4.13.7 Exhibits22.214.171.124 ExhibitsExhibit 4.13.7-1 ASFR - Reconsideration Returns - Centralized Processing SitesExhibit 4.13.7-2 Routing of Campus Reconsideration RequestsExhibit 4.13.7-3 Routing of Area Office Reconsideration Requests (as of 10/01/2013) Exhibit 4.13.7-4 Central Reconsideration Unit (CRU) AddressesExhibit 4.13.7-5 Appeals Account Resolution SpecialistExhibit 4.13.7-6 Addresses for AUR Reconsideration RequestsExhibit 4.13.7-7 Form 12249 Adjustment DocumentExhibit 4.13.7-8 Completing Form 12249 (Adjustment Tag)Exhibit 4.13.7-9 ADJ54 FormatExhibit 4.13.7-10 Adjustment Items Job AidExhibit 4.13.7-11 Form 8758 Excess Collections & InstructionsExhibit 4.13.7-12 Audit Reconsideration First Read ChecksheetExhibit 4.13.7-13 Audit Reconsideration of Assessments Made by Appeals Processing Unit Part 4. Examining ProcessChapter 13. Audit ReconsiderationSection 7. Exhibits 4.13.7 Exhibits Manual Transmittal December 17, 2015 Purpose (1) This transmits revised IRM 4.13.7, Audit Reconsideration, Exhibits. Material Changes (1) Exhibit 4.13.7-2 - Minor grammatical change. (2) Exhibit 4.13.7-10 - Deleted Filing Status & Dependency Deductions chart, ENREQ chart, and added transaction codes. (3) Exhibit 4.13.7-14 through Exhibit 4.13.7-26 - Deleted Exhibits. (4) IPU 14U1295 issued 08-28-2014 Exhibit 4.13.7-2 - Corrected third paragraph concerning Area Office reconsideration routing. (5) IPU 14U1295 issued 08-28-2014 Exhibit 4.13.7-3 - Deleted state alignment chart to campus. Routing based on TC 420 PBC and servicing campus. (6) IPU 13U1711 issued 12-06-2013 Exhibit 4.13.7-1 - Removed contact information and added link to the information. (7) IPU 13U1711 issued 12-06-2013 Exhibit 4.13.7-3 - Removed rows from the Realigned Area Table and made changes to State Alignment table. (8) IPU 13U1711 issued 12-06-2013 Exhibit 4.13.7-4 - Removed contact information and added link to the information. (9) IPU 13U0724 issued 04-11-2013 Exhibit 4.13.7-4 - Change in Austin's fax number. (10) IPU 13U0568 issued 03-20-2013 Exhibit 4.13.7-6 - Clarified note and removed hard coded addresses. (11) IPU 13U0399 issued 02-22-2013 Exhibit 4.13.7-4 - Edits to correct Fresno's fax number. (12) Exhibit 4.13.7-4 - Edits to correct Andover stop number. (13) IPU 12U1606 issued 09-21-2012 Exhibit 4.13.7-4 - Edits to SBSE telephone and fax contact information. (14) IPU 12U0573 issued 03-09-2012 Exhibit 4.13.7-4 - W&I contacts mistakenly removed in IPU 12U0573, which was correcting the SBSE contact info. This update is putting the W&I contacts back in the exhibit. (15) IPU 12U0573 issued 03-07-2012 Exhibit 4.13.7-4 - Updated contacts. (16) IPU 11U1909 issued 12-07-2011 Exhibit 4.13.7-1, address change for International Returns with Form 2555 Effect on Other DocumentsThis material supersedes IRM 4.13.7 dated 12/31/2009. AudienceSmall Business/Self Employed and Wage and Investment Campus Compliance, Customer Account Services Employees, Appeals, TAS Effective Date(12-17-2015)Scott E IrickDirector, Examination/AUR PolicySmall Business/Self-Employed 126.96.36.199 (09-01-2006) Exhibits This chapter contains all of the exhibits for the Audit Reconsideration Handbook. Exhibit 4.13.7-1 ASFR - Reconsideration Returns - Centralized Processing Sites Addresses for Automated Substitute for Return (ASFR) Reconsideration Returns (Tax return filed after ASFR has made an assessment transaction code (TC) 290 with a TC 150 for $0.00) are available at Who/Where - ASFR - Reconsideration Returns - Centralized Processing Sites Exhibit 4.13.7-2 Routing of Campus Reconsideration Requests Use this exhibit to identify the Primary Business Code (PBC), Filing Location Code (FLC) and the Employee Group Code (EGC) on an Integrated Data Retrieval System (IDRS) TXMODA screen. If the receiving campus does not work the exam program, assessments originating in the campuses will be sent back to that campus. Refer to the Filing Location Code (FLC) and Employee Group Code (EGC) to determine the campus where the assessment originated. Assessments made by an area office are sent to the servicing SB/SE campus based on the alignment to AIMS Principal Business Code (PBC) in the TC 420. For more information refer to IRM 188.8.131.52 Function Responsible & Routing Instructions. In addition to the location of the PBC, FLC, and EGC locations, this exhibit outlines which campuses are the W&I campuses with their Area Office and the SBSE campuses with their Area Offices.The W&I campus PBC's are: 190 - Andover Area Office 1XX191 - Atlanta Area Office 1XX192 - Austin Area Office 1XX193 - Fresno Area Office 1XX194 - Kansas City Area Office 1XXThe SBSE campus PBC's are: 295 - Brookhaven Area Office 2XX296 - Cincinnati Area Office 2XX297 - Memphis Area Office 2XX298 - Ogden Area Office 2XX299 - Philadelphia Area Office 2XXThe W&I Campuses Campus File Location Codes are: 08 - Andover07 - Atlanta18 - Austin09 - Kansas89- FresnoThe SBSE Campuses Campus File Location Codes are: 19 - Brookhaven17 - Cincinnati49 - Memphis29 - Ogden28 - Philadelphia Please click here for the text description of the image. Exhibit 4.13.7-3 Routing of Area Office Reconsideration Requests (as of 10/01/2013) North Atlantic Central South Atlantic Midwest Gulf States Area PBC 201 202 203 204 205 Servicing Campus BSC CSC PSC CSC MSC Western California Employment E & G Excise Area PBC 206 207 212 213 214 Servicing Campus OSC OSC CSC CSC CSC International Area PBC 215 Servicing Campus PSC Note: Only cases that were previous NRP cases that have a source code 80 or 91 should be routed to the NRP Coordinators. All others should be routed to the Audit Recon/Claims Coordinators. The Audit Recon/Claims Coordinators can be found at: Area Office/Campus Contacts. The NRP coordinators can be found at: NRP Area Coordinators - Exam. Exhibit 4.13.7-4 Central Reconsideration Unit (CRU) Addresses Central Reconsideration Unit (CRU) Addresses, Telephone and Fax Numbers are now listed at: Who/Where - Audit Reconsideration Requests - Central Reconsideration Unit (CRU) Addresses. Exhibit 4.13.7-5 Appeals Account Resolution Specialist Contact the Appeals Account Resolution Specialist in Fresno at (559) 233-1267 to find out who worked the case in Appeals. Exhibit 4.13.7-6 Addresses for AUR Reconsideration Requests The originating campus may be determined from the address in the upper left corner of the CP2000 (if available) or from the first two digits of the TC922 DLN. If the first two digits of the TC 922 DLN are 07, 08, 18 or 89 it is a W&I taxpayer. If the first two digits of the TC 922 DLN are 19, 28 or 29 it is a SB/SE taxpayer. Send the request to the Campus where the assessment originated. A listing of contact telephone numbers is available on SERP http://serp.enterprise.irs.gov/databases/who-where.dr/aur-recon.htm Note: Phone numbers on SERP are for internal contacts relating to AUR Reconsideration cases only. Route taxpayer phone calls to AUR toll free numbers. The W&I toll free number is 1–800–829–3009 for TC 922 DLN beginning with 07, 08, 18 or 89. The SB/SE toll free number is 1–800–829–8310 for TC 922 DLN beginning with 19, 28 or 29. Exhibit 4.13.7-7 Form 12249 Adjustment Document This Form 12249 is prepared using the fields indicated, and outlined in Exhibit 4.13.7-8. Each box that requires action is outlined in the list and definitions in exhibit 4.13.8. Please click here for the text description of the image. Exhibit 4.13.7-8 Completing Form 12249 (Adjustment Tag) Check "IDRS Adjustment" box. Employee Number - IDRS # of person inputting the adjustment. Input Date - Date of actual input. TIN- Taxpayer’s SSN. MFT - 30 TX-PRD - Tax Year NM-CNTRL - Name Control. SEQ-NUM - 3 digit number. (i.e. 101, 102, etc. on Monday and 201, 202, etc. on Tuesday and so on). You cannot use the same number twice the same day. BLK - Blocking Series - 00 – with original return 05 – Adjustment made without original return 18 – Adjustment made without original return (informs Files to pull original return to the adjustment). 98 – Complete claim disallowance without original return (Certified Disallowance 105C Letter being sent) 99 - Complete claim disallowance with original return (Certified Disallowance 105C Letter being sent) CORRESP-DT - Correspondence Date (MMDDYYYY). This date will print on a notice when it is generated resulting from a taxpayer's correspondence CASE STS-CD - C (for closed). IRS-RCVD-DT - received date. CRTL-CAT - RECN for audit recon. ACTIVITY - Issues of case (FS4/EIC, or EXEMPT/EIC, or FS2/EIC as Examples). 10 characters maximum. TC –Transaction Code - 290/291 (change to tax) or 290 for zero (No tax change) 15a. AMT- Input appropriate amount. Must be input in dollars and cents format with commas and decimal points. TC– Transaction Code - 160/161, or 170/171 to address penalty if on account. TC 160 .00 or 170 .00 if not changing penalty. SRCE-CD Source Code- chooses the statement which will appear on the taxpayer’s adjustment notice with the literal reason code (RC) completing the statement. RSN-CDS - Reason Codes: Maximum allowed is 3. Use reason code to designate item being adjusted and the audit recon reason code. Will determine the explanation that will print on the adjustment notice to the taxpayer. HOLD-CD - Hold Codes- Hold codes are entered to restrict offsetting, refunding and/or issuance of adjustment notices. Note: See Section 8C of Document 6209 for a list of hold codes. PRT-CD - Priority Code - Priority Codes are input to bypass certain unpostable checks. Failure to use the PC, when needed, will cause the transaction to unpost. When adjusting credits and there is a prior TC 30X/29X on the account, a PC 8 is needed. AMD-CLMS-DT - Amended claims date is used when an Overpayment results from a claim or amended return and the refund is not issued within 45 days of the received date. Credit interest is allowed from the received date to the refund date. Master file will use this date to apply the 45-day rule. This date should be used when the taxpayer initiates the adjustments resulting in a refund. Priority code 3 is used when IRS initiates the adjustment. Use the IRS received date. CD - Credit Reference codes. Maximum of 8. 22a. If the credit reference or item reference amount is being decreased enter a minus. Do not reduce Taxable Income below 0. REMARKS – Y- SD if adjustment goes to files, NSD if it is not going to files. REMARKS - generally should match the Activity code Leave notes for other transactions needed (ENMOD changes, add telephone #s, remove STAUP/TC 470) to instruct for the person inputting the adjustment. RFSCDT – (MMDDYYYY) Refund Statute Control Date is used when the RSED (Refund statute expiration date) has expired (return due date plus 3 years). Override indicator code "S" must be present on applicable tax decrease. Override Code – An "R" is necessary if the rec’d date of the correspondence is more than 1 year old. Use "S" if the current date is later than the RSED and the RFSCDT field is used. Exhibit 4.13.7-9 ADJ54 Format This screen print of an ADJ54 screen identifies the fields that are optional or that need to be entered. Exhibit 4.13.10 provides the valid entries for each field. Required field – Adjustment Sequence Number – Identifies the sequence of work performed. Values are 1 through 999.Required field – Blocking Series – Identifies the nature of the adjustment.Elective – Correspondence Date – Identifies the date of the taxpayer’s correspondence.Required field – Transaction Code – Identifies actions being taken on a taxpayer’s account.Required field – Transaction amount – Identifies the amount associated with the TC. A minus (-) following the amount identifies a decrease or credit amount.Required field – Source Code – Identifies the source of information used for the adjustment. Required field – Reason Code – Identifies the reason for adjusting/changing the taxpayer’s account.Required field– Hold Code – Identifies whether to restrict offsetting, refunding, or issuance of adjustment notice.Elective - Priority Code are input to bypass certain unpostable checks. Elective – Posting Delay Code – Identifies the number of cycles the posting action is being deferred. Values are 1 through 6.Required field – Item Reference number/Credit Reference Number – Identifies the specific item being adjusted.Required field – Amount – Identifies the amount associated with the item/credit reference # code. A minus (-) sign identifies a decrease or credit.Required field – Source Document Attached – Identifies if back-up material supporting the adjustment is attached, Values are: - Y – Source document attached - N – No source document attached- R – Source document retainedRequired field – Remarks – Provides a brief explanation of the adjustment. Must contain at least three characters Please click here for the text description of the image. Exhibit 4.13.7-10 Adjustment Items Job Aid This is not all inclusive. See Document 6209 for additional information. Reason Codes Transaction Codes 01 Filing Status to Single 150 Tax on original return 02 Filing Status to MFJ 166 Computer generated Delinquency Penalty 03 Filing Status to MFS 176 Computer generated Estimated Tax penalty 04 Filing Status to HOH 196 Computer generated interest 05 Filing Status to Qualifying widower with child 290 Increase in tax manually 06 Exemptions 291 Decrease in tax manually 30 Adjustments to Income 300 Increase in tax after Examination 32 Adjusted Gross Income 301 Decrease in tax after Examination 75 Taxable Income 336 Interest assessed on additional tax 92 Standard Deductions 340 Manual computation of interest 44 SE Tax 341 Manual abatement or reduction of interest 49 Advanced EIC 342 Reverses restriction of interest 36 Tax Credits 420 Examination opened 51 Federal Income Tax Withholding 421 Examination closed 53 EIC 424 Examination requested 54 EIC Disallowance 706 Credit applied from another year 55 Excess SS tax and RR tax Withheld 826 Credit applied to another tax year 64 Audit Recon-No Response 66 Audit recon-Fully Disallowed 67 Audit Recon- Partially Disallowed 68 Audit Recon- Fully Allowed Reference Codes336 Additional Child Tax Credit680 Accuracy related. Becomes TC 240764 Earned Income Credit765 Earned Income Credit (decrease)766 Substantiated Credit (increase)767 Substantiated Credit (decrease)768 EIC allowed by computer (original processing)806 W-2 Withholding (Credit)807 W-2 Withholding (debit)878 Adjusts Primary Self-Employment Income879 Adjusts Secondary Self-Employment Income881 Total Positive Income885 Advance EIC886 Taxable Income (– sign decreases income)887 Number of Exemptions example: .01 to increase .01- to888 Adjusted Gross Income Adjustment889 Self-Employment Tax Adjustment895 Primary Medicare Income896 Secondary Medicare Income Blocking Series00 With Original Return05 Full Allowance18 Refile DLN without Original Return (Use when associating the document with the original return is important.)98 Complete claim disallowance 105C without Original Return99 Complete claim disallowance 105C with Original Return HOLD CODES HC 1 Stops refund, mails adj. notice. HC 2 Holds notice and credit. HC 3 Stops adj. notice, allows refund. HC 4 Stops notice forever stops refund. HC 0 Use when not using any other HC. Allows notices and refunds to be sent. IDRS STATUS - CC STAUP 19/21 Initial Notice 20 501 Notice 56 503 Notice 58 504 Notice 22/24/26 TDA Status Priority CodesPC 1 Used with an L freeze when both PC1 and PC8 are needed.PC 3 Use when considering the 45- day interest-free period.PC 5 Use with TC 290.00 to force post accruals of unrestricted interest and/or FTP penaltyPC 8 Use when inputting an adjustment within $10.00 of a prior adjustment, when EIC is increased or when adjusting W/H and TC 17X is posted. Exhibit 4.13.7-11 Form 8758 Excess Collections & Instructions Item #NameRequired or OptionalDescription1Document Locator Number (DLN)Requireda. This 14–digit entry is the original DLN of the credit on the account from which its transfer to Excess Collection File (XSF) is requested and will usually become the XSF control number. b. If the original DLN is not used as the XSF control number, it should be the first entry on Line 9 (CREDIT INFORMATION) of the CC XSADD format adding the credit to the XSF.2Renumbered DLNOptionalIf completed, this 14–digit optional entry is the XSF control number. a. If several credits having the same DLN are transferred to the XSF from one taxpayer account (e.g., TC 640 and TC 680), use the DLN with the tax or real credit. After verifying that it’s not a true duplicate, assign the DLN, changing the first digit of the blocking series to the next higher number, to the addition to the tax or generated credit (e.g., TC 680). Change the first digit of the blocking series on credits from a reactivated retention register account. b. If the credit is an FTD/EFTPS payment, insert the last five digits of the TUS number or EFT Trace number into digits 9 through 13 of the original DLN which may be shared with a number of FTD/EFTPS payments. This will create a unique control number which reflects the credit’s origin. c. If the credit has no prior DLN, refer to Figure 3.17.220-4 as a guide to form a DLN, restricting the block number to 800 and above. d. Cases received with out of campus DLNs should not be transferred to the campus that received the payment. Add the credit to the XSF using the dump area office code.3Source CodeRequiredIf completed, this 14–digit optional entry is the XSF control number. a. If several credits having the same DLN are transferred to the XSF from one taxpayer account (e.g., TC 640 and TC 680), use the DLN with the tax or real credit. After verifying that it’s not a true duplicate, assign the DLN, changing the first digit of the blocking series to the next higher number, to the addition to the tax or generated credit (e.g., TC 680). Change the first digit of the blocking series on credits from a reactivated retention register account. b. If the credit is an FTD/EFTPS payment, insert the last five digits of the TUS number or EFT Trace number into digits 9 through 13 of the original DLN which may be shared with a number of FTD/EFTPS payments. This will create a unique control number which reflects the credit’s origin. c. If the credit has no prior DLN, refer to Figure 3.17.220-4 as a guide to form a DLN, restricting the block number to 800 and above. d. Cases received with out of campus DLNs should not be transferred to the campus that received the payment. Add the credit to the XSF using the dump area office code.4Status CodeRequiredThis 4–character entry will be either FROZ, OPEN or IDEN. OPEN will be assumed if no entry is made. This data element may be changed during analysis by the XSF technician as described in IRM 184.108.40.206.2. a. If FROZ (frozen) is used, Source Code must be ST and documentation explaining status must be in the file. b. If IDEN (identified) is used, attached documentation of History section must explain why this credit cannot be applied to the correct account. c. This data element may be changed during analysis by the XSF technician explained in IRM 220.127.116.11.2.5EmployeeOptionalThis 10–digit entry is added by the XSF function if the case is to be assigned to an employee other than the person entering the credit to the file using CC XSADD.6Debit Transaction CodeRequiredThis 3–digit entry is to be selected from Exhibit 3.17.220-6 as the debit valid with document codes 24, 48 or 58 which best reverses the credit to be added to the XSF. Be certain that the selected primary transaction code is compatible with the credit’s MFT and doc code.7Dollar Amount of CreditRequiredThis is the amount of credit to be added to the XSF. The amount is to represent a single credit on the account from which it is moved.8TC 570 IndicatorOptionalCheck the box to input TC 570 as a secondary transaction to the master file. When it is necessary to debit any credits in a multiple-credit transfer from a single master file account module to the XSF, this box must be checked. 9Payment TypeRequiredThis two-character entry designates the type of remittance received. a. BC—Business Check b. CA—Cash (including cash conversions) c. CC—Cashier’s Check d. FD—Federal Tax Deposit (including Certificates of Deposit) e. GC—Government Check f. MO—Money Order g. PC—Personal Check h. UK—Unknown i. WH—Withholding10IRS Received DateRequiredThis is the eight-digit entry in month, day, year format (MMDDYYYY, e.g., January 5, 2003, is 01052003). This entry should reflect the Return Due Date (RDD) for Transaction Code 806 (prepaid withholding and excess FICA payments). For carryback credits, use the availability date of the credit. Use the actual IRS received date, i.e., the earliest date recorded by any IRS office, for all other credits. a. Do not add credits less than one year old (computed from the IRS-received date) other than Doc Code 48, 58 or 65 to the XSF. For accounting purposes, they must be added to the Unidentified Remittance File. b. True Statute cases—CC XSADD will accept credits with received dates less than one year old when source code ST and status code FROZ are used. The statute of limitations for assessments may have expired either before the taxpayer filed an amended return or made the payment or after the amended return was filed or the Examination determination was made and, due to employee error, the assessment was not made.11Actual IRS Received DateOptionalNo entry is required.12Name line 1RequiredEntry limited to 35 characters.13Name line 2OptionalEntry limited to 35 characters.14Street AddressOptionalEntry limited to 35 characters.15City, State, ZIP codeOptionalEntry limited to 29 characters.16Reason for Transfer to XSF (History)OptionalEntry limited to 70 characters.17Taxpayer Identification NumberRequiredEntry limited to 35 characters.18EFTPS IndicatorRequiredCheck the box if this is an EFT payment.19MFT CodeRequiredEntry limited to 2 characters.20Tax PeriodRequiredSix-digit entry in year and month format. (YYMM: e.g., January 2003 is 200301).21Preparer NameRequiredName of preparer of Form 8758. (Please print)22Preparer's Employer NumberRequiredEmployee number of preparer of Form 8758.23CampusRequiredIRS Campus of preparer of Form 8758.24Team NameRequiredFunctional area of preparer of Form 8758.25Team Fax NumberRequiredFax number of the functional area of the preparer of Form 8758.26Stop NumberRequiredEmployee IRS Stop number of preparer of Form 8758.27Phone NumberRequiredEmployee telephone number of preparer of Form 8758.28DateRequiredThe date that the Form 8758 is prepared.29Research Prior to TransferRequiredThis entry should reflect research performed in the originating function. a. Copies of pertinent documents such as transcripts and taxpayer correspondence should be attached to the completed Form 8758. b. The originator of Form 8758 should include the IRM reference authorizing amounts that are below tolerance to be added to the XSF.30Research by Excess Collections PersonnelRequiredBe as specific as possible so that your manager or subsequent technician can easily determine the actions you take. Please click here for the text description of the image. Exhibit 4.13.7-12 Audit Reconsideration First Read Checksheet This sheet should be prepared for each Audit Reconsideration received and worked by the first read examiner. The top third of this form identifies specific information about the reconsideration. The bottom two thirds provide check boxes that instructions for the clerical/processing unit. The bullet list identifies the first third of the form. Taxpayer NameTaxpayer AddressSSNMFT/Tax Year/ProgramTelephone NumberPower of AttorneyIRS Received DateThe following items are the titles of the check boxes in the bottom two thirds of the page. Complete Form 911, send to TAS, and Control case to examiner.Re-open on AIMS for Correspondence Exam.Assign to Audit Recon TE. Open controls on IDRS and CEAS.Send Letter 3338C, close on CEAS using Status Code 72.The following line has three check boxes and are: Send Interim LetterSend Letter 2645Send Letter 2644The remaining lines each have one box on each line. They are: Transfer to Area Office - Establish AIMS control.Transfer to Appeals.Route to Classification.Request Administrative File.Transfer to Other Site: Site IdentifiedMisroute - return to:Area Office Recon to be worked in Campus Audit Recon Unit - Assign Project Code 0001 to CEAS record.Send 86C letter.Send 96C letter.Staup.A line to write additional remarks/comments is present and titled Additional Remarks.There is a line titled First Read Examiner/Campus for the name and campus of the examiner preparing the sheet.There is one additional line, on the same line as the examiner line for the date and the title of it is Date. Please click here for the text description of the image. Exhibit 4.13.7-13 Audit Reconsideration of Assessments Made by Appeals Processing Unit Don't automatically send audit reconsideration requests on closed Appeals cases to Appeals. Some reconsideration requests should go to Appeals. Some should be routed to the originating function that made the adjustment – AUR, ASFR, Exam, etc. Some must be rejected because the Appeals closure was final. It depends on how Appeals closed the case. Send the audit reconsideration request directly to Appeals when: The TP agreed with the Appeals finding and signed agreement form 870. (Appeals closing code 03 or 04.) Note: Appeals also uses closing code 03 on closures with Form 870-AD or Form 906 (Closing Agreements of Final Determination of Tax Liability) or 866 (Agreement as to Final Determination of Tax Liability). Don’t send audit reconsideration requests on these cases to Appeals. (Refer to IRM 18.104.22.168.(1) b. through f.) Follow the instructions in #3 below. Appeals issued a Statutory Notice of Deficiency but, the TP did not respond so Appeals defaulted the notice and assessed the tax. (Appeals closing code 05) In these cases, when you forward the audit reconsideration to Appeals, send the TP letter 916C and select the optional paragraph that reads: "Thank you for your audit reconsideration request dated ______. Appeals previously considered and closed your case. We are forwarding your audit reconsideration case to the Appeals office located at _________________________ . You should hear from them within 90 days." Don’t send the audit reconsideration request to Appeals – but route it to the originating function that made the initial determination (AUR, ASFR, Exam, etc) when: The case was docketed in Appeals and the Tax Court dismissed the TPs case for Lack of Jurisdiction. In these cases, Appeals had no involvement with the issue and Appeals processing input the adjustment per the Statutory Notice of Deficiency for Area Counsels’ office. (See IRM 22.214.171.124(1)f and g.) (Appeals closing codes 08, 11, or 21.) In these cases, send the case to the appropriate originating function and send the TP letter 916C and select the optional paragraph that reads: "Thank you for your audit reconsideration request dated ________. We are forwarding your case to_________________ for consideration. You should hear from them within ___days." Deny the TPs audit reconsideration request when the case was previously in Appeals and the Appeals determination was final or the Tax Court entered a final decision. This would include cases closed as follows: With a decision document secured in a case docketed before the United States Tax Court. (Appeals closing codes 08, 10, or 21). A decision made by the Court in a case that went to trial. (Appeals closing code 17). A dismissal by the Tax Court due to Lack of Prosecution. (Appeals closing code 12). In these cases send the TP letter 916C and select the optional paragraph that reads: "The Appeals Office or the Tax Court previously considered the examination of your tax return at your request. The Appeals Office or the Tax Court closed that examination based on the last examination report you received. That determination was final and we cannot reopen or reconsider your case."