Note:

Update the Administrative Record and Index for all correspondence you sent to the taxpayer/POA while the case is in MR.

TEB: Print and assemble a physical case file and administrative record for all cases sent to TEGEDC if a taxpayer filed a petition to Tax Court. Contact the examiner for assistance, if needed, to create the administrative record if the exam group closed the case with taxpayer agreement to the adverse action.

Computations of tax, penalties, and interest are correct and included in case file (if applicable).

If unagreed, the case file documents reasonable effort by examiner to reach an agreement using available correction and settlement programs or early referrals to Appeals.

Management involvement is documented in the case file.

Proper completion of internal examination procedures, clearly documented in workpapers, Form 5773, Workpaper summary, Form 4318, Examination Workpapers Index and case chronology. This includes required forms, letters and documents. EO: The case is PATH Act compliant (if applicable).

In managing fraud suspense cases, follow IRM 4.70.14.4.2.1.1, Paper Case File Assembly, for paper records that must be maintained for cases with criminal fraud potential.

During the review, ensure the case contains properly:

Executed Forms 872, Consent to Extend the Time to Assess Tax or 872-A, Special Consent to Extend the Time to Assess Tax, if needed.

Completed Form SS-10 Consent to Extend the Time to Assess Employment Taxes.

Assembled tax returns for all years on the Audit Inventory Management System (AIMS)/RCCMS.

Documented Forms 5773, TE/GE Workpaper Summary, and Forms 5464, Case Chronology Record.