Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
If you issue one or more Letters 2511 and there are no other issues, prepare and issue Letter 1744 as the closing letter for the annual information return (or e-Postcard) examination. In the attached Form 886-A, make reference to the agreed adjustment under a separate examination report.
If the taxpayer protests a formal examination report, review the reply and proceed as follows:
If the additional information provided...
Then...
Changes your conclusion, resulting in a no change
Rescind the report.
Close as a no change.
See Exhibit 4.70.14-1, Closing Letters for No-Change Cases, for the appropriate closing letter to be issued.
Changes your conclusion, resulting in a modified adjustment
Change the report and issue the revised formal examination report, unless rescinding the report and considering a FTS for the unagreed issue.
See IRM 4.70.14.2.3, Fast Track Settlement Procedures.
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