Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
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Groups holding short statute cases prepare and issue the 90-day letters. The Area Manager approves and signs 90-day letters. Examiners work directly with Counsel on cases with imminent statute.
ITG - The ITG Technical Group is responsible for the review of unagreed cases without protest that require the preparation and delivery of a statutory notice of deficiency, full or partial claim disallowances and manager requests for review.
TEB -
Issuer protests to Form 886-A, Explanation of Items, and the examiner’s rebuttal even if documentation was previously reviewed in a prior technical review. See procedures in IRM 4.70.14.6.10.1, TEB – Final Adverse Determination
Arbitrage claims: o Allowed refund > $2M o Disallowed (full or partial)
With Senior Manager approval, group managers may request a specific case be reviewed.
Management may identify other cases as being subject to mandatory review, as problems or other special needs arise.
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