Part 4 - Examining Process

 

This memorandum issues Field Examination specific guidance on the time requirements to conduct the GMCM until IRM 4.10.3 is published. Reissue IG Memorandum SBSE-01-1019-0042 dated October 16, 2019.

The interim guidance SBSE-04-0922-0075 effective immediately regarding the timing of supervisory approval for penalties subject to IRC 6751(b) is a reissuance of interim guidance SBSE-04-0920-0054 dated 9/24/2020.

The purpose of this interim guidance is to clarify actions examiners must take to analyze and document Currency Transaction Report (CTR) data during an audit conducted under Title 26 of the United States Code (USC) (i.e., the Internal Revenue Code).

This memorandum reissues interim guidance IRM 4.10.4 Reissue Interim Guidance for Addressing Currency Transaction Report Information (SBSE-04-0821-0043 ), dated August 20, 2021.

An interim Guidance, SBSE-04-0922-0063, effective 9/28/2022, has been issued to update IRM 4.10.6 regarding Supervisory approval for penalty abatement.

An Interim Guidance Memo effective 01/23/2023 was issued to revise seventeen standard explanations until IRM 4.10.10 is updated.

An Interim Guidance Memorandum, effective 2/26/2023 has been issued to revise IRM 4.10.15 regarding instructions for the deletion of cases on the Report Generation Software (RGS).

This memorandum issues guidance to SB/SE Field Examination and LB&I on where to send ID Theft taxpayer account adjustment requests until IRM 4.10.27, Identity Theft Case Processing for Field Examiners, is published.

This memorandum issues guidance to SB/SE and LB&I Examination operations on ensuring awareness of taxpayer's actions with respect to carrybacks when examining tax returns reporting a net operating loss.

An interim guidance effective 08/17/2022 was issued to revise IRM 4.11.51 regarding Submitting Return Preparer Penalty Referrals.

This Interim Guidance effective 9/29/2022 Reissues Interim Guidance Memorandum SBSE-04-1221-0068; Formerly SBSE-04-1219-0054, regarding the Qualified Business Income Deduction on a Substitute for Return to update IRMs 4.12.1, 4.19.15, & 4.19.17.

An IRM procedural update, effective 02/07/2023, was issued to revise IRM 4.19.14 regarding Schedule C and Form 1099-K; Qualifying Relative Residence Supporting Documentation

An IRM procedural update, effective 01/19/2023, was issued to revise IRM 4.19.14.6(5) regarding Valid Social Security Number (SSN) for the Earned Income Tax Credit (EITC).

An IRM procedural update, effective 01/03/2023, was issued to revise IRM 4.19.19.16 regarding Updating the Address SB/SE Corr Examination; Added the Amended Refund Hotline.

An IRM procedural update, effective 02/28/2023, was issued to revise IRM 4.19.19.2.3 regarding an Update to Provide Clarity for Controlling the Call.

This memorandum issues guidance on an additional use of Letter 1024-T, Employment Tax Return Accepted as Filed, until IRM 4.23.10 and IRM 4.23.12 are revised.

This memorandum provides guidance on the registration tests that must be met for Forms 637, Application for Registration (For Certain Excise Activities), received for activities other than under IRC 4101, including new G Registrations.

An Interim Guidance Memorandum has been issued to update IRM 4.24.8, effective 1/4/2023 regarding revised report writing procedures for claims.

An interim guidance effective 09/29/2022 was issued to revise IRMs 4.24.10, 4.24.16, & 4.24.17 regarding the extension and updating of guidance for determining the adequacy of an appeal in an excise tax exam case.

This memorandum issues interim guidance for a change in fuel related penalty package enclosures to be included with Letter 3145 and Letter 3057 until IRM 4.24.16, Excise Fuel Compliance Report Writing, Case Processing and Appeals Procedures is published.

This memorandum reissues interim guidance, IRM 4.24.21.5.3.1, Re-Issuance of Interim Guidance on No Change Excise Report Non-Filed Excise Return Report Forms, Letters and Closing Procedures, Obsoleted (SBSE-04-0920-0064) dated September 10, 2020.

An interim guidance effective 10/5/21 was issued to revise IRM 4.24.21.5.3 regarding Revised Closing Procedures for No Change Excise Examinations.

An interim procedural update effective 12/2/2021 was issued for IRM 4.25.2.5.10 Estate Tax Closing Letter Requests.

This memorandum issues guidance on the preparation of Form 6111, IRC 2032A Election Referral Package Checklist, until IRM 4.25.11.2 is published.

An Interim Guidance Memorandum, effective 12/12/2022 has been issued to revise IRM section 4.26.17 regarding an Updated Deviation for FBAR Compliance Activity. This IG memo supercedes IG SBSE-04-1120-0074.

An interim guidance memo effective January 26, 2022 was issued to obsolete or withdraw certain LB&I field directives.

This memorandum outlines new procedures for use by LB&I and SB/SE employees when determining whether to approve or deny a request filed by a partnership to revoke its election to adjust the basis of partnership property under IRC section 754. Effective 8/26/2021. IRM 4.31 and IRM 4.8.8.

Interim Guidance Memo LB&I-04-1021-0017, Interim Guidance on Implementation of the Large Partnership Compliance Pilot Program, was issued on 10/21/2021. It affects IRM 4.31, IRM 4.46.3 and IR 4.50.2.

IGM for Syndicated Conservation Easement Examinations - IRM Deviation to Procedures in IRM 4.31.2 for TEFRA imminent statute of limitation cases. This IGM replaces the previously issued memorandum SBSE-04 0320-0016, which expired on March 27, 2022.

LB&I issued Interim Guidance Memo LB&I-04-0821-0010, Interim Guidance for TEFRA Partnership Examinations with IRC 965 Issues - Statute Considerations, Examination and Classification, on August 20, 2021. This memo affects IRM 4.31.2.

Deviation from Established Time Frames Described in IRM 4.31.9 Regarding 2018, 2019 and 2020 SCE CIP and Campaign Cases Audited under BBA. Effective date: 11/17/2022.

LB&I issued Interim Guidance Memo LB&I-04-0821-0009, Interim Guidance for BBA Partnership Examinations (the Centralized Partnership Audit Regime of 2015) with IRC 965 Issues - Statute Considerations, Examination and Classification, on August 20, 2021. This memo affects IRM 4.31.9.

Interim Guidance on Implementation of the Centralized Partnership Audit Regime (BBA) Exam Field Support Operation Procedures (EFSO). Effective date 02/14/2023. Affected IRM 4.31.10.

LB&I issued Interim Guidance Memo LB&I-04-0722-0016, Interim Guidance on Modernized Process for Joint Committee Review Cases, effective 7/19/2022. This memo affects IRM 4.36.3, Joint Committee Procedures, Examination Team Responsibilities.

LB&I issued Interim Guidance Memo LB&I-04-0122-0004, Electronic Communications with Taxpayers, effective 1/25/2022. This memo affects IRM 4.46.3.

LB&I and SB/SE jointly issued IG Memo LB&I-04-1222-0026, Updated Interim Guidance on Claims for Refund that Include a Claim for Credit for Increasing Research Activities. This IG memo supersedes LB&I-04-0122-0001 and affects IRM 4.46.3, IRM 4.10.11 and IRM 4.1.1. Effective date 1/10/2022.

LB&I issued Interim Guidance Memo LB&I-04-0922-0018, Reissuance of Interim Guidance Regarding Examination Priorities and Modification of Pause on New DAS Cases, effective 9/20/2022. This memo affects IRM 4.46.3 and IRM 4.46.4.

LB&I issued Interim Guidance memo LB&I-04-0821-0011, Video Meetings with LB&I Taxpayers and their Representatives, effective October 18, 2021. This memorandum affects IRM 4.46.3, Planning the Examination.

Interim Guidance Memo LB&I-04-0422-0014, Interim Guidance Memorandum on Economic Substance Doctrine and Related Penalties, was jointly issued by LB&I and SB/SE on April 22, 2022. This IGM affects IRM 4.46.4, IRM 4.10.13 and IRM 20.1.5.

LB&I issued Interim Guidance Memo LB&I-04-1121-0019, Requesting Participation in Appeals Conferences for Appeals Team Leader Cases on November 8, 2021. The memo affects IRM 4.46.5, Resolving the Examination.

LB&I issued Interim Guidance Memo LB&I-04-0922-0019, Updated Interim Guidance for Examinations with IRC 965 Issues – Statute Considerations, Examination and Classification, effective 9/21/2022. This memo affects IRM 4.46.5, LB&I Examination Process, Resolving the Examination.

This memorandum reissues Interim Guidance Memorandum LB&I-04-0120-0002, which provides guidance for procedures for FATCA Certification Event or Default Notices. Affected IRM 4.65.3 (new). Effective date 4/1/2022.

Employee Plans Examinations issued interim guidance effective June 1, 2022, to revise IRM 4.70, 4.71.3, 4.71.4, 4.71.5, 4.71.8, 4.71.10, 4.71.14, 4.71.16, 4.71.23 and 4.71.27 regarding Cases Subject to Mandatory Review.

Employee Plans Examinations issued interim guidance effective January 10, 2023, to update IRM 4.70, 4.71.1, 4.71.3, 4.71.4, 4.71.5 and 4.71.27 regarding Use of Standardized Letters and Forms.

Employee Plans Examinations issued interim guidance effective February 1, 2023, to revise IRM 4.70 and 4.71.3 regarding Revisions to the DO 8-3 Closing Agreement Process.

Compliance, Planning and Classification issued interim guidance effective June 10, 2022, to revise IRM 4.70.6 regarding Sending Acknowledgement Letters when Receiving Large Volumes of Similar Referrals.

Tax Exempt and Government Entities issued interim guidance effective May 26, 2022, to revise IRM 4.70.13, 4.71.1, 4.75.10, 4.75.11, 4.81.5, 4.86.5, regarding Video Meetings with Taxpayers and Representatives.

Tax Exempt and Government Entities issued interim guidance effective February 28, 2022, to revise IRM 4.71, 4.75, 4.81 and 4.81 regarding the discussion and documentation of Publication 1, Notice 609, Publication 5146 and the examination process.

Tax Exempt and Government Entities issued interim guidance effective February 2, 2021, to update IRM 4.71, 4.72, 4.75, 4.81, 4.86, 7.1, 7.2, 7.11 and 7.13 regarding the completion of a letter consolidation project.

TE/GE issued interim guidance effective November 15, 2022, to revise IRM 4.71.1, 4.71.4, 4.71.6, 4.71.10, 4.71.17, 4.75.10, 4.75.12, 4.75.13, 4.75.15, 4.75.16, 4.75.20, 4.75.21, 4.75.22, 4.75.39 and 4.81.5 regarding a letter consolidation for Change due to Correction of Operations Closing Letter.

Interim guidance on communicating with taxpayers eligible for Taxpayer Digital Communication Secure Messaging (TDC SM).

Compliance Planning and Classification issued interim guidance effective September 15, 2017, to revise IRM 4.71.6, IRM 4.75.5, IRM 4.81.2, IRM 4.86.2, and IRM 4.90.6 regarding Referral Acknowledgement Letter 4426.

Tax Exempt and Government Entities issued interim guidance effective May 23, 2022, to revise IRM 4.71.22 regarding the Tax Exempt and Government Entities Title 26 Compliance Check Process.

Exempt Organization Examinations issued interim guidance effective March 1, 2021, to update IRM 4.75.12, in regard to Verifying Forms 8976 Were Filed and Applicable Penalties.

Tax Exempt and Government Entities issued interim guidance effective June 21, 2024, to revise IRM 4.75.7, 4.75.10, 4.75.40, 4.86.1 and 4.86.5 regarding the Tax Exempt and Government Entities Examination Process.

Government Entities issued interim guidance effective August 23, 2022, to revise IRM 4.86.1 regarding Customer Assistance for Indian Tribal Governments.