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Employment Tax Unagreed Cases

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

Refer to the following IRMs for unagreed cases:

IRM 4.23.10.16, Unagreed Employment Tax-Examination Reports, provides general instructions on procedures to be used for unagreed employment tax returns.

IRM 4.23.22 - Unagreed Employment Tax Case Procedures

This section provides information about additional procedures that must be followed, and additional documents included in case file prior to closing:

Examiner’s rebuttal to taxpayer’s protest

Taxpayer’s protest

Current AMDISA and BRTVU or BMFOLT

Report forms:

Form 2504, 2504-S or 2504-T, Agreement to Assessment and Collection of Additional Tax and Acceptance of Overassessment

Form 4665, Report Transmittal

Form 4666, Summary of Employment Tax Examination

Form 4667, Examination Changes (FUTA)

Form 4668, Employment Tax Examination Changes

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