Caution:

If a document is defaced, you may need to exchange it with the taxpayer again, with the markings on it. Discuss this situation with your group manager or TEGEDC.

By carefully tracking all documents exchanged by date, it’s easier to compile the administrative record and prepare the index if the case goes unagreed. It’s recommended you compile an administrative record file at the same time as the various exchanges so that when items are exchanged, you scan that item and put in the electronic administrative record file.

Tax Court Rule 217 imposes short deadlines for filing the administrative record. Further, Counsel reviews all unagreed cases subject to declaratory judgment before IRS issues the final adverse letter. The administrative record must be well-organized and complete when Counsel receives it.

When scanning documents, make sure that the copy is a clear identical copy of the original (aside from being in black and white versus color). This requires that you:

Lay the document flat on the glass pane in lieu of using an auto feeder if the document is folded or bent.

Remove staples, paper clips, or other fasteners before scanning.

Scan the front and back of a document if information is present on the back.

Check that no portions of the document are eliminated or missing in the scan.

Double check each page scanned to ensure that it is a pristine identical copy of the original.