Example:

You secure half of the year’s bank statements at the initial exam, a few more by IDR a month later, and the rest by bank summonses two months later. You subsequently exchange the summoned bank statements with the taxpayer to include them in the administrative record. Counsel advises you to keep all bank statements for a given year together as one exhibit. Index the dates and methods describing the documents that were exchanged. Identify the number of pages of each set of documents in the description of the documents.

If the taxpayer ultimately agrees, an administrative record is required, but an index is not.

Keep all original paper records after scanning and saving in RCCMS until the issues are resolved. If requested, you may need to assist Mandatory Review if an administrative record is subsequently required for a case you closed to Mandatory Review with taxpayer agreement to the adverse action (in other words, the taxpayer filed a petition.)

Consult your group manager on cases with unique circumstances that might justify processing with a paper case file.