Section 10. TE/GE Compliance Checks›4.70.10 TE/GE Compliance Checks›Note:
Title 26 Compliance Check Process - 3 Phases
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
The TE/GE Title 26 Compliance Check process is conducted in three phases. Within each phase are separate and distinct steps.
The first phase is the planning/preparation phase which includes these steps:
Assignment of the compliance check case to the group
Assignment of the compliance check case to the examiner
Examiner completes the pre-contact analysis (research)
The next phase is the execution phase.
Examiner initiates contact with the taxpayer.
Examiner will evaluate taxpayer response for compliance.
Examiner will determine case conclusion.
The third phase is the resolution phase.
Examiner will prepare and issue the appropriate closing letter.
Examiner will take the steps to close the compliance check administratively.
Examiner will submit the compliance to their manager for review and closure approval.
Planning/Preparation Phase¶
This phase of the process sets the scope of the compliance check. Issues selected should have the broadest impact on compliance regardless of the size and type of entity or organization.
The compliance check plan is issue focused and contains the following:
Actions/activities to be taken to work case i.e., IDRS research and risk analysis.
Verify all appropriate returns were filed, and payment requirements followed. Issues of potential noncompliance identified (i.e., Large, Unusual, Questionable (LUQ)).
Develop compliance check plan and receive managerial approval.
Timeline(s).
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