Internal Revenue Manual (IRM) Materials Relating to Tax Exempt Bonds

 

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IRM 4.81.5 Examination Process
This manual section provides the basic techniques that are intended to ensure that a uniform approach is taken when conducting TEB examinations. The following guidance on general examination techniques and procedures used to conduct examinations of tax-exempt bonds and tax credit bonds is provided for TEB examiners. The procedures outlined within this manual are designed to be used as a guide for TEB examiners when examining a Form 8038 series information return and are not intended to be all inclusive.

IRM 4.81.6 Closing Agreements
This manual section provides procedures for the IRS to enter into closing agreements with governmental issuers and other parties to tax-exempt bond transactions with respect to the application of federal tax law requirements under the Code and corresponding Income Tax regulations (the "Regulations" or "ITR" ) in order to correct any compliance failures and preserve the tax-exempt status of the bonds. These procedures are intended to ensure consistency of treatment and to encourage increased voluntary compliance throughout the municipal bond industry.

IRM 4.81.7 Bondholder Referrals
This manual section provides guidance for TEB examiners to refer bondholders in the event of an adverse bond examination.

IRM 7.2.3 Tax Exempt Bonds Voluntary Closing Agreement Program
This manual section provides procedures for the voluntary closing agreement program for tax-exempt bonds and tax credit bonds known as TEB VCAP.

4.81.12 Compliance Review of Form 8038-CP
This IRM section provides procedures for the Field Assistance Support Team’s review of the refundable credit payments claimed on Form 8038-CP.

4.81.14 Unagreed Issues
This IRM section provides examination guidelines for Tax Exempt Bonds, Unagreed Issues, including denials of claims for recovery of an asserted overpayment of an arbitrage payment under IRC 148 and unagreed disallowances to credit payments under IRC Section 6431.

4.82.2 Arbitrage Payment Refund Claim Procedures
This IRM section provides basic examination procedures that will enable Tax Exempt Bonds (TEB) employees to process claims for recovery of overpayment of arbitrage payments.

4.82.3 Direct Pay Bonds
This IRM section provides examination guidelines for Direct Pay Bonds, a type of tax-advantaged bonds where the interest paid on the bonds is taxable to the holder and the bond issuer is allowed a refundable tax credit.