This chapter covers unique processing instructions for large dollar cases. In determining whether a case should be considered a large dollar case, treat each tax period separately (except over $10 million in deficiency cases See IRM 4.4.18.5.) and do not consider offsets. Large dollar cases are:

All large dollar cases with agreed and unpaid deficiencies or overassessments of $100,000 and greater must be flagged on Form 3198 in the " Expedite Processing" section. In addition the "Over $100,000 Agreed and Unpaid" section of Form 3198 must be completed by the field group. Requirements for Centralized Case Processing (CCP) and Technical Services to complete this section have been removed. The next revision of Form 3198 will reflect the changes above.

This section pertains to income, estate, gift and certain excise taxes with agreed and unpaid deficiencies of $100,000 and greater that are subject to the interest-free waiver period under IRC section 6601. These procedures do not apply to employment tax returns or delinquent returns secured by Examination after a Substitute for Return has posted.

The "Expedite Processing" section of the Form 3198 must be completed by the field group for all case files with agreed unpaid deficiencies or overassessments of $100,000 and greater. The $100,000 criteria is not cumulative, but is determined per year.

Due to interest paid on the deficiency or overassessment, these cases must receive expedite processing. Every effort should be made to assess the deficiency within 30 calendar days of the agreement date if the unpaid deficiency is greater than $100,000. In addition, a quick assessment will be necessary ONLY if the 23C date will not be within 30 calendar days from the agreement date. See IRM 4.4.25, Quick Assessments .

Every effort should be made to forward these cases as expeditiously as possible. The following time frames have been established and should be followed:

The quick assessment guidelines found in IRM 4.4.25, Quick Assessments, will be revised as follows for agreed, unpaid deficiencies for income, estate, gift and certain excise taxes:

Overassessments of $100,000 or more must receive expedite processing. See IRM 4.4.18.3.

Overassessments of $100,000 or more in Correspondence Exam groups in the Campus must be approved by the lead tax examiner or manager and processed within 21 days of receipt.

Overassessments of ten million dollars or more (including allowable interest) will be refunded using manual refund procedures. See IRM 4.4.19, Manual Refunds.

Each year the General Accounting Office (GAO) examines the Service’s financial statements. As a part of this audit, they review documentation for taxpayers whose balance due (including interest and penalties) is over $10 million.

For each taxpayer, where the Balance Due (this includes interest and penalties)for all tax periods combined will be $10 million or more, a copy of the Form(s) 4318 or Form(s) 4700, and the examination report(s) is sent to the Office of Unpaid Assessment Analysis. This information will be sent by Centralized Case Processing after the case has been closed. If you are sending the information via regular mail delivery, the address is:

If you are sending the information via overnight mail, the address is:

See the LMSB Joint Committee website for links to Joint Committee IRM 4.36, geographic assignments, contact information and review group mailing addresses. http://lmsb.irs.gov/hq/pqa/Joint_Committee/index.asp .

LMSB Joint Committee (JC) agreed or surveyed cases will be updated by the field group to status 21 and sent to the appropriate Joint Committee Review Group, JCRG, servicing the field group’s geographic area.

The LMSB field group should contact the appropriate JCRG servicing the group’s geographic area for instructions on processing LMSB JC partially agreed (minimum refund) cases. See IRM 4.36.3.7.1 for minimum refund definition.

SBSE agreed/partially agreed/surveyed JC cases will be updated by the field group to status 21 and sent to the Local Technical Services group servicing the field group’s geographic area.

If a survey based on the taxpayer’s retained copy is requested, Centralized Case Processing will use an original return blocking series, prepare Form 2275 and forward it to the appropriate campus in the source document file the same day the closing was input. The Files Unit at the campus will enter the new DLN on the Form 2275 and refile the original return under the new DLN.