Note:

When reviewing directions in IRM 4.8.9, keep in mind that TEGEDC reviews all TE/GE issued Statutory Notices of Deficiency before they’re issued, and that TE/GE Closing Group handles the notices in lieu of Small Business/Self Employed (SB/SE) Centralized Case Processing (CCP) units.

EO - For excise taxes involving a second tier tax for failure to correct without full correction, IRS must determine the second level at the time liability for the first level is determined. It is therefore included in any notice of deficiency, regardless of whether the first level tax is agreed. The second level will be abated if correction is made after the mailing of the notice plus extensions that apply. See IRC 4961(c) for suspending the collection period for the second tier tax to allow the taxpayer to seek judicial review of the assessment.