Skip to content

If...›Note:

Return of case to Examination Group

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

Reviewers return cases to the examination group in Status Code 12 on RCCMS, with the mandatory review or technical manager’s concurrence, when any of the following conditions exist:

Major technical deficiencies.

Significant computation errors.

Seriously underdeveloped issues.

Clear evidence of an incorrect determination made or a seriously underdeveloped case.

"Clearly defined substantial" errors based on an established IRS position during the exam. "Clearly defined" means the error is plain and not vague or uncertain. "Substantial" refers to the dollar amount of tax that we wouldn’t assess if we don’t return the case.

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — Internal Revenue Manual Part 4. Examining Process

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.