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EO – Unagreed SFR Tax Cases

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

If you issued your report of examination (30-day letter and RAR), and the taxpayer disagrees, close the case to Mandatory Review, except for:

Unagreed without protest employment tax cases (other than worker classification). The 30-day letter becomes final. Close to the EO Closing Unit for assessment.

Unagreed without protest gaming excise tax cases. The 30-day letter becomes final. Close to the EO Closing Unit for assessment.

Close the case using DC 07 (601) or DC 10 (604).

Mandatory Review or Appeals will issue a 90-day statutory notice of deficiency.

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

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