EO Reports and Closing Letters for Claims and Abatements
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
(1) For general procedural instructions on claims and requests for abatement, see IRM 4.70.17, Claims and Abatements.
(2) Where FTS is a viable option to an eligible taxpayer for unagreed issues, give the taxpayer Pub 5092, Fast Track Settlement A Process Resolution of Tax Exempt and Government Entities (TEGE) Tax Issues, with the initial examination report.
(3) If a statute date is imminent and there is no time to send a standard 30-day letter, consider issuing a replacement transmittal letter for the report. Consult with Area Counsel concerning the content, format, and timing of issuing a letter that replaces a 30-day letter. Refer to the Taxpayer Advocate Service (TAS) directory page https://organization.ds.irsnet.gov/sites/tas/SiteAssets/TAS%20Directory.aspx for the current list of TAS offices. Generally:
Summarize in the letter why you can’t use a standard 30-day letter. See Sections 9.10 and 12.02 of Rev. Proc. 2019-5 (updated annually).
Ensure the replacement transmittal letter contains the standard Taxpayer Advocate paragraph.
A suspense date for the letter isn’t required.
The transmittal letter can direct the taxpayer toward availing themselves the opportunity for Appeals consideration, such as by promptly submitting a valid consent to extend the statute date.
Claims Allowed in Full
TYPE OF RESULT & RETURN:
CLOSING LETTER
Income Taxes - Claim Allowed in Full:
Form 990-T also proxy tax
Form 1120-X
Form 1120-POL
Form 1041
Letter 570-A
Form 4549
Chapter 41 and 42 Excise Taxes - Claim Allowed in Full:
Form 990-PF
Form 990-BL
Form 4720
Form 4720-A
Form 843
Letter 570-A
Form 4621
Form 4883
Miscellaneous Excise Taxes - Claim Allowed in Full:
Form 11-C
Form 730
Form 8849
Letter 3601
Form 5384
Employment Taxes - Claims Allowed in Full
Form 940
Form 941-X
Form 944-X
Form 945-X
Letter 570
Form 4666
Form 4667, if applicable
Form 4668, if applicable
Form 4668-B, if applicable
Claims Disallowed in Full or in Part
Examination Result
Type of Report
Report Forms and Letters
Income Taxes Claims Disallowed in Full, Claims Disallowed in Part or Claims Disallowed with Additional Adjustment:
Form 990-T (also proxy tax)
Form 1120-X
Form 1120–POL
Form 1041
Report (issued by group)
Draft transmittal letter, IDR or Form 5701 (Initial reports only) or
Letter 3602, 30-day letter or
Letter 3602-B, 30-day letter; use with additional adjustment
Form 2297 with any letter above
Form 3363 with any letter above
Form 4549 with initial examination report only
Form 870 with Letter 3602-B only
Form 4549-A with either Letter 3602 or Letter 3602-B only
Form 886-A with any letter above
Agreed Closing Letter (issued by group)
Letter 2841-A, For agreed closing of full disallowance of claim only (correct the signature block)
Copy of Signed Form 2297
Copy of Signed Form 3363
Letter 2511, For agreed closing of partial disallowance of claim, or any disallowance with adjustment
Copy of Signed Form 2297
Copy of Signed Form 3363
Copy of Signed Form 4549 or Form 870
Unagreed Closing Letter
Letter 905, Statutory Notice of Disallowance of Claim in Part, issued by Mandatory Review or Appeals or
Letter 906, Statutory Notice of Disallowance of Claim in Full, issued by Mandatory Review or Appeals or
Letter 917, Closing letter when taxpayer fails to show eligibility to reconsider claim, for Claim Reconsiderations only, issued by group.
Chapter 41 and 42 Excise Taxes Claims Disallowed in Full, Claims Disallowed in Part or Claims Disallowed with Additional Adjustment:
Form 4720
Form 4720-A
Form 990-PF
Form 990-BL
Form 843
Report (issued by group)
Draft transmittal letter, IDR, or Form 5701 (initial examination reports only) or
Letter 3602, 30-day letter or
Letter 3602-B, 30-day letter- use with additional adjustment
Form 2297 with any letter above
Form 3363 with any letter above
Form 870-E with initial examination report or Letter 3602-B only
Form 4621 with any letter above
Form 4883 with any letter above
Form 886-A with any letter above.
Agreed Closing Letter (issued by group)
Letter 2841-A, For agreed closing of full disallowance of claim only (correct the signature block)
Copy of Signed Form 2297
Copy of Signed Form 3363
Letter 2511, For agreed closing of partial disallowance of claim or any disallowances with adjustment
Copy of Signed Form 2297
Copy of Signed Form 3363
Copy of Signed Form 870-E
Unagreed Closing Letter
Letter 905, Statutory Notice of Disallowance of Claim in Part, issued by Mandatory Review or Appeals or
Letter 906, Statutory Notice of Disallowance of Claim in Full, issued by Mandatory Review or Appeals or
Letter 917, Closing letter when taxpayer fails to show eligibility to reconsider claim, for Claim Reconsiderations only, issued by group.
Miscellaneous Excise Taxes Claims Disallowed in Full, Claims Disallowed in Part or Claims Disallowed with Additional Adjustment:
Form 11-C
Form 730
Form 8849
Report (issued by group)
Draft transmittal letter, IDR or Form 5701 (initial reports only), or
Letter 3602, 30-day letter or
Letter 3602-B, 30-day letter- use with additional adjustment
Form 2297 with any letter above
Form 3363 with any letter above
Form 5384 with initial reports only
Form 2504-E with Letter 3602-B only
Form 5385 with Letter 3602 or 3602-B only
Form 886-A with any letter above
Agreed Closing Letter (issued by group)
Letter 2841-A, For agreed closing of full disallowance of Claim (correct the signature block)
Copy of Signed Form 2297
Copy of Signed Form 3363
Letter 2511, For agreed closing of partial disallowance of claim, or any disallowances with adjustment,
Copy of Signed Form 2297
Copy of Signed Form 3363
Copy of Signed Form 870-E
Unagreed Closing Letter
Letter 905, Statutory Notice of Disallowance of Claim in Part, issued by Mandatory Review or Appeals or
Letter 906, Statutory Notice of Disallowance of Claim in Full, issued by Mandatory Review or Appeals
Letter 917, Closing letter when taxpayer fails to show eligibility to reconsider claim, for Claim Reconsiderations only, issued by group.
Employment Taxes Claims Disallowed in Full, Claims Disallowed in Part or Claims Disallowed with Additional Adjustment:
Form 940
Form 941-X
Form 944-X
Form 945-X
Report (issued by group)
Draft transmittal letter, IDR or Form 5701 (initial reports only) or
Letter 5376, 30-day letter or
Letter 953, 30-day letter, Reconsideration of Disallowed Claims only
Form 2297 with any letter above
Form 3363 with any letter above
Form 2504 use appropriate version, for any disallowance with additional adjustments
Form 4666 with any letter above
Form 4667 with any letter above
Form 4668 with any letter above
Form 4668-B with any letter above
Form 886-A with any letter above
Pub 3498 with any letter above
Pub 594 with any letter above
Pub 5 with any letter above
Agreed Closing Letter (issued by group)
Letter 2841-A, Agreed Closing for Full Disallowance of Claim (correct the signature block)
Copy of Signed Form 2297
Copy of Signed Form 3363
Letter 2511, Agreed Closing for Partial Disallowance of Claim, or any Claim with Adjustment
Copy of Signed Form 2297
Copy of Signed Form 3363
Copy of Signed appropriate Form 2504 version if there are additional adjustments
Unagreed Closing Letter
Letter 905, Statutory Notice of Disallowance of Claim in Part, issued by Mandatory Review or Appeals, or
Letter 906, Statutory Notice of Disallowance of Claim in Full, issued by Mandatory Review or Appeals, or
Letter 917, Closing letter when taxpayer fails to show eligibility to reconsider claim, for Claim Reconsiderations only, issued by group
Abatement Requests Allowed in Full
TYPE OF RESULT & RETURN:
CLOSING LETTER
Income Taxes - Requests for Abatement Allowed in Full:
Form 990-T also proxy tax
Form 1120-X
Form 1120-POL
Form 1041
Letter 693, examination reconsiderations only, check the 1st box for full abatement and enclose Letter 2738 to Letter 693 or
Letter 2738 by itself for non examination reconsiderations
Form 4549, with either letter
Chapter 41 and 42 Excise Taxes - Requests for Abatement Allowed in Full:
Form 4720
Form 4720-A
Form 990-PF
Form 990-BL
Letter 693, examination reconsiderations only, check the 1st box for full abatement and enclose Letter 2738 to Letter 693 or
Letter 2738 by itself for non-examination reconsiderations
Form 4621 with either letter
Form 4883 with either letter
Miscellaneous Excise Taxes - Requests for Abatement Allowed in Full:
Form 11–C
Form 730
Letter 693, examination reconsiderations only, check the 1st box for full abatement and enclose Letter 2738 to Letter 693 or
Letter 2738 by itself for non examination reconsiderations
Form 5384 with either letter
Employment Taxes - Requests for Abatement Allowed in Full:
Form 940
Form 941-X
Form 944-X
Form 945-X
Letter 5154, check the 1st box
Letter 2738 enclosed
Form 4666
Form 4667
Form 4668,
Form 4668-B
Pub 5,
Abatement Requests Disallowed in Full or in Part
Examination Result
Type of Report
Report Forms and Letters
Income Taxes Abatements Disallowed in Full Abatements Disallowed in Part, or Abatements Disallowed with Additional Adjustment:
Form 990-T, also proxy tax
Form 1120-X
Form 1120–POL
Form 1041
Report (issued by group)
Abatements Disallowed in Full or in Part Only
Get a plain-English answer with a citation back to this text.
Ask AI about this code