Note:

Normally ITG regards any proposed change to a case involving net additional tax of $10,000 or more, regardless of the years involved, as substantial. Don't consider penalties and interest when making this determination.

Any evidence of fraud, malfeasance, collusion, concealment or misrepresentation by the taxpayer or representative.

Administrative or procedural errors that prevent case processing.

Favorable adjustments to the taxpayer and Review can’t readily correct the report.

Other circumstances indicating that not returning the case would be a serious administrative omission.

Prepare Form 5456, Reviewer's Memorandum - TE/GE, before returning a case for further development. The reviewer’s report is an official communication between mandatory review or technical groups and field groups for technical/procedural errors found in cases or for commendatory feedback.

Send the Form 5456 to the mandatory review or technical manager for approval. In the email identify the group manager and area manager.

Reviewer: For Form 5456 Correction Memos:

Update the CCR stating that the case is being returned with an explanation of the reason.

Upload the approved version of Form 5456 and any additional files prepared by the reviewer into the RCCMS Office Documents folder using the RCCMS Naming Convention.

Update the case in RCCMS to status 12.