EP Transfer to 90-day Reviewer

This section applies to cases transferred to the “90-Day Reviewer”; the reviewer designated by the MR manager to issue 90-Day Letter packages.

Effective on the date of transfer, the 90-Day Reviewer is entirely responsible for the case (including protecting the SOL) and its closure.

Before transferring the case to the 90-Day Reviewer:

Complete the "Person to Contact" section of the letter using the 90-Day Reviewer’s information (address, ID, and phone number).

Ensure that the following is located in the RCCMS Office Document Folder:

Entire 90-Day Letter package (excluding any pubs and notices)

Approved Form 1725 indicating the Mid-Atlantic Area Manger approved the issuance of the 90-Day Letter.

Entire 30-Day Letter package

Copy of applicable return(s), all forms, all workpapers, and all research

Copy of all correspondence Reminder: Ensure that all documents were saved to the RCCMS Office Documents Folder using the TE/GE RCCMS Naming Convention.

Ensure that the Administrative Record is correctly prepared per IRM 4.70.14.2.4.1.3.1, EP & EO Maintaining the Administrative Record File, for Form 5500 cases involving revocation or non-qualification. See Employee Plans Examination Exhibit for an Administrative Record index template.

Complete the RCCMS Closing Record. See IRM 4.70.14.4, Case A Closing.

Request transfer of RCCMS case to the 90-Day Letter Reviewer.

90-Day Reviewer: When you receive the complete case file (RCCMS files, paper case files and the 90-Day Letter package), review the 90-Day Letter package:

Immediately, if the statute of limitations expires within 45 days.

Within 10 workdays, if the statute of limitations expires in more than 45 days.

90-Day Reviewer:

Review the 90-Day Letter Package

Make any necessary minor corrections to the 90-Day Letter package.

Contact the original reviewer to discuss any significant corrections identified to see if all facts are understood and to determine if a solution can be reached. If there is a difference in opinion between the 90-Day Reviewer and the original reviewer on the type or extent of the change(s), the MR manager resolves any differences and determines if the case will be returned to the original reviewer.

If the taxpayer has a representative, make sure that all years listed on the 90-Day Letter are listed on Form 2848 or Form 8821.

Proceed to issue the 90-Day Letter.

Process the case per IRM 4.70.14.6.8.1, EP 90-Day Letter Procedures, paragraphs (18) through (26).