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Early Referral to Appeals

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

Taxpayers may request, under Rev. Proc. 99-28, 1999-2 C.B. 109, Early Referral of Issues to Appeals, an early referral of one or more unresolved examination or collection issues to the Appeals office. Proper issues for early referral are limited to those that:

Are fully developed.

If resolved, can reasonably be expected to result in a quicker resolution of the entire case.

Both the taxpayer and the ITG Program Manager agree.

Are part of a case where the remaining issues are not expected to be completed before Appeals could resolve the early referral issue.

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

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