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Dispute Resolution

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

The exam group manager has two options for resolving disputes with a reviewer's recommended course of action:

Contact the reviewer to discuss the case. Document the outcome of the discussion in the Form 5457. Have the examiner complete any agreed upon actions. Sign the Form 5457 and return the case to the reviewer.

Complete the Form 5457 documenting the disputed items and why the group won't take the course of action. Sign the Form 5457 and return the case to the reviewer.

Reviewer: Upon receipt of the case file:

Review the Form 5457 and the case file.

Determine whether to agree with the group manager.

Sign the Form 5457, checking the applicable entries in boxes 8 and 9.

Reviewer: If in disagreement with the group, contact the mandatory review or technical group manager. Provide a copy of the Form 5457. Discuss the case.

Mandatory Review or Technical group manager: Schedule a call with the exam group manager and his/her area manager. Document the discussion and any resolution agreed upon. If the parties can't agree upon a course of action, the Director of the functional examination program makes the final decision on the issue.

Mandatory Review or Technical group manager: Convey the directions to the reviewer, who either prepares a correction memorandum to return the case or proceeds to make any necessary corrections.

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