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

The Form 5773-A incorporates the time spent on all years of the examination cycle.

The date the examination was completed

Form 5773 or Form 5773-A is not a substitution for administrative workpapers or supporting workpapers to document the identification, development, and resolution of selected examination issues.

EP/EO: Form 10329

Form 10329 must be completed and saved in the RCCMS Office Documents Folder when there are related returns and case files. This Form helps all users of the file including the closing unit to identify all related case files that should be processed together.

Complete the following fields on Form 10329:

i. List your group number in the Area Office section. ii. Starting with the primary return and continuing to include all related returns – each year individually, list:

Taxpayer name – this may be different for each type of return.

TIN – this will be different for different taxpayers.

MFT – each return type has its own MFT code.

Tax Period – each line item should represent one, single tax period.

Statute of Limitations – each line item should list the statute of limitations at the time of case closure. If you received an extension, list the extended statute date. If you alpha coded a statute, list the date with the alpha indicator. It is very important that a future user of this document can quickly see what returns have potential statute issues.

3198-A Special Handling checksheet in RCCMS

TE/GE has added RCCMS functionality to document the case file for Special Handling Notice with the 3198-A Special Handling checksheet. Follow the procedures below as appropriate.

Appropriately note the following items on Form 3198-A Special Handling checksheet in RCCMS:

i. Cases subject to mandatory review. ii. Cases that require updating the BMF on Form 2363-A. iii. Cases closed based on an taxpayer's retained copy of a return. iv. Cases where an amended return was received directly from the t/p during the examination. v. Power of Attorney instructions. vi. Discrepancy adjustments cases. vii. Restricted interest cases. viii. Unagreed cases. ix. Cases with less than 270 days (9 months) until the statute of limitations for assessment expires. x. Instructions for notification of state officials. xi. Related case files. xii. Any other special instructions regarding the case that may be helpful in the closing process. xiii. The case includes proof of filing Form 990-N.

Under "Other instructions" may include, but don’t limit to, the following:

i. Form 4669 adjustments allowed by examination. ii. Wage statements secured by examiner (send originals to Social Security Administration (SSA)). iii. Delinquent Form 1099 secured by examiner (send original to Cincinnati Campus). iv. Assess Civil Penalty as indicated on Forms 8278 and 3645. v. -A freeze addressed-release freeze. vi. ASEDR5 (enter only when ALL adjustments are subject to IRC 3509 rates). vii. For declaratory judgement cases, refer to IRM 4.70.14.4.11.1, EO Declaratory Judgement Cases, for further instructions on completing 3198-A for agreed and unagreed cases. viii. For a converted return case file, refer to IRM 4.70.14.2.1.3.3, EO – Conversion of Returns, for agreed cases for further instructions.

Form 5666

Group managers and examiners may submit leads by submitting a Form 5666, TE/GE Referral or Information Report, with any supporting documents that provide details about potential noncompliance. Securely email the Form 5666 to your manager to review and forward to the CP&C Referral group at EOClass@irs.gov, if applicable. See IRM 4.5.1.6.9.2, TE/GE Referral or Information Report, and IRM Exhibit 4.5.1-12, Instructions for Preparing Form 5666, TE/GE Referral/Information Report.

Use Form 5666 to:

i. Recommend a future year examination of the same organization. ii. Recommend the examination of another person, such as potential unreported gross income. iii. Recommend the examination of a revoked organization for income tax.

The general instructions for completing Form 5666 are on the back of the form.

Procedures for considering referrals and how to process them are in IRM 4.70.11.15, Collateral Examinations and Referrals.

FSL/ET and ITG:

Form 4318, Examination Workpapers Index, is the cover sheet that indexes the administrative and issue lead sheets and supporting documents (e.g., information document requests, correspondence, case building materials). It pertains to one taxpayer and includes all tax years under examination. The conclusions on this document should correspond to the conclusions on the lead sheets, workpapers and reports.

Form 4318 is not a substitute for administrative workpapers or supporting workpapers to document the identification, development, and resolution of selected examination issues.

Use Form 9984, Examining Officer’s Activity Record, (case activity record) to document each action you take on the work assignment. Documentation includes the date, location, time charged, and an explanation of each activity or contact. The activity record should be prepared contemporaneously and provide a complete and concise case history. Write all entries factually and professionally and omit personal opinions. Other employees responsible for activity on the case must also document their actions using the same criteria listed above (for example, group manager, Technical staff, clerical staff).

TEB: Tax Exempt Bond Workpaper Summary ("TWS", also known as the Pushpin Workpaper) is not a substitute for administrative workpapers or supporting workpapers to document the identification, development, and resolution of selected examination issues.

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▸Contents — Internal Revenue Manual Part 4. Examining Process

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