Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
A "R" at the end of the docket number indicates a retirement plan case.
If the recipient of the 90-day Letter files a petition with the U.S. Tax Court:
Contact the assigned Counsel attorney with a cc to the Area Counsel attorney responsible for the case to let them know the case is being closed to Counsel through the Appeals function.
Ask the Counsel attorney if they want the Administrative Record (Form 5500 cases only) mailed directly to them (if there is a paper Administrative Record).
Prepare the case for closing.
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