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Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
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It’s recommended the reviewer first review the file to see if TEGEDC previously had been involved in advising Exam in the case. The file should be sent to the TEGEDC office attorney who originally worked on the case.
After consulting the map, prepare a Form 3210 and Form 9814 to ship any paper case file items to the identified TEGEDC office. For a list of TEGEDC office addresses, see http://ccintranet.prod.irscounsel.treas.gov/OrgStrat/Offices/TEGE-DC/Pages/AreaCounselOffices.aspx.
Double package any paper case file per IRM 10.2.13.4.4.1. Send any paper case file to TEGEDC.
When TEGEDC returns the file, acknowledge receipt on the Form 3210 and return the form. Retain a copy of the Form 3210 as per local procedures.
Review the memorandum from TEGEDC. Make any corrections to the 90-day letter package as directed. If you have questions, consult the memo author.
Anytime an EO or FSL specialist, reviewer or field manager discusses an issue with TEGEDC it is documented in the file (such as the case chronology record), indicating TEGEDC had been consulted, the name of the attorney, contact number, etc.
For final adverse determination letters, grade 12 reviewers and above may authorize and sign. If needed, make copies of the letters for distribution to powers of attorney.
Print and date stamp the completed final 90-day letter package. Use the method provided in IRM Exhibit 4.8.9-2, Computation of Last Day to File a Petition with United States Tax Court and Computation of Default Date, to determine the last day for filing a petition.
For statutory notices of deficiency and notices of worker classification determination, signature stamp the letter with the Director, EO Examinations signature.
Make additional copies of the 90-day letter as indicated in the enclosure statements at the end of the letter. Make sure to save the final 90-day letter package in RCCMS.
Prepare the 90-day letter package for mailing, either certified for domestic addresses, or registered for foreign addresses:
Follow local procedures for obtaining postage and mailing the package.
Obtain a stamped certified or registered mail receipt. (For countries that don't permit registered mail, get a certificate of mailing).
Complete Postal Service (PS) Form 3877, Firm Mailing Book for Accountable Mail.
Scan the receipt and save with the 90-day package and administrative record (if applicable) in RCCMS.
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