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TEB – Cases Closed to Appeals

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

If the examiner's group manager decides to transfer the case to Appeals before the TLS determines the rebuttal sufficiently addresses the issuer's protest, the TLS will brief the TEB Technical Manager on the case. Then, the program manager, Technical and the TEB Exam group manager will discuss whether additional case actions are required before transferring the case to Appeals.

Examiner: provide any subsequent revisions to the rebuttal to the issuer and/or the representative before transferring the case to Appeals.

Examiner: transfer case to Appeals.

Confirm the RCCMS case file sent to Appeals includes copies of the following documents:

The technical advice memorandum, if any

All information received by TEB from the issuer regarding the bond issue or Arbitrage Rebate Claim Denial.

All workpapers related to TEB’s examination of the bond issue or Arbitrage Rebate Claim Denial.

TEB’s written Proposed Adverse Determination or Arbitrage Rebate Claim Denial.

The issuer’s written protest.

TEB’s response to positions stated by the issuer in its protest.

Ship any paper case file items to Appeals via Form 3210, Document Transmittal, following the instructions on the Appeals Case Routing Addresses and Instructions page.

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

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