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EO - EO Enforcement Criteria

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

Generally, EO examiners must enforce converted return taxes for the affected tax years of an adverse status change if there is a tax deficiency of ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ in the aggregate for all tax years under examination.

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▸Contents — Internal Revenue Manual Part 4. Examining Process
Internal Revenue Manual Part 4. Examining Process

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