Part 4 - Examining Process

 

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 memorandum, effective 7/13/2023 has been issued to revise IRM 4.10.6 regarding Procedures for Assessing IRC 6698 and IRC 6699 Penalties.

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 memorandum, effective 9/22/2023 was issued to revise IRM 4.10.10 regarding Adding Standard Explanation for Residential Energy Credit.

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).

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 Intermin Guidance Memorandum was issued on 4/17/2023 with an effective date of 5/4/2023 for the processing of California State Department of Industrial Relations, Division of Labor Standards Enforcement Federal Tax Information Requests.

An IRM procedural update, effective 03/31/2023, was issued to revise IRM 4.19.14.6.5 regarding EITC Qualifying Child (QC): Update to the Support and Tiebreaker Rule for Supporting Documentation and Eligibility Requirement Explanation; Correction to the Tax Court Citation Regarding the Form 8332.

An IRM procedural update, effective 06/22/2023, was issued to revise IRM 4.19.14 regarding Inclusion of PC 1360 in Program Description; Additional Clarifying Language for EITC Responses, QRP, RRC, and SFLC.

An IRM procedural update, effective 05/05/2023, was issued to add subsection IRM 4.19.14.18.11 regarding New Unallowable Subsection Added to Provide Guidance for the IRC 1341, Claim of Right Credit.

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 11/01/2023, was issued to remove IRM 4.19.19.2.2.1 regarding Answering Fast Track Calls (W&I Only).

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.

An interim guidance memorandum effective 6/2/2023 was issued to revise IRM 4.24.1, 4.24.2, 4.24.5, 4.24.6, 4.24.8, 4.24.17, 4.24.23, and 4.24.24 regarding Excise Examinations of Indian Tribal Governments.

An interim guidance memorandum was issued effective 5/02/2023 to revise IRM 4.24.1, Petroleum Tax on Domestic Crude Oil Exported from the United States.

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 effective 6/8/2023 was issued to revise IRM 4.24.8 relating to the new Letter 6517, Paid Fuel Claim Short Statute Assessment, until IRM 4.24.8, Examination Guidance for Excise Claims for Refund or Abatement, is revised.

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 memorandum, effective 3/21/2023, was issued to revise IRM 4.24.13 regarding Fuel Compliance Inspections on Indian Tribal Lands.

An interim guidance memorandum, effective 4/11/23, has been issued regarding standard electronic workpaper naming conventions in issue management system (IMS).

An interim guidance memorandum, effective 7/6/2023, was issued to revise IRMs 4.26.16 and 4.26.17 regarding FBAR Examination Case Procedures Due to Supreme Court Decision (Bittner v. US).

An interim guidance memorandum, effective 8/8/2023, was issued to revise IRM 4.26.17 regarding Updated Deviation for FBAR Compliance Activity, to Modify Procedures for CTR Operations’ Building Closure.

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

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 Memorandum LBI-04-0423-0004, Interim Guidance for Approval of Penalties under Internal Revenue Code (IRC) 6751(b)(1) for LB&I Examinations, on April 27, 2023. This memo affects IRM 4.46.1, IRM 4.46.3, IRM 4.46.4, IRM 4.31.9 and IRM 20.1.1.

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 issued Interim Guidance Memorandum LBI-04-0423-0005, Interim Guidance on Deviation from Mid-Cycle Risk Analysis for Micro-Captive Insurance Cases. This memo affects IRM 4.46.3.

LB&I issued Interim Guidance memo LB&I-04-1023-0008, Interim Guidance on LB&I Compliance Priorities, effective October 11, 2023. This memorandum affects IRM 4.46.3, Planning the Examination.

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-04-0821-0011, 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.

LB&I issued Interim Guidance Memorandum LB&I-04-0423-0006, Interim Guidance on Review and Acceptance of Advance Pricing Agreement (APA) Submissions, effective April 25, 2023. This memorandum affects IRM 4.60.3, Tax Treaty Related Matters.

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.

Tax Exempt and Government Entities issued interim guidance effective May 8, 2023, to revise IRM 4.70, 4.71.3, 4.75.25, 4.75.37, 4.75.40, 4.81.6, 4.86.5, 7.2.3, and 7.11.8 regarding Changes in Closing Agreement Requirements.

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.

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.

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.

Exempt Organizations and Government Entities issued interim guidance effective May 10, 2023, to revise IRM 4.75.37, 4.86.5, and 4.70.17 regarding Processing COVID-19 Related Credit Claims.

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