Part IV—List of Upgradable Issues that May Result in an Upgrade for Field Examination…

If a case is graded at a GS–11 level based upon Parts I, II and III, and an upgradable issue appears on the return, the case may be upgraded to a GS–12 after consideration of the facts in the case. These same 13 upgradable issues may cause a case to be upgraded from GS–12 to GS–13. However, the decision to upgrade a case to GS–13 is most often a determination that is based on case size and case complexity. Additionally, a 14th upgradable issue called "Unusual Complexity" is included to allow group managers to upgrade a case based upon features, facts and circumstances encountered during a particular examination.

The following table presents 13 upgradable issues which may cause a case to be upgraded from GS–11 to GS–12 and a 14th category "Unusual Complexity."

Part IV—List of Upgradable Issues that May Result in an Upgrade

I. Controlled Group

2. Complex Like Kind Exchange

3. Liquidation/Reorganization

4. Foreign controlled (Exclusive of Significant Specialist Involvement)

5. Valuation issues (Exclusive of Significant Engineering Support)

6. Financial Products. e.g., commodities, straddles, etc.

7. LIFO

8. IRC 263A — Capitalization of Inventory Costs

9. IRC 482 — Allocation of Income/Deductions among two or more trades/business

10. IRC sections 741/742/743, Recognition/Character of Gain/Loss & Basis on Sale of a partnership.

11. Key Case TEFRA

12. Complex Fraud Development

13. Sensitive, High-Profile Taxpayer

14. Unusual Complexity