ITG - Concluding the Examination
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
Meet with the tribal official(s) to inform them of any findings, recommendations or proposed tax adjustments when you finish your examination.
Provide your employee information again when you issue the report. Refer to IRM 4.10.1.6.9, Providing Taxpayers with Employee Contact Information.
Issue the examination report and attach Pub 3498, The Examination Process, or Pub 5146, Employment Tax Returns Examination & Appeal Rights.
Discuss proposed adjustments with the taxpayer and/or taxpayer’s representative including the law, regulations, rulings and court decisions supporting your conclusions.
Solicit agreement
Provide workpapers, if requested.
On agreed cases, request full payment of tax, penalties and interest.
If taxpayer indicates an inability to pay the tax due at closing or within 120 days of the first notice, alternative payment methods should be discussed. An installment agreement should be offered if the taxpayer meets the requirements. See IRM 4.70.14.2.1.4.8.6, Installment Agreements.
If the taxpayer and/or representative do not wish to pay the deficiency immediately, explain that a statement for the deficiency plus interest will be mailed. Their cancelled check will be their receipt. Encourage them to pay using EFTPS. If they must send a check instruct them to put the entity name, EIN, tax form number and tax period on the face of the check itself. Secure waivers as needed and close the case.
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