Note:

While the case is in Counsel, the reviewer is responsible for protecting the statute of limitations.

When Counsel returns the case, they note recommendations in a Counsel Recommendation Memo. Upload Counsel’s memo the RCCMS case file using the TE/GE RCCMS Naming Convention "2.1 Counsel Recommendation Memo" followed by a descriptive extension.

The reviewer will:

Generally, follow the recommendations in the Counsel Recommendation Memo and document the CCR accordingly.

Only deviate from Counsel’s recommendation(s) after: i.) attempting to obtain agreement from the attorney who wrote the memo on any deviation and/or proposed alternative actions (sometimes clarification is needed and agreement is reached), ii.) discussing your reasons for deviation and proposed alternative actions, if any, with the MR manager, iii) obtaining the MR manager’s written approval.

Generally, reviewers issue 90-Day Letter packages on the cases they review. The Mandatory Review manager determines exceptions to the rules. Reviewers who don’t issue 90-Day Letters, transfer to the 90-Day Reviewer. The 90-Day Reviewer issues the 90-Day Letter package and becomes the case owner.

After getting Counsel concurrence, the reviewer emails the Mid-Atlantic EP Area Manager (with cc to the Mandatory Review Manager) the entire 90-Day Letter Package, along with the Counsel Recommendation Memo.

Note the email’s purpose in the subject line.

At the top of the email: list the entity name, the years covered, the form number and the statute date.

In the body of the email: ask the Mid-Atlantic Area Manager and the Mandatory Review manager to approve the letter’s issuance by signing the attached Form 1725 (the buck slip included in the email).

Address the buck slip to the Area Manager. Identify the taxpayer (name, plan number), issue(s), form number, years covered and the corresponding statute date(s). State whether you followed Counsel’s recommendations and, if applicable, whether you’ll send the POA a copy of the letter.