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

With the exception of IRC 4975, when a SFR posts, the year reflected should be six years from the date the SFR posted. For example, if the SFR posted on 10/21/2020, the statute date should be "10/EE/2026" .

Generally, don’t expand the examination into years beyond the field examiner’s unagreed return package. However, if you believe that pursuing a qualification issue or tax issue (income/excise) for years not covered in the examiner’s unagreed package is warranted, discuss with the MR manager.

Once you have determined a case is technically and procedurally accurate, complete 90-Day Letter processing. See IRM 4.70.14.6.8.1, EP 90-day Letter Procedures.

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