Special Procedures for Notices of Determination of Worker Classification or Section 530…

IRM 4.23.10.10, Preparation of the Employment Tax Examination Report, provides general information about IRC 7436, which provides Tax Court review when a part of the examination includes a controversy involving a determination that at least one worker should be reclassified as an employee of the taxpayer for employment tax purposes and/or that the taxpayer is not entitled to relief under section 530 of the Revenue Act of 1978.

Special procedures must be followed when unagreed issues are subject to IRC 7436.