Part 4 - Examining Process

 

IRM 4.10.1 Timing of Supervisory Approval of Penalties Subject to IRC 6751(b) (PDF) PDF

An interim guidance memorandum dated September 24, 2020 issues Field Examination specific guidance for supervisory approval of penalties subject to IRC 6751(b) until the impacted IRMs listed above are published.

IRM 4.10.3 Reissue Interim Guidance for Group Manager Concurrence Meeting (GMCM) PDF

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.

IRM 4.10.4 Guidance for Addressing Currency Transaction Report Information (PDF) PDF

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).

IRM 4.10.4 Reissue Interim Guidance for Addressing Currency Transaction Report Information PDF

This memorandum issues Field Examination specific guidance on Currency Transaction Report (CTR) data until IRM 4.10.4 is published. Reissue IG Memorandum SBSE-04-0819-0021 dated August 12, 2019.

IRM 4.10.9 Reissue Interim Guidance for SB/SE Field Examination Administrative Lead Sheets PDF

This memorandum issues Field Examination specific guidance on administrative lead sheets until IRM 4.10.9 is published. Reissue IG Memorandum SBSE 04-1019-0043 dated October 16, 2019.

IRM 4.10.10 Interim Guidance Revising and Adding Standard Paragraph Explanations

This guidance is now incorporated into the IRM. Following the link above will take you to IRM 4.10.10 where the guidance has been incorporated. This link will be removed on 7/27/2022.

IRM 4.10.27 Interim Guidance for Routing of Identity Theft Account Adjustment Requests PDF

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.

IRM 4.11.11 Interim Guidance for Examining Tax Returns Reporting Net Operating Losses PDF

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.

IRM 4.12.1 Reissue Interim Guidance Memorandum SBSE-04-0721-0040; Formerly SBSE-04-0719-0034, Third-Party Contact Notification Procedures PDF

Reissue Interim Guidance Memorandum (IGM) SBSE-040721-0040 dated July 22, 2021 (formerly issued as SBSE-04-0719-0034, dated July 26, 2019), which provided guidance for making third party contacts in connection with the determination or collection of a tax liability of a taxpayer. IRM 25.27.1.

IRM 4.23.10 Temporary Guidance on Additional Use of Letter 1024-T PDF

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.

IRM 4.24.2 Interim Guidance on Registration Tests for Form 637 Registrations Other than Under IRC 4101, including new G Registrations PDF

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.

IRM 4.24.10 Determining the Adequacy of an Appeal in an Excise Tax Exam Case (PDF) PDF

An interim guidance memorandum dated June 30, 2020 was issued to revise guidance based on Determining the Adequacy of an Appeal in an Excise Tax Exam Case. This memo issues guidance when determining the adequacy of a taxpayer protest until IRMs 4.24.10, 4.24.16 & 4.24.17 are published.

IRM 4.24.16 Fuel Related Penalty Package Enclosures for Letter 3145, 30- Day Letter for Fuel Related Proposed Penalties and Letter 3057, Refusal Letter Under IRC PDF

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.

IRM 4.24.21.5.3.1 Interim Guidance on IRM 4.24.21.5.3.1, No Change Excise Report Non-Filed Excise Return Report Forms, Letters and Closing Procedures, Obsoleted (PDF) PDF

This memorandum issues guidance on IRM 4.24.21.5.3.1, No Change Excise Report Non-Filed Excise Return Report Forms, Letters and Closing Procedures, until IRM 4.24.21, Excise Tax, Case Closings is revised.

IRM 4.24.21.5.3 Revised Closing Procedures for No Change Excise Examinations PDF

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.

IRM 4.25.2 - Estate Tax Closing Letter Requests 12/2/2021 PDF

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

IRM 4.25.11 Interim Guidance on the preparation of Form 6111, IRC 2032A Special Election Referral Package Checklist PDF

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

IRM 4.26.17 Deviation for FBAR Compliance Activity in COVID-19 Environment (PDF) PDF

This memorandum issues updated guidance for Report of Foreign Bank and Financial Accounts (FBAR) compliance activity in the ongoing COVID-19 environment.

IRM 4.30.2 Obsoletion/Withdrawal of LB&I Field Directives PDF

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

IRM 4.31 Guidance on the Revocation of Internal Revenue Code Section 754 Election Procedures PDF

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.

IRM 4.31 Interim Guidance on Implementation of the Large Partnership Compliance Pilot Program PDF

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.

IRM 4.31.2 IGM for Syndicated Conservation Easement Examinations - IRM Deviation to Procedures in IRM 4.31.2 for TEFRA imminent statute of limitation cases PDF

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.

IRM 4.31.2 Interim Guidance for TEFRA Partnership Examinations with IRC 965 Issues - Statute Considerations, Examination and Classification PDF

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.

IRM 4.31.3 Handling of the qualified business income deduction on investor returns controlled by examination field support groups in LB&I and SB/SE Campus PDF

Handling of the qualified business income deduction on investor returns controlled by examination field support groups in LB&I and SB/SE Campus effective October 21, 2021 for the impacted IRMs 4.31.3 & 4.31.6.

IRM 4.31.9 Deviation from Established Time Frames Described in IRM 4.31.9 Regarding 2019 and 2020 Syndicated Conservation Easement Compliance Initiative Project (PDF) PDF

This memorandum extends the previously approved deviation in LB&I-04-120-0019 for 2018 tax years to the 2019 and 2020 tax years for cases specifically addressed in the guidance. The effective date is March 18, 2022. The affected IRM is 4.31.9.

IRM 4.31.9 Deviation of Established Time Frames Described in Interim Guidance Memorandum LB&I-04-1019-010 as it Pertains to SCE CIP/Campaign Cases Audited Under (PDF) PDF

LB&I and SB/SE jointly issued IG memo LB&I-04-1020-0019,Deviation of Established Time Frames Described in Interim Guidance Memo LB&I-04-1019-010 as it Pertains to SCE CIP/Campaign Cases Audited Under the Centralized Partnership Audit Regime of the BBA, on Nov. 12, 2020, affecting IRM 4.31.9.

IRM 4.31.9 Interim Guidance for BBA Partnership Examinations with IRC 965 Issues - Statute Considerations, Examination and Classification PDF

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.

IRM 4.31.9 Interim Guidance on Case Closing Procedures in IRM 4.31.9.6.5, Pass-Through Entity Handbook, Centralized Partnership Audit Regime (BBA) Field Exam PDF

An interim guidance memorandum effective 2/14/2022 was issued to revise closing procedures in IRM 4.31.9.6.5, Processing Partner Non-Pass-Through Adjustments.

IRM 4.32.4 Interim Guidance on IRC 6707A Penalty Approval PDF

This memorandum issues guidance eliminating the requirement for penalty approval beyond the immediate supervisor. This IGM will be incorporated into IRM 4.32.4, IRC 6707A Penalty for Failure to Include Reportable Transaction Information With Return, by March 31,2024.

IRM 4.46.3 Electronic Communications with Taxpayers PDF

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.

IRM 4.46.3 Examination Priorities and Modification of Pause on New DAS Cases PDF

LB&I issued Interim Guidance Memo LB&I-04-0222-0007, Examination Priorities and Modification of Pause on New DAS Cases, effective 2/24/2022. This memo affects IRM 4.46.3 and IRM 4.46.4.

IRM 4.46.3 Interim Guidance on Claims for Refund that Include a Claim for Credit for Increasing Research Activities PDF

LB&I and SB/SE jointly issued IG Memo LB&I-04-0122-0001, Interim Guidance on Claims for Refund that Include a Claim for Credit for Increasing Research Activities. This IG memo affects IRM 4.46.3, IRM 4.10.11 and IRM 4.1.1. The effective date of the memo is January 10, 2022.

IRM 4.46.3 Video Meetings with LB&I Taxpayers and their Representatives PDF

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.

IRM 4.46.4 Interim Guidance Memorandum on Economic Substance Doctrine and Related Penalties PDF

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.

IRM 4.46.5 Requesting Participation in Appeals Conferences for Appeals Team Leader Cases PDF

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.

IRM 4.61.7 Interim Guidance for Examinations with IRC 965 Issues - Statute Considerations, Examination and Classification PDF

LB&I issued Interim Guidance Memo LB&I-04-1120-0020, Interim Guidance for Examinations with IRC 965 Issues - Statute Considerations, Examination and Classification, dated 11/17/2020. The affected IRMs are IRM 4.61.7 and IRM 25.6.23.

IRM 4.65.3 Reissue Interim Guidance Memorandum LB&I-04-0120-0002, Procedures for FATCA Certification Event of Default Notices PDF

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.

IRM 4.70 Cases Subject to Mandatory Review PDF

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.

IRM 4.70.6 Sending Acknowledgement Letters when Receiving Large Volumes of Similar Referrals PDF

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.

IRM 4.70.13 Video Meetings with Taxpayers and Representatives PDF

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.

IRM 4.71 Discussion and Documentation of Publication 1, Notice 609, Publication 5146 and the Examination Process PDF

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.

IRM 4.71.1 Interim Guidance on Letter Consolidation (PDF) PDF

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.

IRM 4.71.1 Taxpayer Digital Communications Secure Messaging PDF

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

IRM 4.71.6 Referral Acknowledgement Letter 4426 (PDF) PDF

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.

IRM 4.71.22 Tax Exempt and Government Entities Title 26 Compliance Check Process PDF

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.

IRM 4.75.12 Interim Guidance on Verifying Forms 8976 Were Filed and Applicable Penalties (PDF) PDF

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.

IRM 4.75.7 Tax Exempt and Government Entities Examination Process PDF

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.

IRM 4.86.1 Customer Assistance for Indian Tribal Governments (PDF) PDF

This memo updates Customer Assistance for Indian Tribal Governments procedures that we'll publish in IRM 4.86.1 and remove from IRM 4.88.1. This memo is effective October 15, 2020.

IRM 33.3.6.2.1 Interim Guidance on Designation of Cases for Litigation (PDF) PDF

This memorandum provides interim guidance to the field on the criteria that should be applied in considering if a request for designation for litigation should be made to the Office of Chief Counsel.

All Published Guidance - the Internal Revenue Manual

To find all published guidance for employees go to the corresponding Part of the Internal Revenue Manual.