Skip to content

If...

Caution:

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

If still within the 30-day period of the formal letter when you receive the incomplete protest, the taxpayer has the remainder of the 30 days and the additional 10 days in which to reply with the formal protest (a total of 40 days from the date of the formal 30-day letter).

If you receive a response to the drafted letter, refer to the above table as to how to proceed. Don’t send more than two drafted follow up letters to the taxpayer. If you don’t receive a formal protest after the second letter, close to Mandatory Review as unagreed without protest.

If the taxpayer fails to reply to a formal examination report and:

You sent the report...

You may...

More than 30 days ago

In some tax cases issue Letter 923, Letter Extending Time to File Protest, or Letter 923-E, Letter Extending Time to File Protest Excise See Notes 1, 2, and 3

37 days ago (45 days if you issued Letter 923 or a comparable letter)

Close the case to Mandatory Review as unagreed without protest with DC 10 (RCCMS - 604) or DC 55 (RCCMS - 605). See Exception.

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — Internal Revenue Manual Part 4. Examining Process

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.