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.
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