized software. However, in rare circumstances when necessary, some workpapers and supporting details may be handwritten. When handwritten workpapers and notes are necessary, they must be legible.

  2. A computer’s proper use can improve the quality and efficiency of conducting an examination through the use of automated workpapers and reports.

  3. Each examiner who is assigned a computer should use the computer to prepare workpapers and reports in a way that will most efficiently and effectively document the examination process.

  4. The following are additional reasons that workpapers should be neat, legible, and grammatically correct:

    1. Ease in preparing reports;

    2. Possible use in a court of law many months or years later;

    3. Possible request for the case file by the taxpayer through the Freedom of Information Act (FOIA);

    4. Appearance of the workpapers reflect the professionalism and skills of the examiner;

    5. Poorly prepared workpapers can adversely impact the Service's credibility;

    6. Potential reviews performed by managers, Technical Services, Appeals, the Taxpayer Advocate Service, Interest Abatement Coordinator, Treasury Inspector General for Tax Administration, Government Accounting Office, etc.

    7. Facilitate closing by Centralized Case Processing.

  5. The following suggestions will help ensure that workpapers are neat, legible, grammatically correct, and easily understood:

    1. Use vocabulary that is easily understood;

    2. Avoid using jargon (use common terms in place of legal jargon);

    3. Provide explanations when acronyms are used the first time;

    4. Verify that spelling and punctuation are correct (consider using spell-checker and/or grammar-checker if available);

    5. Prepare workpapers properly to avoid unnecessary rewriting (workpaper should be prepared contemporaneously);

    6. Ensure photocopied workpapers and other documentation are legible.

4.10.9.4.1  (01-12-2010)
Workpapers: Pre-Audit Stage

  1. Examiners should document in the case file taxpayer/representative contact made to set up the initial appointment. RGS should be updated for any contact information that needs to be changed or added based on the initial taxpayer contact.

  2. Examiners should preplan the case as outlined in IRM 4.10.2.3, In-depth Pre-Contact Analysis, and complete all mandatory pre-planning lead sheets. All actions taken should be documented in the case file.

4.10.9.4.2  (01-12-2010)
Workpapers: Initial Interview

  1. Interview questions should be customized for the taxpayer under examination. It can be a listing of questions customized for the taxpayer or a workpaper designed by the examiner to capture needed information.

  2. Audit Technique Guides (ATG) contain pro-forma interviews and interview questions for specific industries and issues. This information may be helpful in planning the interview. ATG are available at http://www.irs.gov/businesses/small/article/0,,id=108149,00.html

  3. It is not advisable to interview the taxpayer and type the answers into the computer during the interview process. Examiners should manually take notes during the interview. A summary of important items discussed should be prepared immediately following the interview.

  4. IRM 4.10.3.2.5, Documenting Interviews, discusses the elements of an adequately documented interview and should be referenced when preparing for the interview.

4.10.9.4.3  (01-12-2010)
Workpapers: Tour of Business

  1. Examiners should document their observations when a tour of business or other appropriate inspection sites are conducted. The tour should be documented in sufficient detail to explain what was observed and any conclusions reached. See IRM 4.10.3.3, Tour of Business Site, and IRM 4.10.3.3.6, Case File Documentation.

4.10.9.4.4  (01-12-2010)
Workpapers: Development/Write-up of Issues

  1. RGS is designed to be used by examiners or other users who select, control, process, or monitor tax cases. The system enhances the performance of the work process by automating numerous activities such as workpaper preparation and reports.

  2. Workpapers prepared using the computer should be prepared in the format as discussed in IRM 4.10.9.2. Various lead sheets have been developed that provide examination procedures and techniques. Additionally, special application tools are available on the RGS website to assist in the examination of passive losses, income analysis, NOL computations, depreciation, etc. See Exhibit 4.10.9-1 for a listing of some available RGS courses. Also, you will find a listing of RGS Training material on the RGS User Website at http://mysbse.web.irs.gov/exam/rgs/training/default.aspx .

  3. Examiners can use various tools to assist in the preparation of workpapers. These may include word processing, database, or spreadsheet applications. Examiners should select the tool that will provide the most utility and functionality for the issue being addressed in the most efficient and effective manner. Additionally, MySB/SE Intranet site is continuously updated with new releases of tax administration tools that may be helpful.

4.10.9.4.5  (01-12-2010)
Workpapers: Reports

  1. Report Generation Software (RGS) and other programs are used for computer generation of examination reports. Software programs exist for Income Tax, Employment Tax, International Tax, Excise Tax, Tax Exempt and Government Entities, etc.

  2. Examiners must use computer generated reports in all examinations, unless a computer generated report is not available. For example, RGS use is required for all income tax exams of 1040, 1120, 1120S and 1065 returns in the general examination program. However, RGS use is not required for Form 1041 because is it currently not available within RGS. Therefore, until RGS is available to compute tax on a Form 1041 , the examiner can use other software.

    Note:

    Tax Computation Aids are available for Form 1041 on the Abusive Tax Avoidance Transactions web site under Trust.

  3. A list of the currently approved software can be found on the Workstation Standards Website at http://coe.enterprise.irs.gov/softwareOrdering/product/listProducts.asp. To have other approved computational software loaded on your machine, request the software using the OS GetServices request on the MITS website.

4.10.9.4.6  (01-12-2010)
Workpapers: Closing Cases Using Automated Workpapers and Reports

  1. Cases on RGS LAN (1040, 1120, 1120S, 1065) must be moved to the file server to close the case. All electronic workpapers saved within the RGS program automatically close to the file server. Do not copy the RGS case to a floppy disk. A disk should not be included in the paper case file.

  2. Case files not required to be on RGS LAN, should include a disk or CD that contains a label with the following information:

    1. Identification of disk content

    2. Media information (software format)

    3. Employee’s name

    4. Office

    5. Date created

  3. All workpapers and reports should be printed and included in the case file.

  4. See IRM 4.10.8.11, Unagreed Case Procedures: Preliminary (30 Day) Letters.

4.10.9.4.7  (01-12-2010)
Workpapers: Use of Computer

  1. Examiners will use a computer to prepare taxpayer data files. Cases created using RGS require periodic backup to the RGS file server. Examiners should back up daily to the RGS file server when they are in the office and no less than weekly.

  2. Taxpayer electronic information should be stored within the RGS program. This separates the taxpayer data and provides security and privacy for each taxpayer.

    Note:

    When data is stored in the RGS program, it is backed up. This is another reason you want to store it within the RGS program.

  3. The availability of report writing programs allow examiners to fully automate work papers. Special applications are available for developing issues and generating workpapers. If workpapers are generated outside of any RGS application, they should be saved to the RGS electronic case file folder to be saved to the file server.

4.10.9.4.8  (01-12-2010)
Workpapers: Other Sources

  1. Examiners should be familiar with other sources that can be helpful in documenting and using automated workpapers and records, such as:

    • The RGS Website and the Exam Lead Sheets Website.

    • The Specialist Referral System (SRS) Website for Computer Audit Specialist Assistance with Computerized Records.

    • The E-Business Website for a listing of Electronic Records Specialist.

  2. However, since letters are constantly updated, RGS might not have the most current. The Forms/Pubs/Products Repository, on the Publishing website has the most recent version of form letters.

4.10.9.5  (01-12-2010)
Case File Assembly for Closing

  1. Proper assembly of a case file helps to minimize delays, administrative problems and procedural errors.

  2. Each case should be placed in a separate folder. A case constitutes all examined returns and workpapers with the same type of tax for the same taxpayer. The oldest year should be placed on top, followed by the other years in order, with the most current year on the bottom.

  3. All related cases should be submitted together with the controlling, primary, or key case on the top. Form 3198, Special Handling Notice, is required for the primary case and should be noted as such. Form 3198 is also required for each related case and should be noted with the names of all other related cases.

  4. If more than one folder is used to hold returns, workpapers, or related cases, they should be numbered to ensure they are not separated in error. When transmitting case files out of the group, Form 3210, Document Transmittal, should identify each taxpayer, each tax period, and list the folder numbers for each taxpayer. Each folder should be secured with a rubber band or strap. All related case folders should be associated with rubber bands, straps, staples, or boxed together, as appropriate.

  5. All examiners should follow the instructions listed in this section for:

    1. Forms attached to the outside of the case file.

    2. Forms attached to inside left of the case file.

    3. Forms and other documents enclosed within the case file.

    4. Forms and other documents to be attached to tax returns.

  6. Workpapers should be assembled in uniform size. If odd sized paper or documents are included, they should be folded to the appropriate size. Adding machine tapes or other small size documents should be attached to uniform sized sheets of paper.

  7. The forms, reports and/or documents listed below will not be required in every case. While the list is not all inclusive, it addresses the most common items.

4.10.9.5.1  (01-12-2010)
Forms on the Outside of the Case File

  1. When the following forms and documents are required, they should be attached to the outside of the case folder and placed in the following order (top to bottom):

    1. Form 895, Notice of Statute Expiration, (case must be placed in a red folder. the form 895 is to be stapled to the red folder, on top of all other documents.)

    2. Document 6441, This Document Requires Protection, (this is a special cover sheet for cases requiring protection)

    3. Form 3185, Transfer of Return

    4. Form 3198, Special Handling Notice

      Note:

      Form 4760, Document 6077, and Document 6078 were replaced by adding a special section to Form 3198 for expedite processing. Examiners should mark expedite process on Form 3198 next to the other block for cases with agreed deficiency from $10,000 to $100,000. A special block is listed on Form 3198 for deficiencies $100,000 and greater.

4.10.9.5.2  (01-12-2010)
Forms on the Inside Left of the Case File

  1. Forms and documents to be attached to the inside left of the case folder should be assembled in the following order (top to bottom):

    1. Form 885-E, Schedule for FICA Tax Adjustment of Wages Not Reported to Employee (or RGS equivalent)

    2. Form 885-T, Adjustment of Social Security Tax on Tip Income Not Reported to Employee (or RGS equivalent)

    3. Form 6657, Related Returns Examination Report (Key Case File—Non-TEFRA)

    4. Form 5752, Flow Through Entity Distribution Schedule

    5. Form 5346, Examination Information Report

    6. Form 3699, Return of Documents to Taxpayer

    7. Form 2363, Master File Entity Change (Change of Name/Address Sheet)

    8. INOLES, AMDISA, and IMFOLI (current within 30 days of closure)

    9. Computer diskettes enclosed in protective jacket(s) for non-RGS LAN cases.

4.10.9.5.3  (01-12-2010)
Forms and Other Documents Inside the Case File

  1. In order to create a well organized, professional appearing case file, the workpapers in the case file should be arranged in packages (groups). The packages should be clipped or stapled together and placed inside the folder in the following order (top to bottom).

    1. Confidential Information — place in "To be Opened by Addressee Only" or envelope and Document 6441, This Document Requires Protection, is to be used as a cover sheet to alert others to the sensitive nature of the information.

    2. Collectibility Information (ARDI Forms) — Form 9440, Taxpayer Levy Source and Contact Information. See IRM 4.20.3.3.

    3. Compliance evaluation, taxpayer’s protest, correspondence, and copy of 30-Day Letter

    4. Waivers and Acceptance Forms, such as Form 870 (PL) , Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment; Form 875, Acceptance of Examiner's Findings By A Partnership, Fiduciary, S Corporation, or Interest Charge Domestic International Sales Corporation, Income Tax Examination Changes Reports (formerly referenced as Revenue Agent Reports (RAR)) Form 4549, Form 4549-B, Form 4605, Form 886-S, Form 886-X, Form 886-Z, Form 2504, Form 4667, Form 4668, Form 2297 , Waiver of Statutory Notification of Claim Disallowance, and Form 3363, Acceptance of Proposed Disallowance of Claim for Refund or Credit.

    5. Unagreed Report (top to bottom order) — Form 4665, Report Transmittal, (all unagreed cases); Form 3213, Engineer Memorandum Report ; Form 3963. International Examiner’s Report; Examination Report (i.e. Form 4549 and Form 4605); Supporting Computations (i.e. penalty and SE tax computations), Forms 886-S, X, Z & A and exhibits, and appropriate RGS lead sheets for unagreed issues.

    6. When a case is partially agreed ( agreement not reached on all issues for a given year), or when a case is agreed for some tax periods and unagreed for other tax periods, see IRM 4.10.8.5 and IRM 4.10.8.6 for special report writing instructions.

    7. Tax Return(s) — The oldest tax period should be on the top and progress down to the most current year.

    8. Workpapers — Form 4318 or Form 4700 should always be the first page of the workpapers. The following items should also be included: copy of Form 433-D, Installment Agreement;Form 9984, and all other forms and documents, which provide a trail of where the case has been and what actions have been taken. It is generally not necessary to include complete copies of the taxpayer's books and records or all invoices for a specific expense. There may be, however, instances where it would be necessary to maintain these records in the case file.

    9. Prior Examining Officer’s Reports and workpapers

    10. Miscellaneous Documents, e.g. Special Agents’ Reports, Collateral Reports.

4.10.9.5.4  (01-12-2010)
Forms and Documents to be Attached to Tax Returns

  1. Form 5344, Examination Closing Record, (one for each tax period), attached to the face of the return.

    Note:

    Partially agreed cases should follow manual procedures located at IRM 4.10.8.5

    Note:

    If you are requesting that the return you are closing from the group be recharged to a specific location, complete Form 2275 and place it on top of Form 5344. Form 3198 must contain instructions regarding where to send (recharge) the return.

  2. Form 433-D, Form 9465, and Form 2159 should be placed on top of Form 5344.

    Note:

    When any of these forms are enclosed in a case file, Form 3198 should be flagged so CCP will remove the form and send it to the appropriate Campus.

  3. Form 1900, Income Tax Survey After Assignment,

  4. Form 3244-A, Payment Posting Voucher, (attach to first page of return). On cases (generally LMSB) where payment is made via EFTPS system or by same day wire transfer, no Form 3244-A is required. On these cases the examiner should attach the IDRS TXMOD printout showing the payment has posted.

  5. Form 872, 872–A, 872–B, 872–F, 872–O, Consents to Extend the Time to Assess Tax, or 872–N, Notice of Termination of Special Consent to Extend the Time to Assess Tax, if initiated by the taxpayer (staple one of the two copies to the reverse of the first page of the tax return).

  6. Form 872-T - A copy of an executed Form 872-T mailed to or received from the taxpayer should be attached to the back of the first page of the tax return to which it applies. See IRM 25.6.22.7.1.6, Location of Executed Form 872-T.

  7. Form 56, Notice Concerning Fiduciary Relationship, (staple to reverse of the first page of the tax return)

  8. Form 1310,Statement of Person Claiming Refund Due a Deceased Taxpayer,

  9. Form 2848, Power of Attorney and Declaration of Representative, (staple to reverse of the first page of the tax return)

  10. Form 8821, Tax Information Authorization,

  11. Form 843, Claim for Refund and Request for Abatement, 1040X or 1120X, amended returns

  12. Form 1045, Application for Tentative Refund,or Form 1139, Corporation Application for Tentative Refund, (staple to tax return giving rise to tentative carryback adjustment)

  13. Form 906, Closing Agreement on Final Determination Covering Specific Matters,

  14. Form 5546, Return Charge Out Sheet, and applicable transcripts;

  15. Form 2198, Determination of Liability for Personal Holding Company Tax.

Exhibit 4.10.9-1  (01-12-2010)
Available Courses and Course Books for Examination Report Generation System (RGS)

TRAINING PUBLICATION COURSE NUMBER TITLES
20119-101 RGS Revenue Agent New Hire Classroom Instructor Guide
20119-102 RGS Revenue Agent New Hire Classroom Student Guide
20119-103 RGS Revenue Agent New Hire OJT Instructor Guide
20119-104 RGS Revenue Agent New Hire OJT Student Guide
20263-101 RGS Tax Compliance Officer New Hire Instructor Guide
20263-102 RGS Tax Compliance Officer New Hire Student Guide
22801-101 RGS Form 1120 Workshop Instructor Guide
22801-102 RGS Form 1120 Workshop Student Guide
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