4.36.4  Joint Committee Specialist Procedures

4.36.4.1  (05-04-2010)
Case Review

  1. There are two types of reviews that may be conducted by Joint Committee Specialists:

    1. a closed case review is conducted following the submission of a closed case by the examination group to Joint Committee Specialist Review, or

    2. an in-process review, is conducted concurrently with the examination.

    Note:

    Both SB/SE and LMSB Joint Committee returns are sent directly from the field to Joint Committee Review.

    See IRM 4.36.3.8.

  2. The specialist will perform a focused review of both the technical and procedural aspects of the case

4.36.4.1.1  (05-04-2010)
Closed Case Reviews

  1. Upon receipt of a closed case, the Joint Committee Specialist will determine the correct statute date. Letter 1573A (P) will be prepared and mailed to the taxpayer and the authorized representative, if applicable. This advises the taxpayer of the receipt and subsequent assignment of the case to a Joint Committee Specialist and of the Joint Committee review process. See Exhibit 4.36.4-1. In addition, an e-mail will be sent to notify the team manager and revenue agent of the case assignment.

  2. Following the review of the case and supporting documentation, the Joint Committee Specialist prepares the Joint Committee report. The review is conducted at the Joint Committee Specialist's post-of-duty.

4.36.4.1.2  (05-04-2010)
In-Process Review

  1. Upon assignment of an in-process referral, the Joint Committee Specialist will contact the team manager or examiner to advise them of the assignment.

  2. In-process reviews are conducted at the place of examination but may also be conducted remotely such as from the Joint Committee Specialist's post-of-duty. Upon receiving the referral the Joint Committee Specialist will, within 5 days advise the team of:

    1. the review process,

    2. the requirements for the preparation of the report to Joint Committee on Taxation (JCT), and

    3. the reporting and documentation requirements.

    To satisfy the 5 day requirement a telephone call or visit to the examination site will be made as appropriate under the circumstances.

  3. The Joint Committee Specialist will periodically contact the examiner to ascertain the status of the examination, its JC jurisdiction, and the need for in-process participation. The visitations generally are scheduled as the audit progresses and there is a sufficient number of notices of proposed adjustments issued/pending to be reviewed. It will not be necessary for the Joint Committee Specialist to make continuous ongoing visitations to the examination site. The in-process review is designed to achieve collaboration between the examiner and the Joint Committee Specialist.

  4. The Joint Committee Specialist will prepare the Joint Committee report during the concluding stages of the examination.

4.36.4.1.3  (05-04-2010)
Scope of Review

  1. At the initial stage of the review, the specialist will develop a review plan identifying its scope and depth. The plan may change in course of the review to accommodate the facts and circumstances of the case. The review plan should consider the following:

    1. The scope and depth of the examiner’s audit plan,

    2. Counsel, ISPs or issue specialist involvement,

    3. Advance Pricing Agreements (APAs) ,

    4. The examination team’s compliance with the Joint Committee process and procedures as outlined in the IRM,

    5. The materiality of the examined issues and ,

    6. Issue management initiatives (i.e. LIFE Audits, Fast Track Settlement program, etc.).

  2. The specialist’s review is generally focused on the examined issues. The Joint Committee Specialist will discuss any unexamined large, unusual, or questionable items noted in the review with the examination team or the team manager.

  3. On a LIFE audit review, the specialist may not request information on items below the thresholds established in the LIFE Memorandum of Understanding.

4.36.4.1.4  (05-04-2010)
Statute Control Procedures

  1. Statute of limitation control procedures are essential to proper Joint Committee case submission. IRM 4.36.3.5 requires that any case reported to the Joint Committee have a minimum of 12 months remaining on the period of limitation. This applies to the carryback years as well as source years. Every effort should be made to secure consents extending the remaining period with respect to the Statute of Limitations for all carryback and source years.

  2. Examination groups are required to prepare a Form 895 , Notice of Statute Expiration, whenever a return in their control has a period of limitation that will expire within 180 days. This form must be placed on the outside of the case file folder on top of any other required documents.

  3. Any return with a period of limitation expiring within the next 180 days must be placed in a red folder.

  4. For any return with an expired normal period of limitation, the examining group must insert an alpha statute code signifying the return as open under provisions relating to claims or carrybacks.

  5. In instances where the examining group failed to comply with the statute of limitation control procedures (IRM 25.6.23), the Joint Committee Specialist will prepare an advisory memorandum detailing errors or omissions. The advisory memorandum will be sent to the team manager. In the event the case file is returned to the examining group, the Joint Committee Case Return Transmittal will note the specific errors as well as the failure to follow statute procedures.

4.36.4.2  (05-04-2010)
Case Return Criteria

  1. The Case Return Criteria stated below identify errors deemed significant enough to warrant return of the case to the group for correction. Cases returned under these criteria must contain a clear and substantial error or involve an unexamined large, unusual, or questionable item. Cases will be returned to the group only with concurrence of the Joint Committee Team Manager. Where appropriate, the Joint Committee Specialist or the Joint Committee Team Manager should contact the examiner or examination team manager prior to returning the case.

  2. Every effort should be made to resolve inquiries informally. Should the examining group require more than 15 days to resolve the inquiry, a written memorandum should be prepared outlining the specific information requested and returned to the examiner via a Case Return Transmittal (CRT).

  3. If the examiner and team manager do not agree with the position taken by the Joint Committee Specialist or the Joint Committee Refund Counsel (with respect to a report submitted to Joint Committee on Taxation), the administrative file will be returned via a CRT. Generally, the examiner should resolve outstanding issues in consultation with the Area Counsel. Disagreements not resolved at this level will be elevated to the appropriate management official. See Exhibit 4.36.4-4.

  4. Refer to IRM Exhibit 4.36.3-5 for response time frames and status updates.

  5. The following subsections describe conditions that will result in the return of a case. Also see IRM 4.8.2.8.1.

4.36.4.2.1  (05-04-2010)
Substantial Error

  1. A substantial error may be a misapplication or misinterpretation of law or fact, or represent a clear omission of a material issue or item. A determination of a substantial error is based not only on the overall dollar amount, but also its materiality relative to other return items. A timing error may be deemed material.

  2. Evidence of a substantial error will generally be ascertained on the basis of the revenue agents’ reports (RAR) and relevant workpapers. Notwithstanding, where there is a clear indication of a substantial error, the Joint Committee Specialist may expand the scope of review with the consent of the Joint Committee Team Manager.

  3. See IRM 4.8.2.8.1.1 for examples of substantial error.

4.36.4.2.2  (05-04-2010)
Fraud or Malfeasance

  1. A case will be returned if there is evidence of fraud, malfeasance, collusion, concealment, or misrepresentation by the taxpayer or representative. See IRM 4.8.2.8.1.2.

4.36.4.2.3  (05-04-2010)
Serious Administrative Omissions

  1. The existence of other circumstances indicating that failure to return the case would be a serious administrative omission. For example:

    1. Failure to do so could result in serious criticism of the Service’s administration of the tax laws,

    2. A position, if left uncorrected, would establish a precedent that would seriously impede subsequent efforts to uphold the Commissioner’s position, or

    3. Would result in inconsistent treatment of similarly situated taxpayers.

  2. Also see IRM 4.8.2.8.1.3.

4.36.4.2.4  (05-04-2010)
Unprocessable Cases

  1. The case cannot be processed by CCP and the errors cannot be corrected by the Joint Committee Specialist without a significant effort (i.e. case requires new agreements, AIMS establishment, etc.). See IRM 4.8.2.8.1.4.

4.36.4.2.5  (05-04-2010)
Corrections Favorable to the Taxpayer

  1. Corrections in favor of the taxpayer must be made. See IRM 4.8.2.8.1.5.

4.36.4.3  (05-04-2010)
Processing of Joint Committee Report

  1. Upon completion of the review the Joint Committee Specialist will:

    1. Prepare the report to the Chairman of the Joint Committee on Taxation (see IRM 4.36.5) in the final form,

    2. Complete and attach Form 4081, Transmittal Memorandum-Joint Committee Case.

    3. Submit the report to the authorized official for signed approval. See Delegation Order 4–18, as revised. Electronic signatures are encouraged and should be used when appropriate.

    4. Promptly forward the report, by express mail (2nd Day Air for non-expedite refund reports and Next Day Air for expedite refund reports). The report must be mailed within two business days of signing. See IRM 4.36.5.7 for address instructions and Exhibit 4.36.3-5 for a summary of all applicable time frames.

    5. See IRM 4.36.5.3 and Exhibit 4.36.5–10 for proper file assembly.

4.36.4.4  (05-04-2010)
Inquiries from Joint Committee on Taxation

  1. Inquiries from the JCT Refund Counsel should be treated with the highest priority.

  2. If the Joint Committee Specialist is unable to resolve the Refund Counsel inquiry, the Joint Committee Specialist may contact the examiner or request that the examiner contact the Staff Attorney directly. The Joint Committee Specialist will remain charged with the case and ensure timely resolution of outstanding concerns.

  3. When a case referred back to the examination group for reconsideration is subsequently protested and resolved by Appeals, the Appeals Officer will prepare the response to the JCT inquiry. In the interim, the Joint Committee Specialist will prepare a provisional reply briefly discussing the issues raised by the JCT, indicating the status of the case and provide copies of the revised RAR and the taxpayer’s protest. This reply will be submitted to the JCT.

4.36.4.4.1  (05-04-2010)
Types of Inquiries

  1. The JCT makes two types of inquiries:

    1. Informal – Telephone or e-mail

    2. Formal – Written memorandum via Staff Review Memorandum (SRM)

4.36.4.4.2  (05-04-2010)
Response Time Frames

  1. Every effort should be made to respond to the inquiry in a timely manner. Informal inquiries should be initially responded to within 3 working days of issuance. Formal written inquiries should be responded to within 15 days.

  2. If the response to either type of inquiry will take longer than 15 days, a memorandum providing a status report should be submitted to the JCT immediately and every 30 days thereafter. The memorandum should contain the case name, tax years, earliest statute of limitations, status explanation/reason for delay, and expected completion date. See Exhibit 4.36.3-5 for a summary of all applicable time frames.

  3. If an inquiry is outstanding more than 90 days, the Joint Committee Team Manager will contact the Field Team Manager concerning the status of the inquiry.

  4. If an inquiry is outstanding more than 180 days, the Program Manager will contact the Territory Manager concerning the status of the inquiry.

4.36.4.5  (05-04-2010)
Disclosure of Correspondence with the Joint Committee on Taxation

  1. Generally, any IRS records generated during an examination or other processing giving rise to the credit or refund should be considered agency records subject to FOIA.

  2. Any correspondence from the JCT should also be considered agency records subject to FOIA but should not be released to the taxpayer without permission from the JCT.

  3. If the JCT communication contains a legend that says the document should be treated as a Congressional record and is beyond the scope of FOIA, it should be treated as such.

  4. When the JCT expresses a differing position with respect to an issue, the Service may:

    1. adopt that position and present it to the taxpayer as its own; or

    2. communicate its reason for disagreement to the JCT.

4.36.4.6  (05-04-2010)
Withdrawal of Report from Joint Committee Jurisdiction

  1. If adjustments reducing the net refund or credit below the jurisdictional amount are made or proposed by the examination group, after a report has been submitted to the JCT but before JCT has issued a clearance letter on the case, the Joint Committee Specialist will prepare a memorandum requesting withdrawal of the case from consideration by the JCT.

  2. The memorandum should be prepared at the earliest opportunity once an agreement (Form 870 or equivalent), is secured. It should contain the taxpayer’s information, briefly discuss the adjustments, set forth the taxable income or loss and tax liability as finally determined, and request that the case be released from JCT jurisdiction. The Joint Committee Specialist will submit this memorandum to the Joint Committee on Taxation.

4.36.4.6.1  (05-04-2010)
Taxpayer Notification Letters

  1. At the time of submission of the report to the Joint Committee on Taxation, the Joint Committee Specialist will prepare and mail Letter 1573 (P) to the taxpayer and its authorized representative, if applicable. See Exhibit 4.36.4-2. The team manager will be notified of the case status by email.

  2. When the clearance letter is received from the JCT, the Joint Committee Specialist will issue Letter 1574 (P) to the taxpayer and its authorized representative, if applicable. See Exhibit 4.36.4-3. The team manager will be apprised of this by e-mail. The case file (including the administrative file copy of the Joint Committee report) will be processed and closed in accordance with established procedures.

4.36.4.6.2  (05-04-2010)
Closing Procedures

  1. Related cases should be retained only if they are liable to be affected by the outcome of the review of the key Joint Committee case.

  2. After the report is submitted to the JCT, selected sample cases must be sent to Industry LQMS for review.

  3. Upon receipt of the JCT clearance letter, SBSE cases identified as part of the sample selection will be forwarded to the originating SB/SE Technical Services (TS) Group servicing that geographic area for closure. The TS Group will then send the case to EQMS for review, if necessary. See IRM 4.36.3.8.

  4. Cases closed by the JC Specialists will be processed in the JC group. The JC Specialist must ensure that cases properly include all necessary documents. Each tax return is submitted in a separate folder as follows:

    1. Forms 5344 – completion of right side only and Items 405-407.

    2. Forms 2285 attached to face of tax returns as required.

    3. Forms 3198 attached to face of each tax return folder

    4. Form 895 should be attached to the tax return folder as appropriate.

    5. A copy of Form 4549-A and Form 870 should be included in each tax return folder

    6. A copy of the Letter 1574 (P) should be included in each tax return folder

    7. Surveyed years require Form 1900 or LMSB Survey Form.

4.36.4.7  (05-04-2010)
Closing Agreements

  1. Closing agreements, including those based on Competent Authority determinations, may not be signed by the approving Service official prior to their clearance by the JCT. Notwithstanding, they must be duly executed by taxpayers or their authorized representatives. A copy of the closing agreement will be submitted with the Joint Committee report. Following release by the JCT, closing agreements will be returned to the preparer for proper signatures.

  2. In those situations where there is a request for a review of the closing agreement early in the examination, such as Fast Track Settlement or Early Referral to Appeals, the Joint Committee Specialist will forward a copy of the closing agreement, any supporting documents, and the cover memo prepared by the examiner to the JCT. The Joint Committee Specialist’s contact information will also be provided to the JCT. See IRM 4.36.3.6.2 and Exhibit 4.36.3-6. After it is reviewed, the JCT will notify the Joint Committee Specialist, who will notify the examining group that the closing agreement can now be signed by the appropriate Service official.

4.36.4.8  (05-04-2010)
Fast Track Settlements

  1. When a case settled under the Fast Track Settlement Program is submitted for review with an unsigned closing agreement, the Appeals Closing Memorandum (ACM) must be included as part of the file.

4.36.4.9  (05-04-2010)
Suspense Cases

  1. In the event a Joint Committee case must be placed in suspense while undergoing review, the case will be returned to the examining group for appropriate action.

4.36.4.10  (05-04-2010)
Bankruptcy Cases

  1. Bankruptcy or receivership cases that meet the jurisdictional amounts of IRC 6405 must be reported to the Joint Committee on Taxation. Overpayments or deficiencies should be processed in accordance with the procedures outlined in IRM 4.27, Bankruptcy Handbook.

4.36.4.11  (05-04-2010)
TEFRA and Non-TEFRA Investor Procedures

  1. Joint Committee cases that contain TEFRA and other flow-thru issues will be suspensed. Prior to placing the case in suspense and its submission to the appropriate Joint Committee Specialist group for preliminary review, agreed deficiencies relating to flow-thru issues must be assessed. Upon completion of the review, the case will be returned to the examining group (without preparation of a Joint Committee report) pending completion of the related key case examination.

  2. If the taxpayer is entitled to a minimum refund in excess of $2 million a JC report will be prepared prior to completion of the flow-thru examination. The minimum refund procedures for cases with unagreed issues are applicable. See IRM 4.36.3.7.1.

  3. Upon completion of the examination of the key case, the case will be returned to the Joint Committee Specialist group for preparation of the Joint Committee report provided the jurisdictional amount is met at that time.

4.36.4.12  (05-04-2010)
Processing IRC 6405(a) Refunds-Expedite Refund Report

  1. To ensure timely processing of "expedite" refunds, the Joint Committee Specialist will prepare closing documents and place them in a separate "dummy" file. Once a dated copy of the report acknowledging receipt of the report by the JCT is received, the Joint Committee Specialist will notate on Form 3198, Special Handling Notice (or local equivalent) the tentative scheduled refund date (23C date), which is the 31st day from the date the report was received by the JCT. The specialist will attach the form (or its equivalent) to the file. The specialist will then forward the "dummy file" to the Field Office Resource Team (FORT) at the appropriate Centralized Case Processing (CCP) unit.

  2. Generally, JCT inquiries received during the above 30-day period will not defer issuance of the refund. Nevertheless, should the JCT advise against payment of the refund, the Joint Committee Specialist will immediately contact CCP to stop its issuance.

4.36.4.13  (05-04-2010)
Refunds Eligible for Expedite Treatment

  1. The Service will issue a refund subject to IRC 6405(a) in advance of its release by the JCT under the following circumstances:

    1. The period for assessment under the statute of limitations (IRC 6501) must be protected for all jurisdictional years as well as the source year. Accordingly, in carryback situations, the original statute must be open or extended by consent for the source year as well as the carryback year(s).

      Note:

      If a claim year or carryback year has a statute designated with an alpha code on AIMS, it will not qualify for expedite treatment.

    2. For expedite refund requests, there must be a minimum of twelve months remaining with respect to the Statute of Limitations when the case is submitted to the Joint Committee Specialist Group. For Modified Expedite Refunds, the remaining period open under the Statute of Limitations must be sufficient for completion of the examination and JCT review process.

    3. Carryback years which do not have open assessments statutes will not deny expedite refund treatment for those years which do qualify.

4.36.4.13.1  (05-04-2010)
Refunds Not Eligible For Expedite Treatment

  1. Under no circumstance will the Service process a IRC 6405(a) refund or credit with respect to any jurisdictional year prior to release by the JCT if any of the following conditions exist:

    1. any portion of the tax, if erroneously refunded, may only be recovered by civil action brought in the name of the United States under the provisions of IRC 7405 for erroneous refunds; or

    2. The portion of a refund attributable to an unexamined (or not surveyed) source year, to the extent such amount is not secured by bond under the procedures set forth in IRM 4.36.3.7.3; or

    3. The remaining period of limitations for that jurisdictional year is less than six months.

4.36.4.14  (05-04-2010)
Disclosure of Individual Information - Form 5482, Record of Disclosure

  1. Tax information about individuals or aliens admitted to permanent U.S. residence provided to the JCT pursuant to IRC 6405 requires Privacy Act accounting on Form 5482, Record of Disclosure.

  2. The Joint Committee Specialist will complete Form 5482, Record of Disclosure if the individual is a U.S. citizen or alien admitted to permanent U.S. residence. The form is a two-part form. The original will be filed with the examination administrative file for the individual and the copy will be retained in the Joint Committee Specialist group for five years. Additional Forms 5482 need to be completed if information concerning years and/or individuals not previously accounted for is disclosed to the JCT. See IRM 11.3.19, Privacy Act Accounting for Disclosures, for additional information about the form.

  3. Form 5482 should be completed at the time the Joint Committee report is forwarded to the Joint Committee on Taxation.

  4. When completing the form, Item 3, Record System Number, should be 42.001 and Item 8, Privacy Act Provisions, should be (b)(9).

Exhibit 4.36.4-1 
Letter 1573 A (P) (10-2003)

Name of Taxpayer Taxpayer Identification Number:
Attn: Corporate Officer Form(s):
Street Address -- Suite/RM # Contact Person:
City, State, Zip Code Telephone Number :
  Employee Identification Number:
  Date:
  Tax Periods
Source Years:
Refund Years:
Dear Taxpayer:  
The Joint Committee Specialist Group has received your case from the examiner. We will review the case and prepare a report for the Joint Committee on Taxation. We will notify you when we forward the report to the Joint Committee on Taxation.
If you have any questions about the process or need additional information, please call the person named above.
  Sincerely,
  (Signature)
(Type name of specialist)
Joint Committee Specialist
cc: Authorized representative  
NAME OF REPRESENTATIVE  
  Letter 1573A(P)(Rev. 10-2003)

Exhibit 4.36.4-2 
Letter 1573 (P) (10–2003)

Name of Taxpayer Taxpayer Identification Number:
Attn: Corporate Officer Form(s):
Street Address -- Suite/RM # Contact Person:
City, State, Zip Code Telephone Number:
  Employee Identification Number:
  Date:
  Tax Periods
Source Years:
Refund Years:
Dear CORPORATE OFFICER:  
Introduction (Choose appropriate paragraph)
(Exam no-change with tentative allowances)
Based on the recent examination of your income tax returns for the indicated tax periods, the Internal Revenue Service has proposed to the Joint Committee on Taxation that these returns be accepted as adjusted by the tentative allowance refund(s) shown on the Form 1045/1139 which you previously filed.
(Survey with tentative allowances)
The Internal Revenue Service has proposed to the Joint Committee on Taxation, in a special report mandated by section 6405(b) of the Internal Revenue Code of 1986, that your income tax returns for the indicated tax periods be accepted as adjusted by tentative refund or credit allowances, based on Form 1139/1045 which you had previously filed.
(Survey with claims)
The Internal Revenue Service has proposed to the Joint Committee on Taxation, in a special report required by section 6405(a) of the Internal Revenue Code of 1986, that your income tax returns for the indicated tax periods be accepted as amended by refund claims per Form 1120X/1040X which you had previously filed.
(Exam, report previously furnished)
The Internal Revenue Service submitted a special report to the Joint Committee on Taxation, as required by section 6405(a) of the 1986 Internal Revenue Code, outlining the findings of a recent examination of the company's income tax return for the indicated years, shown in a report of examination, dated MM/DD/YYYY, previously furnished to you. Agreement to the tax changes was indicated by the MM/DD/YYYY signing of a waiver Form 870.
(Exam, report enclosed)
The Internal Revenue Service submitted a special report to the Joint Committee on Taxation, as required by section 6405(a) of the 1986 Internal Revenue Code, outlining the findings of a recent examination of the company's income tax return for the indicated years, shown in a report of examination, dated MM/DD/YYYY. Enclosed is a copy of the report. You indicated approval to the tax changes by signing a waiver Form 870.
Payment (Choose appropriate paragraph)
(Overpayments over $2 million)
The tax overassessment(s)/overpayment(s) shown in the report cannot be processed for refund or credit until after the case is released by the Joint Committee on Taxation.
(Qualified Waiver)
The "qualified" waiver Form 870, showing offsetting deficiencies and overassessments, will become effective on the date the Joint Committee on Taxation releases its jurisdiction of the case. The remaining deficiencies, plus interest, shown on an "unqualified" waiver Form 870, will be assessed; if you have not made payment, we will bill you.
(Advance Payment)
The advance payment, which you made on MM/DD/YYYY, will be applied against these amounts.
(Expedite Refund)
When the Joint Committee on Taxation receives this report, the 30-day period, during which we are statutorily prohibited from issuing the refunds, will commence. If the Joint Committee on Taxation does not raise any concerns regarding the Service’s position, we will process the refunds as soon as possible after the expiration of this 30-day period.
(Straight Deficiency)
If you have not paid the deficiency shown in the report, we will bill you soon for the deficiency, plus interest.
(Straight Overpayment)
Since the overassessment shown on the report is less than the jurisdictional amount of $2 million, the report will be processed prior to release by the Joint Committee Taxation.
Other (Choose appropriate paragraph)
(Restricted Interest)
Even though there is/are no tax change(s) for some of these examined years, the indicated adjustments to income, deductions and/or credits result in assessable "restricted interest" on the potential tax deficiency prior to application of the net operating loss or credit carryback.
(872-A)
This letter does not terminate the Internal Revenue Service consideration referred to in consent Form 872-A filed for the tax period ended MM/DD/YYYY.
Closing
We will notify you when the Joint Committee on Taxation completes consideration of your case. If you have any questions, please contact the person whose name and telephone number are shown above.
  Sincerely,
   
  Joint Committee Specialist
Enclosure
cc: Authorized representative
Name of Representative
 
  Letter 1573 (P) (Rev. 10-2003)

Exhibit 4.36.4-3 
Letter 1574 (P) (10–2003)

Name of Taxpayer Taxpayer Identification Number:
Attn: Corporate Officer Form(s):
Street Address -- Suite / RM # Contact Person:
City, State, Zip Code Telephone Number:
  Employee Identification Number:
  Date:
  Tax Periods
Source Years:
Refund Years:
Dear Corporate Officer:  
We have been advised that the Joint Committee on Taxation has completed its consideration of our special report (made to satisfy the requirements of section 6405 of the Internal Revenue Code of 1986) on these income tax returns and has taken no exception to the conclusions reached by the Internal Revenue Service
Processing (Choose appropriate paragraph)
The tax changes shown on the examination report, previously furnished to you, are being processed for refund or credit.
The overassessment(s) shown on the approved Form 1040X/1120X claims are being processed for refund or credit.
The tax changes have previously been processed.
Use the following if necessary  
This letter does not terminate the Internal Revenue Service consideration referred to in consent Form 872-A filed for the tax periods ended MM/DD/YYYY.
  Sincerely,
   
  Joint Committee Specialist
   
cc: Authorized representative
Name of Representative
 
  Letter 1574 (P) (Rev. 10-2003)
The following wording is used if the refund is made before the Joint Committee on Taxation has released its jurisdiction:
The Joint Committee on Taxation has taken no exception to our processing of the overpayments shown on the examination report previously furnished to you OR being accepted per your amended return claims on Form 1040X/1120X previously filed by you.
Accordingly, the overpayments will soon be processed for refund or credit.
This letter is not a notification that the Joint Committee has completed its consideration of the conclusions reached by the Service regarding these income tax returns. At a later time, we will let you know when the Joint Committee completes such consideration.

Exhibit 4.36.4-4 
Dispute Resolution Chart

Types of Dispute First Level Second Level Third Level Comments
Proposed Change to RAR -
JC Specialist Inquiry
Team Manager & JC Specialist Manager Territory Manager & JC Program Manager DFO/Compliance Area Director and Director, PQAS If no agreement reached, the Director, PQAS with concurrence from Chief, will make the decision.
Proposed Change to RAR-JCT Inquiry Team Manager & JC Specialist Manager Territory Manager & JC Program Manager DFO/Compliance Area Director and Director, PQAS; JCT Senior Refund Counsel and Chief Counsel If no agreement reached, the Director, PQAS with concurrence from Chief Counsel, will make the decision.

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