Paper Case File Assembly

Some cases with unique circumstances such as fraud or specific requests from management, Appeals or Counsel might justify closing with a paper case file.

If a paper file is warranted, document your CCR with the specifics warranting a paper case file and follow these paper case file assembly guidelines.

Follow notation instructions for Form 3198-A, TE/GE Special Handling Notice in IRM 4.70.14.4.2.2(4) to generate a paper Form 3198-A.

Follow the instructions for the RCCMS Case Closing Record input in IRM 4.70.14.4.5, Completing Special Handling Notice 3198-A, and IRM 4.5.2, TE/GE Examined and Non-Examined Closures, to generate the applicable closing record Form 5599, Form 5650 (EP Form 5500 or NRU exams) or other closing record as appropriate.

Except as indicated, use a brown or manila folder for a paper examination case file.

Use red folders for short statute cases.

Use pink folders for claims.

Use a separate case file folder for each type of MFT. You can place multiple years of the same MFT for one t/p in one folder.

EP and EO: For declaratory judgment cases, maintain a separate Administrative Record file folder.

Place whistleblower and other confidential information in a "To be Opened by Addressee Only" envelope with a TD F 15-05.11, Sensitive But Unclassified (SBU) Cover Sheet (Catalog Number 56033J). Place the envelope in a separate folder with the same cover sheet. Do not include whistleblower documents in RCCMS and continue to maintain them separately from the examination case file (paper or electronic.)

Front Outside of the paper case file should include cover documents (corresponding with TE/GE Naming Convention category 1):

Special handling notices

Transmittal documents

Reviewer’s Memos

Responses to Reviewer’s Memos

Left Inside of the paper case file should include non-disclosure/administrative documents and checksheets (corresponding with TE/GE Naming Convention category 2):

Internal administrative documents

Referral documents

Case checksheets

Other miscellaneous forms or documents not indexed to workpaper summary sheet in the workpaper section

Right Inside of the paper case file should include closing letter and/or RAR and attachments, working Return, POA, statute extensions, remittances and related documents, CCR, workpaper summary, case file workpapers, and correspondence with taxpayer/representative (corresponding with TE/GE Naming Convention categories 3-6):

Category 3: Closing Letters 30-day Letters for unagreed cases Taxpayer Protests to Appeals Rebuttals to Protests Closing Agreements All attachments to closing letter and/or RAR (e.g., Forms 4549, 4549-E, 2504, 886-A, 870, etc.)

Category 4: Original return/RICS return under examination Taxpayer’s copy of Return SFR package Dummy return Forms 2848/8821 Statute extensions (Forms 872, SS-10, etc.) Form 3244-A Current IDRS Prints (within 30 days of closure)

Category 5: Case Chronology Record (CCR) Workpaper summary ( Forms 5773, 5773-A, 4318 and TEB’s workpaper summary document) All workpapers referenced on the workpaper summary Internal correspondence emails with your manager, Counsel, K-Net and specialists

Category 6: Correspondence to and from the taxpayer/representative Information Documentation Requests (IDRs) Taxpayer provided documents Summons