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If the organization...

Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

Then...

Agrees

Stamp the received date on Form 4549 (or Form 870-E).

Issue Letter 2511.

Prepare RCCMS Closing Record for the SFCR, 102.

Complete ARDI Code, on RCCMS Closing Record.

Close tax case to the EO Closing Unit.

Fails to reply

Prepare RCCMS Closing Record for the SFCR, DC 604.

Close tax case to Mandatory Review to issue the SNOD.

Disagrees - Provides NO new information, or provides additional information that does not change your report

Issue Letter 5918, Rebuttal to Organization.

Prepare RCCMS Closing Record, for the SFCR, DC 601 or DC 604.

Close tax case to Mandatory Review to issue the SNOD.

Disagrees -Provides additional information showing no tax adjustment was necessary

Issue Letter 2656.

Prepare RCCMS Closing Record, for the SFCR, DC 107.

Close tax case to the EO Closing Unit.

Disagrees - Provides additional information that decreases the tax

Issue a corrected RAR only. Don’t issue a new 30-day letter.

Issue Letter 5918 Rebuttal to Organization, over the part of the deficiency that remains unchanged.

Prepare RCCMS Closing Record for the SFCR, DC 601 or DC 604.

Close tax case to Mandatory Review to issue the SNOD.

Disagrees - Provides additional information that increases the tax

Issue a new 30-day letter Letter 950 (orLetter 3614) and a corrected RAR.

Suspend tax case for 30 days pending reply to new proposal.

Refer back to this table after organization responds.

After initiating deficiency procedures in IRM 4.70.14.2.1.3.3.11(6), close the SFCR as follows if you secure a converted tax return:

Closing the Converted Tax Return (SFCR)Organization Responds to Your Converted Tax Proposal by Filing a Converted Tax Return

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▸Contents — Internal Revenue Manual Part 4. Examining Process

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