TEB Technical – Final Adverse Determination

If the issuer or authorized representative doesn’t request an administrative appeal of a proposed adverse determination to Appeals, issue the appropriate final adverse determination letter: Letter 4409, Notice of Final Adverse Determination; Letter 905, Final Partial Claim Disallowance; Letter 906, Final Full Claim Disallowance; or Letter 5677, TEB Arbitrage Claim Notification of Final Adverse Determination, by certified mail with a request for return receipt.

Field Exam group manager forwards a copy of this letter to the Bondholder Referral Coordinator, if applicable.

For a conduit financing resulting in a final adverse determination, determine whether the conduit borrower is under exam by another operating division or another TE/GE function. If the conduit borrower:

Is under examination, inform the appropriate operating division of the final adverse determination and coordinate as needed to consider any impact on the conduit borrower's tax matters.

Isn’t under examination, refer to the appropriate operating division or other TE/GE function to consider any impact on the borrower's tax matters.