Description:
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Same or similar issues of a CIC taxpayer from one tax period to other tax periods
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Unlike Delegation Order 236, settlement authority not added for managers
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Taxpayer requests extending the examination of issues to more current tax periods
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Auditing work or verification performed on the subsequent year adjustments
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Utilizes either a Closing Agreement or standard partial and/or full agreed deficiency procedures
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Certain issues are excluded or require approval of other offices or functions
Revenue Procedure 94-67
See IRM sections 4.46.5.6.8 - 4.46.5.6.9 of IRM 4.46.5.6 (scroll down to 4.46.5.6.8)
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