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

The FTS AO updates the FTS Report after the FTS session with the developments of the session.

Generally, the FTS AO considers only those issues outlined in the FTS Report, except by mutual agreement of the parties.

If the taxpayer presents information during the FTS session that wasn’t previously presented during the examination, the FTS AO adjusts the targeted completion date to give the appropriate IRS officials time to evaluate the information.

During the FTS session, the FTS AO may propose settlement terms for any or all issues, and may consider settlement terms proposed by either party.

If the parties resolve any disputed issue at the conclusion of the FTS session:

The parties and the FTS AO sign the FTS Report acknowledging acceptance of the terms of settlement for purposes of preparing computations.

You process the case under normal case processing procedures.

The signature of the parties on the FTS Report doesn’t:

Constitute a final settlement.

Waive restrictions on assessment.

Terminate consents to extend periods of limitation.

Start the running of any periods of limitation.

Constitute agreement to close the case.

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