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

A new 30-day letter for a tax change is unnecessary if there are no new issues and the revised report is favorable to the taxpayer.

Doesn't change your conclusion, and constitutes a formal protest to Appeals.

Prepare a rebuttal to the protest.

Issue the rebuttal to the taxpayer.

Close to Mandatory Review using DC 07, Unagreed-Protest to Appeals (RCCMS - 601).

See IRM 4.70.14.7, Closing Cases to Appeals, for procedures on how to prepare a rebuttal.

Doesn’t change your conclusion, and doesn't constitute a valid formal protest to Appeals.

Prepare and send a drafted letter to the taxpayer. Give 10 days to respond.

See Exhibit 4.70.14-8, Incomplete Protest Returned to taxpayer - Suggested Language, for suggested language.

Doesn’t change your conclusion, and the taxpayer filed a petition to Tax Court.

Send an individually designed letter, approved by the GM, notifying the taxpayer that the petition is premature, and they have the option of filing a formal protest. Give 10 days to respond.

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

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