Note:

All cases subject to declaratory judgment under IRC 7428, require a formal report.

Don’t issue a report to a taxpayer prior to discussing findings and proposed issues with the taxpayer. Exceptions to this rule are for the following:

No-show / no-response appointments.

Uncooperative taxpayers.

When additional records are provided for your consideration.

The RAR provides more details as to facts, law and argument than the initial report. The formal examination report:

Combines a 30-day letter with an RAR.

Transmits the RAR to the taxpayer.

Eliminates consideration for a FTS (unless properly rescinded).

Requires managerial approval prior to issuance.

Requires issuance via certified (domestic) or registered (international) mail.