Description:
Taxpayer requests early referral to Appeals of developed unagreed issue in an open audit (prior to 30-day letter)
Taxpayer and Team Manager agree issue should be referred early
Remaining issues are not expected to be complete before Appeals resolve early referral issue
Certain issues excluded but includes Industry Specialists Program (ISP) and Appeals Coordinated Issues
Closing Agreements executed if agreement is reached
If agreement is not reached, taxpayer may request mediation or will be issued a statutory notice of deficiency
Revenue Procedure 99-28
Section 4.46.5.6.10 of IRM 4.46.5.6 – Early Referral to Appeals (scroll down to 4.46.5.6.10)
|