Example:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
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In the opening appointment letter, Pub 1, Your Rights as a Taxpayer, must be given or sent to the taxpayer, and must also be included in the administrative record.
Clarify incorrect computations, misinterpretations of law (IRC, Regulations, Revenue Rulings, etc.) or incorrect conclusions in writing via subsequent correspondence to the taxpayer.
Any information you previously shared with the taxpayer becomes a part of the administrative record; therefore, include incorrect information that you put in writing and sent to the taxpayer/representative in the administrative record.
To correct a mistake, do not remove the document from the administrative record. Rather, acknowledge the mistake and send a corrected statement or revised calculation to the taxpayer/representative.
To place information into the administrative record that was communicated orally with the taxpayer or POA in the initial interview or a subsequent telephone conversation, create a transcript or summary of the discussion using Form 4564, Information Document Request.
Document the Form 4564 with whom the conversation was held, and the matters discussed.
Send Form 4564 with Letter 1477, Information Document Request Cover Letter -EP and EO, to the taxpayer and ask them to confirm that the summary is an accurate representation of the information it contains, and if not, to provide specific clarification.
If you have any doubt that a document has been exchanged, mail it to the taxpayer with Letter 1477, Information Document Request Cover Letter -EP and EO, listing the document(s) being enclosed with the letter.
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