4.10.2  Pre-contact Responsibilities

Manual Transmittal

January 17, 2012


(1) This transmits revised IRM 4.10.2, Examination of Returns, Pre-contact Responsibilities.


This text includes guidance for completing required responsibilities and analyses before an examination is initiated, pre-contact planning of the examination, and instructions for contacting taxpayers.

Material Changes

(1) Editorial changes were made throughout IRM 4.10.2 which include the following:

  • Updated website addresses

  • Updated IRM references and other reference material

  • Updated position titles

  • Corrected spelling errors and typographical errors

  • Updated IRM (3) reference from AC 501 to AC 522

  • Removed references to Form 9984-D because both office and field uses Form 9984

Effect on Other Documents

This IRM supersedes IRM 4.10.2 dated April 2, 2010.


SBSE Compliance Examination Field Operations Employees

Effective Date


Duane Gillen
Director, Examination Policy, SE:S:E:EP
Small Business/Self-Employed  (01-17-2012)

  1. The purpose of this section is to provide examiners with guidance for:

    • Analyzing tax returns before contacting the taxpayer to determine if the return should be examined and which items on the return should be examined;

    • Determining the examination scope and depth; and

    • Contacting taxpayers.  (04-02-2010)
Return Assignment

  1. Before beginning the actual analysis of a return for examination issues, consideration should be given to factors which could prevent examiners from initiating an examination. Listed below are some of the factors that must be considered before an in-depth, pre-contact analysis is performed:

    1. Statute of limitations (SOL);

    2. Examination cycles;

    3. Conflict of interest;

    4. Examiner conducted most recent audit;

    5. Repetitive audits; and

    6. Other IRS Divisions are working with the taxpayer.  (01-17-2012)
Statute of Limitations (SOL)

  1. The Internal Revenue Code limits the time in which the government may make an assessment of tax. Examiners have the primary responsibility for identifying and protecting the statutes of limitations for returns in their custody. IRM 25.6.23, Examination Process - Assessment Statute of Limitations Controls, provides guidance for verifying statute dates. Failure to protect the statute of limitations can result in disciplinary action.

  2. If the statute of limitations is imminent, or if it has already expired on the assigned return, the return should be immediately brought to the group manager's attention to determine the appropriate disposal of the return.

  3. A statute of limitations to assess tax can be extended with the taxpayer’s consent. Examiners must obtain the approval of the group manager before requesting a taxpayer to execute a consent. The need for a consent should be clearly identified before it is solicited and the group manager’s approval documented in the case file. See IRM (2), Assessment, for a listing of some of the conditions that allow for a statute extension.


    An examiner can not initiate an examination on any return with less than 12 months remaining on the statute of limitations for assessment, without prior managerial approval.  (01-17-2012)
Examination Cycles

  1. The examination and disposition of income tax returns is to be completed within 26 months for individual returns and within 27 months for business returns (Forms 1120, 1041, 1065, etc.) after the due date of the return or the date filed, whichever is later. Strict adherence to these guidelines is needed to ensure that the examination and all other processing can be completed within the statute of limitation.

  2. If the examination cycle can not be met during the initial screening, the matter should be discussed with the group manager. If the group manager and examiner agree that an examination should be initiated, approval for deviation from the examination cycle requirements should be documented in the workpapers.

  3. The following types of returns are exempted from the requirement to complete the examination and other processing within the exam cycle. These guidelines are not applicable to Forms 706 and 709.

    Cases Exempted From 26/27 Month Examination Cycle
    Source Code Description
    17 Tax Shelter Program
    39 Tax Shelter Program Related Pick-Up
    64 Pick-Up Related to Forms 1065, 1041 and 1120S other than Tax Shelter
    Project Codes Description
    0015 Tax Shelter Program - Other TEFRA/AMENDED
    0074 Related to Appeals not listed
    0310, 0311, 0154, 0156, 0165, 0437, 0458, 0669, 0112, 0016, 0034, 0149, 0150, 0265, 0266, 0449, Frivolous Filers/Nonfilers
    0101-0118 Tax Shelter Program -- Specific  
    Push Code Description  
    020 Delinquent Return  
    021 Substitute for Return (Use if a TC 150 is not needed.)  
    036 Substitute for Return  
    037 Potential CI Referral/Nonfiler  
    Status Code Description  
    17 Fraud Development Status  
    18 Acceptance by Criminal Investigation  
    29 Other TEFRA Suspense  
    30 Form 1254, Examination Suspense Report  
    32 General Fraud Suspense  
    36 Grand Jury Suspense  
    38 Suspense-Other  
    44 PSP Suspense  
    Returns with AIMS creation dates 270 days old or less with the following source codes: Description  
    11 Studies, Tests, and Research  
    23 TEFRA Related  
    24, 25 Nonfiler  
    30 Claims for Refund/Abatement  
    32 Carryback Refund  
    60 Information Report  
    77 State Information  
    85 IRP Information Document Match  
    88 Special Enforcement  
    90 Fraud Regular  

  4. IRC 6404(g) suspends interest for timely filed individual returns for taxable years ending after July 22, 1998, if the Service fails to notify the taxpayer of a liability within 18 months after the due date of the return (including extensions). P.L. 110-28, Title VIII, Subtitle B, Part 2, section 8242(a), amended IRC 6404(g) interest suspension period from 18 months to 36 months for notices provided to taxpayer after November 25, 2007. See IRM, Notice Under IRC Section 6404(g) - Suspension of Interest, and IRC 6404(g).

  5. Circumstances may warrant exceeding the exam cycle if failure to conduct the examination would:

    1. Result in a serious criticism of the Service’s administration of tax laws,

    2. Establish a precedent that would seriously hamper subsequent attempts by the Service to take corrective action,

    3. Result in inconsistent treatment of similarly situated taxpayers, or

    4. Be contrary to an established Service position (the Service position must be clear at the time the approval, to initiate the examination, is granted and not in the developmental stages).  (08-01-2007)
Conflict of Interest

  1. Policy Statement 4–6 (P-4-6), IRM, prohibits examiners from examining or surveying a tax return if a relationship impairs impartiality. A conflict of interest exists if an examiner’s personal relationship(s) or private interest (usually of a financial or economic nature) conflict, or raise a reasonable question of conflict, with the examiner’s public duties and responsibilities.

    1. Personal relationships can include family members, friends and associates.

    2. A financial interest may be one involving the examiner’s spouse, minor child, partner, or organization in which the examiner is serving as an officer, director, trustee, partner or employee, or any person or organization with whom the examiner is negotiating or has any arrangement concerning prospective employment.

  2. Examiners must avoid any situation which creates a conflict of interest or creates a reasonable question of a conflict of interest with their official duties. Penalties prescribed by statute for established violations include both a fine and/or imprisonment.

  3. An examiner assigned a return which might create a real or apparent conflict of interest must immediately bring this matter to the attention of the group manager.

  4. Examiners should never initiate, terminate, or in any way modify audit actions based on requests from certain Executive Branch employees (specifically the President, Vice President, employees of the executive offices of the President or Vice President, or any other cabinet level official with the exception of the Attorney General). Any requests received by an examiner that violate this prohibition should be reported to the Treasury Inspector General for Tax Administration. Examiners should always consult with the group manager if anyone, other than the group manager, requests actions related to ongoing or potential examinations.  (01-17-2012)
Repeat Audits by the Same Examiner

  1. IRM, Policy Statement 4–5, (P-4-5), prohibits an examiner or specialist from surveying or examining a tax return of a taxpayer for more than five consecutive years (60 months) from date of assignment. If the examination is in process at the five consecutive year point, the examiner or specialist is allowed to complete the examination provided the current cycle or audit has less than 12 months remaining from the five consecutive year point. An examiner or specialist will not be reassigned to the same taxpayer for at least one intervening examination or two intervening surveys.

  2. If an examiner is assigned a return described in paragraph (1) above, the tax return should be returned to the group manager for reassignment.  (04-02-2010)
In-depth Pre-contact Analysis

  1. The examiner is responsible for determining the scope of the audit, beginning with the issues identified by the classifier on the classification check sheet. The examiner must perform a pre-contact analysis including a thorough review of the case file to identify large, unusual, or questionable items (LUQs) beyond those selected on the classification check sheet. The examiner should take the following actions:

    1. Review the complete tax return including line items, credits, the balance sheet, elections and schedules, and any other items attached to the return.

    2. Review the Form 5546 (C), Examination Return Charge-Out Sheet, for information including the assessment statute expiration date (ASED), prior audit results, activity and source codes, collectibility indicators, etc. Additional details are available in IRM 4.4, Aims/Processing Handbooks.

    3. Review internal and external data from the sources reflected in the table below:

      External Data Source
      IDRS - Integrated Data Retrieval System
      CFOL - Computer Files On Line
      MACS - Midwest Audit Classification System or CDE - Compliance Data Environment (replaces MACS)
      IRP - Information Reporting Program Transcripts
      Asset Locator / People Locator Service
      Internet Research

    4. Examiner should review the above information to determine if another IRS function is working with the taxpayer. If another function is working with the taxpayer, the examiner should contact the employee assigned the case and determine the extent of their involvement. Facts and circumstances of the involvement may affect the examination of the return. (CFOL commands IMFOL and BMFOL)

    5. Examiners must check appropriate internal records to determine if a valid power of attorney is on file for the year(s) under examination. If a TC 960 is posted the examiner must secure a CC CFINK and retain a copy in the file.

    6. Perform preliminary research, including reviewing code section, regulations, court cases, revenue rulings and procedures, Coordinated Issue Paper (ISP), Audit Technique Guides (ATG), and/or business units' web pages as necessary to become familiar with the issues.

    7. Office examination: The Form 9984, Examining Officer's Activity Record, should document all actions taken during the pre-audit stage. If any additional issues are identified as a result of the pre-audit or if classified issues do not warrant examination, the examiner will document the revision of the scope and obtain approval from the group manager. Managerial approval is required when pre-auditing time exceeds 1 hour on a non-business return and 1.5 hours on a business return.

    8. Field examination: The examiner should perform any additional pre-contact audit steps appropriate to their taxpayer. The examiner should document their actions taken and findings during the pre-planning stage. Revenue Agent "Plan to Close" Check Sheet (Lead Sheet 110) can be used for this purpose. Preplan time charged to a case will vary with the complexity of the case. Group managers should monitor phase I or preplan time to ensure that the time charged is commensurate with the work accomplished. This can be accomplished using the Embedded Quality tool.  (04-02-2010)
Large Unusual Questionable Items (LUQs) Defined

  1. The definition of a large, unusual, or questionable item will depend on the examiner’s perception of the return as a whole and the separate items that comprise the return. Some factors to be considered when identifying LUQs are:

    1. Comparative size of the item — an expense item of $6,000.00 with total expenses of $30,000.00 would be a large item; however, if total expenses are $300,000.00, the item would not be generally considered a large item.

    2. Absolute size of the item — despite the comparability factor, size by itself may be significant. For example, a $50,000 item may be significant even though it represents a small percentage of taxable income.

    3. Inherent character of the item — although the amount of an item may be insignificant, the nature of the item may be significant; e.g., airplane expenses claimed on a plumber’s Schedule C.

    4. Evidence of intent to mislead — this may include missing schedules, incomplete schedules, misclassified entries, or obviously incorrect items on the return.

    5. Beneficial effect of the manner in which an item is reported — expenses claimed on a business schedule rather than claimed as an itemized deduction.

    6. Relationship to other items — incomplete transactions identified on the tax return. For example, the taxpayer reported sales of stock but no dividend income.

    7. Whipsaw issues — occur when there is a transaction between two parties and characteristics of the transaction will benefit one party and harm the other. Examples include alimony vs. child support, sale vs. rental/royalty, employee vs. independent contractor, gift vs. income.

    8. Missing items — consideration should be given to items which are not shown on the return but would normally appear on the returns of similar taxpayers. This applies not only to the examination of income, but also to expenses, deductions, etc., that would result in tax changes favorable to the taxpayer.

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Step 1: Review Return to Identify LUQs

  1. Regardless of the type or class of return being examined, examiners should first review the return in its entirety. This review should include not only the line items and credits claimed, but also such things as the balance sheet, elections, schedules, or any other documents attached to the return.

  2. Other documents included with the return that should be reviewed are:

    1. Examination Return Charge-Out Sheet,Form 5546-C. This form contains information such as statute dates, prior audit results, no-change issue codes, collectibility indicators, and special messages. See IRM 4.4, AIMS/Processing Handbook, and related exhibits for a more detailed description of the information contained on the charge-out sheet.

    2. Classification Sheets — Generally, field cases will have a classification sheet attached. The field examiner will review the classification sheet and modify the scope as appropriate. The field examiner will document the decision on the risk analysis workpaper. A classification sheet will be enclosed on all office examination cases. Office examiners must obtain managerial concurrence prior to modifying the examination scope. If the scope is modified the examiner will document this change on Form 9984.

    3. Other Sources of Information — Depending on how the case was selected for examination, the case file may contain additional information from internal sources. See IRM (1) paragraphs (c) and (d) for other sources of information.  (08-01-2007)
Step 2: Examination of Income

  1. Complete the required pre-contact analysis for the examination of income as outlined in IRM, Minimum Requirement for Examination of Income.  (04-02-2010)
Step 3: Required Filing Checks

  1. Required filing checks will be completed as outlined in IRM 4.10.5, Required Filing Checks. However, when the scope of the examination is limited to a flow-through adjustment, the required filing checks may be limited to consideration of the taxpayer's prior and subsequent year returns.

  2. During the pre-contact phase the examiner should review internal information including IDRS and CFOL to determine whether the prior and subsequent year returns have been filed.

  3. The examiner should review the three year comparative analysis provided by MACS/CDE to assist in determining the audit potential of the prior or subsequent year. The examiner should use their professional judgment to determine if a more detailed analysis is required. This analysis should be retained in the case file.

  4. The examiner should similarly determine whether known related tax returns, information returns, employment tax returns, etc. have been filed.

  5. The examiner must document their findings on Workpaper 130, Multi-year and Related Returns Lead Sheet, and make any required comments. Any documents used in this determination should be included in the case file.  (04-02-2010)
Evaluation of Audit Potential

  1. After completing the in-depth pre-contact analysis, a determination must be made whether the return warrants examination. Examiners will evaluate the identified LUQs, the materiality of any preliminary T-Account imbalances, and the results of the initial required filing checks. Factors to consider when evaluating the audit potential are discussed below.  (04-02-2010)
Risk Analysis Value Added Decision Making - Preplanning Phase

  1. Examiners should compare the potential benefits to be derived from examining a return to the resources required to perform the examination. Once the potential benefits and resources are considered, priorities can be established. Examiners are expected to effectively manage their workload by prioritizing the issues so that the issues with higher audit potential are examined over those with lower potential. Issues with little or no audit potential should not be selected for examination. See IRM, Limiting the Scope When Issues Were Examined and No-Changed in Either of the Two Preceding Years.

  2. The goal of Examination is to determine the "substantially correct" tax liability. The 80/20 concept is "value-added" decision making that weighs the impact of our decisions (potential results) with the investment of additional case time (cost).

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Value Added Decision Making at the Mid Audit Decision Point

  1. At the mid point of the examination, using risk analysis, the examiner should determine whether the remaining classified/identified issues should be examined. This decision should be based on the facts and circumstances, evaluation of internal controls (in business examinations) and the examiner’s judgment. For example, the resulting additional tax is not expected to be material, or the time to develop additional issues is not justified, based on the potential for additional tax.

  2. The mid-point of the examination could be determined based on the number of issues classified/identified or the number of hours expended.

  3. Examiners are expected to use their professional judgment to determine if it is in the government’s best interest to continue the examination. If it is not in government’s best interest to continue the examination, the examiner must document their decision on the Risk Analysis Workpaper as described below.  (04-02-2010)
Documenting the Value Added Decision

  1. In pre-planning, the examiner should use sound judgment to determine the vital few issues to be examined which may necessitate declassifying issues and/or adding issues in lieu of those classified.

  2. When a classification sheet is not included with the return, the only documentation needed to set the initial scope is the statement "pre-plan vital few" on the Risk Analysis Workpaper and/or Form 9984.  (08-01-2007)
Risk Analysis Workpaper Documentation - Field Examination

  1. Field examiners should use the risk analysis workpaper to document their risk based decisions. This workpaper was designed as a tool to assist the examiner in making and documenting their risk analysis decisions with regard to depth and scope of their examination.

  2. The risk analysis workpaper is a mandatory workpaper and has been designated as W/P 110-2.

  3. In many instances the examiner can document their decision by checking the box. However, for complex risk analysis decisions, the examiner should provide a narrative clarifying their course of action. Space is provided at the bottom of the risk analysis workpaper.  (04-02-2010)
Risk Analysis - Preplan Phase

  1. During the preplan phase, the examiner should use sound professional judgment to determine the vital few issues to be examined. This may necessitate declassifying issues and/or adding issues in lieu of those classified.

  2. Documentation of this decision is made in the preplan section of the Risk Analysis Workpaper by checking the appropriate box.

    • If the scope did not change, check the "No Change box"

    • If the scope is changed from the classification check sheet, check the "Revised Scope to Vital Few" and check either "Declassified" and/or "Classified" .


      Declassified denotes that some classified issues were not audited; whereas, classified denotes that new LUQs issues were added.  (04-02-2010)
Risk Analysis - Examination Phase

  1. In this phase the examiner, using professional judgment and risk based decision making concepts, must decide whether or not to continue with the scope established during the preplan phase, expand the scope or curtail the audit and close the case. The examiner must check the appropriate box in the examination section on the Risk Analysis Workpaper.

    1. If the scope has not changed from what was preplanned the examiner should check the "No change to scope" box.

    2. If the scope has been increased to include newly discovered LUQs, the examiner should check the "Expanded Scope" box.

    3. At anytime during the examination phase, it is not in the government’s best interest to continue the examination, the decision should be documented on the Risk Analysis Workpaper by checking the "Decision to End Audit," box.

    4. A decision to pick up a prior, subsequent and/or related return should be documented on W/P 130 Multi-year and Related Return lead sheet.

  2. For complex risk analysis decisions, the examiner should provide a narrative clarifying their course of action. Space is provided at the bottom of the risk analysis workpaper. Group Manager’s approval is not required.  (04-02-2010)
Risk Analysis Workpaper Documentation - Office Examination

  1. Office examiners are not required to complete a risk analysis workpaper. When an office examiner expands or limits the scope during the examination, they should fully document their risk based decisions on Form 9984.  (04-02-2010)
Limiting the Scope When Issues Were Examined and No-Changed in Either of the Two Preceding Years

  1. Limiting the scope is appropriate when an examination of the same issue(s) in either of the two preceding years resulted in a no-change. All individual returns closed as a no-change, require entry of an IMF no change issue code to allow AIMS to record the issues considered during the examination and no-changed. The information is sent to Master file and captured by EOAD. You can review this information using command codes I/BMFOLZ. If a subsequent return is open on AIMS, the Form 5546-CExamination Return Charge-Out Sheet will display the IMF issue codes. Also, the examination return charge-out sheet can be referred to for indications of prior examinations. The charge-out sheet generally provides:

    1. The year of the prior audit;

    2. The disposal code;

    3. The deficiency or overassessment amount; and

    4. No-change issue codes.

  2. If issue(s) being considered in the current examination were no-changed in either of the two preceding years or had a small tax change, the issue(s) should be eliminated from the audit plan unless some other information in the case file indicates that the issue(s) is worth examining.

  3. If all issues are found to be repetitive the case may qualify for repetitive audit. See IRM  (04-02-2010)

  1. To decrease the Account Receivable Dollar Inventory (ARDI) and increase the quality of assessments, examiners should consider collectibility when setting the scope of an examination. Collectibility will be based on the taxpayer's current financial condition and not the tax return (which reflects the taxpayer’s past financial condition.)

  2. Form 5546 (C), Examination Return Charge-Out Sheet, may provide alerts to potential collectibility issues. Examiners should review this form for collectibility indicators. See IRM, General Collectibility Considerations, for a listing and definition of collectibility indicators and steps to take when evaluating collectibility potential during the pre-planning phase.

  3. If a charge-out sheet is not in the file, the examiner must pull certain CFOL prints. See IRM General Collectibility Considerations, for a listing.

  4. Not all taxpayers lacking the means to satisfy additional tax liabilities will be identified. Examiners should be alert for indications in the file that collectibility may be a factor to consider; i.e., the taxpayer is deceased or the taxpayer is a defunct corporation and the issue of transferee liability is not present. Form 9439, Collectibility Evaluation Form, may be used to help document collectibility.

  5. If collectibility is an issue in an assigned case, the group manager should be alerted as soon as the issue is discovered. Managers will make the final determination whether to survey the return or to limit the scope/depth of an examination. A tax return may be surveyed due to an absolutely uncollectible assessment or subjected to a limited scope examination where there is lack of collectibility. It should be emphasized, however, that returns should not be surveyed based solely on collectibility where a limited examination has the potential for developing leads to other non-compliant taxpayers.

  6. Examiners are required to document their evaluation of collectibility during the preplanning phase of the examination.

    1. Collectibility considerations are documented on Lead Sheet 105, Administrative Lead Sheet, for field examination.

    2. Collectibility considerations are documented on Form 9984, for office examination.  (04-02-2010)
Decision to Survey a Return

  1. Following the pre-contact analysis but before examining any books and records, examiners should decide whether an examination will result in a material change to the taxpayer’s tax liability. If the examiner concludes that an examination is not warranted, the examiner should survey the return after assignment.

  2. Traditionally, returns have been closed survey using paper documents. Effective January 2007, some returns can be closed survey using a virtually paperless process. See IRM for non-examined closings utilizing a paperless process.  (01-17-2012)
Conditions Allowing Survey of Returns After Assignment

  1. A return will be surveyed after assignment if, after conducting the in-depth analysis and evaluating the audit potential the following conditions are met:

    1. The taxpayer (or representative) has not been contacted,

    2. Taxpayer records have not been inspected, and

    3. The examiner determined an examination will most likely not result in a material change in the taxpayer's tax liability.


      This authority extends to returns identified for examination on Form 3449, Referral Report. When a return is closed survey after assignment, disposal code 32 should be used. See Document 6036, Examination Division Reporting Codes Booklet, for disposal codes.

  2. In accordance with IRC 7508, field examiners must not conduct any examinations on taxpayers who have been deployed to a Qualified Combat Zone (QCZ). Also, ongoing examinations involving any individual identified as a QCZ taxpayer should be closed immediately, unless criteria under "Compelling Reasons" are determined. See IRM through IRM for guidance.

    1. Substantiation - See IRM

    2. Examination Guidance - See IRM

    3. Compelling Reasons to Suspense Procedures - See IRM

  3. Under certain conditions, a return may be surveyed after the taxpayer has been contacted, but before records have been requested or inspected. Also, instances where the taxpayer is deceased, has a terminal illness, or other extraordinary circumstances exist, may warrant the survey of the return. Normal survey procedures should be followed and Letter 1024, Return Accepted as Filed, should be issued.  (04-02-2010)
Procedures for Surveying Returns After Assignment

  1. Procedures for surveying returns after assignment are as follows:

    1. Stamp the return with the following imprint:

      Examiner’s Signature (and Date)
      Approved — Group Manager’s Signature (and date)


      The stamp should be approximately 3? X 1? and procured locally by the area.

    2. Examiners are required to sign and date the imprint made on the return or electronic print if it is used for the return. The examiner should submit the surveyed return to their manager for approval.

    3. Group managers are required to indicate concurrence with the examiner’s decision to survey the return by signing and dating the imprint.

    4. The use of Form 1900, Income Tax Survey After Assignment, is mandatory in some cases. For example, strategic work, NRP, Joint Committee, Employee Audit, etc., can not be surveyed without a Form 1900. See IRM, Survey of Examination Cases, for more information. Additionally, whenever an examiner considers it necessary to explain why a return was surveyed after assignment, Form 1900 should be completed.

    5. Form 3187 will be used for the survey of estate and gift tax returns. If Form 3187 is not used a written explanation should be included in the Form 9984 and the appropriate workpapers.

  2. An electronic print can be used instead of the original return. Electronic prints include but are not limited to the following:

    1. RTVUE, BRTVU;

    2. MACS or CDE;

    3. ELF (An ELF return can be secured using command code TRDBV. This command code will eventually replace RTVUE and BRTVU.);

    4. IMFOL, BMFOL;

    5. TXMOD; or

    6. TRPRT- This command is used to request a graphical (form image) of an electronically filed tax return. The print contains original taxpayer submitted data only. There are no corrections or processing codes. In essence, it creates a tax form out of electronically filed data. TRDBV prints should not be given to the taxpayer. If a print is to be given to the taxpayer, use command RTFTP.


    If you are working from a copy of the tax return, the copy can not be surveyed. To close this case without requesting the original return, you must secure an electronic print and survey the print. Staple the print to the face of the copy of the return. Ensure the copy is clearly labeled in red "Copy Secured by Examination."  (04-02-2010)
Form 1900, Income Tax Survey After Assignment, Instructions

  1. Return(s): Check or enter the applicable form number of the return(s) being surveyed.

  2. Name and address: Enter the last known name and address.

  3. SSN/EIN: Enter applicable numbers from the returns being surveyed.

  4. Documents surveyed: Identify the types of document(s) included with Form 1900. There are three categories to select from:

    • Return - The tax return filed by the taxpayer. If you do not have an original return in the file, use an electronic return print. See IRM for the definition of electronic print;

    • Amended Returns - the file must contain a Form 1040X, 1120X Form 1120X, or whatever type amended return document filed by the taxpayer; and

    • Claims.

  5. Recommended action: Complete this block to indicate whether your recommended action for the return(s) is "Accepted as Filed" or "Allow in Full or Allow as Corrected."

  6. Accepted As Filed is used when the following conditions occur:

    1. Surveying original returns on which no action has been taken,

    2. Original returns on which tentative carryback allowances have been made, or

    3. Amended returns filed after the due date and reporting additional tax liability.

  7. Allow in Full or Allow as Corrected: This category is selected when claims or amended returns filed as claims are surveyed.

  8. Related cases: Cases related to the case being surveyed. Enter related case name and TIN when applicable.

  9. Taxable year or period: List each year’s return being surveyed on a separate line.

    1. Calendar Year — show ending date (e.g., 12–31–2006).

    2. Fiscal Year — show ending date (e.g., 6–30–2006).

    3. Short Period — show both beginning and ending date (e.g., 1–1–2006 – 9–30–2006).

    4. 52/53 Week Year — show last day of year (e.g., 6–22–2006).

  10. Adjusted gross or taxable income reported: Enter the adjusted gross or taxable income as computed by the taxpayer on the last processed return for the year being surveyed.

  11. Tax liability reported, claim allowable, tentative allowance approved: Generally, there will be just one return being surveyed and no administrative adjustments will have been made to the tax liability reported. As needed, the following procedures are applicable:

    1. If more than one return was filed for the same year prior to the due date of the return, the last return constitutes the original return and the tax liability shown on the last return should be entered.

    2. If a claim reducing the tax liability shown on the original return was filed after the due date of the return, the amended return is considered to be a claim and the tax shown on the original return should be entered under "Tax Liability Reported." The difference between the tax liability reported on the original return and the amended return is entered under "Claim Allowable."

    3. If an amended return, increasing the tax liability shown on the original return was filed after the due date of the return, and the additional tax was assessed, then the tax as shown on the amended tax return should be entered under "Tax Liability Reported."

    4. Where tentative carrybacks have been filed Form 1045, Application for Tentative Refund, or Form 1139, Corporation Application for Tentative Refund, and the refunds have been made to the taxpayer, the tax as shown on the return before administrative adjustment is entered under "Tax Liability Reported." The amount refunded as a result of the filing of the tentative carryback is shown under "Tentative Allowance Approved."

    5. Where claims for refund (including amended and informal claims) have been filed, enter the tax liability as reported on the last processed return under "Tax Liability Reported" and enter the amount of the claim under "Claim Allowable."

  12. Explanation: Explain why the return is being surveyed. If necessary, include computations.

  13. Enclosures: List returns, claims, and other documents enclosed in the case file.

  14. Examining Officer/Date: Signature of the surveying examiner and the date the form was completed.

  15. Approved By/Date: The signature and the title of approving management official (usually the examiner’s manager) and the date of concurrence.  (04-02-2010)
Surveying Claims

  1. Claims for refund (including amended returns and informal claims) of income, estate, and gift taxes may be surveyed after assignment if it is determined that the claim issue is clearly allowable in full and the return does not otherwise warrant examination. Claims requiring Appeals consideration can not be surveyed.

  2. Examiners will prepare a survey after assignment report to briefly explain why the claims are being surveyed. A report is not necessary if the reasons for surveying the claim are clearly stated with the claim document.

    1. Form 1900 should be used for income tax claims.

    2. Form 3187, Survey After Assignment, should be used for estate and gift tax claims.

  3. Claims should be stamped with the "survey after assignment" imprint and signed/dated by both the examiner and the group manager.

  4. The examiner must prepare Form 5344, Examination Closing Record, for cases closed survey. See IRM, Surveyed Claims, for instruction on completing the Form 5344.

  5. Any claim which, if allowed, would produce an overassessment/overpayment, requiring reporting to the Joint Committee of Taxation ($2,000,000 refund) may be allowed without examination (surveyed). However, the claim can be surveyed only after notification is received from the Joint Committee that the Service may proceed with disposition of the claim, as proposed in the report submitted to the Joint Committee, under the provisions of IRC 6405(a). See IRM 4.36, Joint Committee Procedures, for instruction on how to survey a Joint Committee case.

  6. For surveyed estate or gift tax claims see IRM 4.25, Estate and Gift.  (04-02-2010)
Surveying Returns Meeting Repetitive Audit Criteria After Initial Contact with the Taxpayer

  1. If, after initial contact with the taxpayer, it is determined that the return meets the repetitive audit criteria, the examination should be closed using the "survey after assignment" procedures. See IRM

  2. The "survey after assignment" stamp should be imprinted on the return and signed by both the examiner and manager as described above.

  3. The examiner will note, directly under the group manager’s signature: "Send Letter 2684 (DO)" (Repetitive Examination Letter.)

  4. Form 1900 will be used to state the reason for concluding the examination.

  5. Letter 2684 (DO) should be prepared by the examiner. The group manager will sign the letter and send it to the taxpayer.  (04-02-2010)
Surveying Returns Transferred From Another Area

  1. If a return is received from another area and the other area only made the initial contact with the taxpayer, without beginning the examination and/or inspecting the taxpayer’s books and records, the receiving area can apply the survey after assignment procedures if the return does not warrant examination. Letter 1024 (DO), Return Accepted as Filed, can be used to notify the taxpayer.  (01-17-2012)
Surveying International Feature Returns

  1. International feature returns that meet the mandatory referral criteria of IRM, Mandatory Referral Criteria, may be surveyed only after the international referral is rejected.

  2. An international referral is made using the Specialist Referral System (SRS) at https://srs.web.irs.gov/  (04-02-2010)
Paperless Survey - Non-Examined Closures Utilizing a Paperless Process

  1. Certain non-examined cases can be closed virtually paperless if the original return was never requested. Only a Form 5351, Examination Non-Examined Closings, and a Form 3210, Document Transmittal, are needed for a paperless survey. Generally, this process is used when the return was established on AIMS using an electronic print and the original return was never requested. See IRM (2) above for the definition of an electronic print.

  2. If the return was requested when you established the case on ERCS/AIMS (ALL DIF and Automatic Openings request the return) the case CANNOT be closed as paperless. Before requesting a paperless closure, pull an AMDISA and if the words "RETURN REQUESTED" appear on page 2 - line 8 then a paperless closure CANNOT be requested.

  3. An electronic print can be surveyed using the paperless process if there is no requirement to attach any documentation to the survey. Cases requiring the use of a Form 1900 can not be closed using the paperless process. See IRM for an example of cases that require a Form 1900 to survey.

  4. Only survey cases closed at the group level with disposal code 31 or 32 can use the paperless survey process.

  5. Only a Form 5351, Examination Non Examined Closings, and a Form 3210, Document Transmittal, are needed for a paperless survey. These should be faxed to Centralized Case Processing.

  6. Complete Form 3210.

  7. Complete Form 5351 as follows:

    1. Use only one MFT per Form 5351.

    2. The manager should sign their name in the "Approved By" box at the top of Form 5351 and enter the current date.

    3. Enter the taxpayer’s name, TIN, MFT, and tax year. If a label is available affix the label.

    4. Enter the disposal code in the lower left corner of the block. If a label is available, list the disposal code on the label below "STATUS "


      For additional guidance, refer to IRM, Form 5351, for line by line instructions for completion of Form 5351.

  8. Do not send electronic prints, asset locator research, or charge-out documents to CCP. These documents should be shredded. If you have information that must be retained, you can not use the paperless survey closure.

  9. For additional information on paperless closures visit the AIMS web site.

  10. If you can not use the paperless survey closure, see procedures for "Survey Before Assignment" and "Survey After Assignment" at IRM and IRM respectively.  (04-02-2010)
Pre-Contact Planning of Examination Activities

  1. If the in-depth analysis and evaluation of audit potential indicate that a return should be examined, then examiners should begin planning the examination.

  2. Field cases: The planning process begins with the accomplishment of the steps and audit techniques listed on the mandatory lead sheets that are applicable at this stage of the examination.

  3. Office examination cases: The planning process consists of the following:

    1. Review the tax return and classification sheet to ensure that the most egregious issues are correctly classified;

    2. Prepare and review the case building materials;

    3. Assess the risk of potential issues and revise the scope as warranted;

    4. Office examiners should verify tax return information on RGS, Report Generating System;

    5. If the case is not on the LAN, Local Area Network, the examiners should input and verify tax return information into RGS, enter all issues (classified and new issues added during pre-audit),

    6. Ensure RGS information matches IDRS, Integrated Data Retrieval System,

    7. Prepare case file documentation lead sheets,

    8. Develop a forecast.


      A forecast is the amount of time the examiner should estimate for the initial interview with the taxpayer and the time to close the case. The forecast time should be recorded on Form 9984.

    9. Develop a focused Form 4564, Information Document Request, (IDR).

    10. Prepare an appointment letter. See IRM regarding appointment letters to use.


    Managerial approval is required prior to exceeding preplan time of 1 hour on non-business and 1 and 1/2 hours on business returns.

  4. Examiners are expected to examine all large, unusual and questionable items (LUQ). However, it is not intended that examiners should consider every possible issue. For instance, it is not proper for examiners to make a detailed analysis of a specific account unless the potential adjustment will materially affect the tax liability or will be important from a compliance viewpoint.

  5. Examiners are expected to adequately explain the items which are examined and the large, unusual, and questionable items which are accepted without examination. The case file and workpapers will clearly indicate the scope of every examination, the depth of the examination, and the reasons for the decisions.

  6. The examiner is expected to complete their workpapers contemporaneously. The examiner should prepare to the extent possible, the mandatory lead sheets and issue specific lead sheets as they progress through the examination.

    1. The examiner should add comments where the lead sheets indicate that comments are required or where in the examiner’s professional judgment, comments are needed for clarification.

    2. Similarly, the examiner should reference supporting workpapers where the lead sheets indicate that workpapers are required or where in the examiner’s professional judgment supporting workpapers are needed.

  7. Check boxes are found on many of the mandatory lead sheets used in the examination process. They serve many purposes such as a reminder or an action(s) completion list. Checking a box does not necessarily mean comments and workpapers are not required; it depends on the audit procedure and/or examination technique.


    Documenting RRA Separate Notice Requirements - If the taxpayer was married, you would be required to send the initial appointment letter to both the husband and wife. In this case, the Yes box would be checked and a copy of the letter included in the case file. No further comment is necessary.


    Documenting Assessment of Collectibility - Is collectibility an issue? If the answer is yes, then you should include a workpaper with information that supports your conclusion.

    In all cases, professional judgment must be used, the examiner must ensure that the applicable tasks have been performed before checking the box(es).

  8. As the audit progresses the actions and audit steps may change. The examiner is responsible for ensuring that the correct audit response is checked and comments/explanations made as applicable.  (04-02-2010)
Determining the Scope of an Examination

  1. Determining the scope of an examination is the process by which an examiner selects issues warranting examination. Examiners should select issues so that, with reasonable certainty, all items necessary for a substantially proper determination of the tax liability have been considered.

  2. Examiners must assess the facts and apply judgment in determining the scope of the examination.

    1. Office examination: The scope of the examination of a return is prescribed on a classification check sheet during the classification process. However, the scope of an examination should not be limited to the classified issues if other significant issues are revealed during the examination. Whenever possible, tax examiners should consult with their manager before raising new issues.

    2. Field examination: The scope of the examination will be determined by the examiner.

  3. Examiners are expected to continually exercise judgment throughout the examination process to expand or contract the scope as needed.

  4. If during the course of the examination, the scope of the examination is expanded to include another tax period(s), the taxpayer should be notified in writing of the expansion. If the taxpayer has a power of attorney and it does not cover the tax period(s) being picked up for examination, the taxpayer must be given time to secure a power-of-attorney for the additional tax period(s). Also, the examiner must allow the taxpayer time to submit records on the newly added year. Examiners should use the appropriate appointment confirmation letter. See IRM for field letters and IRM for office letters.  (04-02-2010)
Limiting the Scope of an Examination

  1. The scope of an examination may be limited under conditions, as described in this subsection. Any limitations placed upon the scope of the examination should be documented in the case workpapers.

  2. The scope of an examination of a return may be limited to one or two issues if no other items appear worthy of examination. For example, it may be necessary to examine a claim because the issue is highly technical and requires factual development. If there are no other issues meriting development, then the exam should be limited to the claim issue.

  3. If a taxpayer is contacted with regard to an information document program (IRP) item, the scope of the examination is generally limited to resolving differences between items reported by the taxpayer and items reported on the information returns. Emphasis should be placed on determining why the income was omitted and whether the omission occurred in more than one year. When it appears that a material amount of income may not have been reported, and there has not been a prior audit, an examination should be initiated.

  4. If a return is selected due to an issue arising from an agency-investor relationship, or identified as an Information Returns Program (IRP), and no other issues on the return appear worthy of examination, the scope of the examination may be limited to the identified issues.

  5. When a Schedule K–1 is inspected to determine that the flow through items have been reported correctly, the taxpayer and/or representative should be advised that the inspection does not constitute an examination and the taxpayer’s distributions from the related entity may be adjusted later if the related entity is examined.

  6. Generally, short-term timing issues should not be examined. Timing issues with long term, indefinite or permanent deferral features should be examined. Unplanned timing issues which arise as correlative adjustments during an examination of non-timing issues should be made if it is cost effective to do so.

  7. The scope of the examination may be limited due to collectibility. A collectibility determination should be made when the taxpayer has no ability to pay or expectation of a future ability to pay. See IRM 4.20.1, General Collectibility Procedures.

  8. See IRM through IRM for a discussion of scope limitation and examiner documentation requirements.  (04-02-2010)
Expanding the Scope of an Examination

  1. Expanding the scope of the examination is based on the examiner’s judgment. If, while completing the required filing checks, an examiner discovers that a taxpayer has not complied with a filing requirement or that an audit potential exists, they should expand the examination scope if warranted. See IRM 4.10.5, Required Filing Checks, for guidance.

  2. Office examination: If it appears that a related entity warrants examination and the examiner feels they can not conduct the examination, the examiner should discuss the possible reassignment of the case with their group manager. The examiner should secure a copy of the related entity return and prepare the case file for transfer. If the group manager agrees that the case warrants transfer to another examiner, the manager should:

    1. Reassign the case to a more experienced examiner in office examination.

    2. If the related case is outside the examination scope of office examination, the manager should contact a field examination group manager to assess the case’s audit potential.

    If the group manager determines the case does not warrant examination, this decision should be documented in the case file by either the examiner or the manager.

  3. Field examination: If a related partnership return should be examined and:

    Partners are individuals within the area. Proceed with the examination.
    Partners are individuals, not within the area. Prepare Form 5346, Examination Information Report, and forward to the PSP Support Manager.
    Partners are non-individuals not within the area. Prepare Form 5346 and forward to the PSP Support Manager.
    Partners are non-individuals located within the area. May obtain group manager’s approval to examine.

  4. Examiners should refer to IRM 4.31.2, TEFRA Examinations / Field Office Procedures, and IRM 4.31.5, Non-TEFRA Examinations - Field Office Procedures, for more detail information on flow-through entities.  (04-02-2010)
Inventory Checks

  1. If inventory is classified as an issue, examiners will verify that inventories are reported correctly. The techniques outlined below are suggested as minimum checks. It is not necessary that all the techniques be used; only that they be used to the extent needed to determine that inventories are correctly reported.

    1. Verify that the taxpayer’s method of inventory valuation conforms to the "prescribed methods" as indicated in Treas. Reg. 1.471-11, Inventories of Manufacturers. Check for unauthorized changes in the method used to account for inventory.

    2. Compare inventory balances on the return under examination, with the balances on the prior and subsequent years’ returns, and verify these with the taxpayer’s records.

    3. Check the gross profit percentages for variations. Determine that all direct, indirect, and overhead burdens are properly accounted for, that year-end purchases were included in closing inventory, and that any write-downs for "excess" inventory were properly accounted for. See Rev. Rul. 80–60, Accounting Methods; Change; Inventory Write-Down and IRM 4.11.6, Changes in Accounting Methods, for additional guidance.

    4. Analyze unusual entries to cost of sales for labor, materials and burden costs, not directly related to sales or transfers of finished goods.

    5. Determine the significance of any qualifying statements on financial reports prepared by independent accounting firms.

    6. Determine that inventory costing conforms to Treas. Reg. 1.471–11 for taxpayers engaged in manufacturing or production activities.

  2. A more in-depth examination of inventory should be made if the results of the minimum checks warrant further consideration of the issue.

  3. In every case involving inventory as a classified issue, examiners will document the steps taken to verify that inventories are correctly reported. If inventories are not examined but classified, the examiners will note why inventories were not worthy of examination.


    Inventory is no longer a mandatory issue.

  4. If, with group manager approval, the minimum checks to verify that inventories are correctly reported are not completed as required above, then the workpaper documentation outlined in (3) above will not be required and the group manager’s involvement in the case will be noted in the case file.  (04-02-2010)
Depth of an Examination

  1. Depth is the extent to which an issue is developed. It demonstrates the degree of intensity and thoroughness applied in order to make a determination as to the correctness of an item.

  2. Examiners must exercise judgment in determining the depth required for the examination. Determining the depth of the examination for different issues will help to estimate the time needed to complete the examination. The following factors should be considered:

    1. Type of evidence available or expected for the issue,

    2. Complexity of the issue,

    3. Materiality of issue, and

    4. Internal Controls.  (04-02-2010)
Preliminary Research

  1. Preliminary research of the applicable IRC sections, treasury regulations, rulings, and court cases, concerning the proper tax treatment of a particular issue, should be performed on the issues identified in the pre-contact analysis. This will assist in the development of specific interview questions, determine possible audit procedures, and help determine what information should be included on the information document request. It is critical that examiners become familiar with the issues on the return. Extensive research, however, should not be conducted until the facts of the issues are established. See IRM 4.10.7, Issue Resolution.

  2. Review prior revenue agent’s report(s) to determine the issues previously proposed and any problems encountered during the examination. Ask for the taxpayer’s copy of the report or order the administrative file from the Campus.  (04-02-2010)
Referrals for Specialists

  1. Specialists are available to provide assistance with developing and resolving significant complex tax issues. During the pre-planning phase, examiners should determine if their case requires a referral for specialist assistance.

  2. Mandatory referrals should be made as soon as possible; but, no later than 30 days of the initial appointment. For field examination cases the referral must be made no later than 30 days of the initial appointment or the group manager's concurrence meeting whichever occurs first.

  3. Non-mandatory referrals should be requested as early in the examination as the need is identified.  (04-02-2010)
Referral Criteria

  1. Generally, referrals must be considered for all entities with gross assets exceeding $10 million and for cases with a single object of art and/or cultural property valued at $20,000 or more.

    1. Visit https://srs.web.irs.gov/ for the mandatory referral criteria for specialist referrals through the specialist referral system (SRS).

    2. See IRM, Art Appraisals, below for detailed information on mandatory referrals to the Art Advisory Service.

  2. Time required to work the issue by the specialist (including travel time) is included in the case. It is important to determine the projected tax from the specialist issue versus the time required to develop the issue. Cases which would result in minimal change to the taxpayer’s tax liability should not be referred.

  3. Once it is determined that a referral is warranted, or is mandatory, the referral must be made early in the examination to ensure the specialist is assigned to complete the work timely.

  4. Questions regarding referrals should be directed to the specialized program group manager through either the group manager or the area program coordinator.

  5. Informal advice may be solicited on issues that do not appear to warrant a referral, but some assistance is required. For those specialist groups available through SRS, informal questions should be submitted using this system.  (08-01-2007)
Referral Forms

  1. Request for specialist assistance must be made through the SRS. This includes questions and informal requests for assistance. Exception to this rule is for those specialist groups that can not be accessed through this system. See Manual Referrals below.  (01-17-2012)
Specialist Referral System (SRS) - Online Referrals

  1. The SRS is an online automated system that allows for all submissions and approvals for specialist assistance. It automates the referral request process for LMSB, SBSE, W & I and TEGE field specialists. It is accessed from the Intranet at https://srs.web.irs.gov/

  2. The SRS must be used for referrals (includes questions and informal requests for assistance) to the following specialist groups:

    1. Computer Audit Specialists (CAS) - see IRM 4.47, Computer Audit Specialists;

    2. Economists - see IRM 4.49, Overview - Economist Program;

    3. Employee Plan Specialists - see IRM 4.71, Employee Plans Examination of Returns, handbooks for additional information;

    4. Employment Tax Specialists (LMSB, SBSE, and TEGE) - see IRM 4.23, Employment Tax, handbooks for additional information;

    5. Engineers - see IRM 4.48, Engineering Program Handbooks, for additional information;

    6. Excise Tax Specialists - see IRM 4.24, Excise Tax, handbooks for additional information;

    7. Exempt Organizations Specialists;

    8. Federal, State, and Local Government;

    9. Financial Products and Transactions Specialists - see IRM 4.37.1, Financial Products and Transactions Program, handbooks for additional information;

    10. Indian Tribal Government;

    11. International Examiners - see IRM, International Referral Criteria and Procedures;

    12. Joint Committee- see IRM 4.36.4, Joint Committee Specialist Procedures;

    13. LMSB Actuary; or

    14. Tax Exempt Bonds Specialists.

  3. When examiners submit an online request, SRS automatically notifies the appropriate Specialist Manager of the request. The system is totally electronic and web-enabled, providing management necessary information reports.

  4. Examiners will use a manual request only when the specialist groups can not be accessed through SRS (i.e. art appraisal, Counsel assistance, etc.)

  5. The SRS maintains an archive of all referrals.  (04-02-2010)
Manual Referrals

  1. Manual referrals will be prepared to request specialist services or other support not available using the SRS. For example, art appraisers, Counsel assistance, Entities, etc.

  2. Case referrals to TEGE are made using Form 4632-A, Employee Plans Referral Checksheet. If an examiner needs assistance form TEGE, the examiner should submit a request for specialist assistance through theSRS). A copy of the Form 5500 series return, and a copy of the latest IRS determination letter, plan document and adoption agreement (if applicable) should accompany the case referral.

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