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TEB – Arbitrage Refund Claims

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

Certain refund claims are subject to mandatory review:

Approved refund claims "exceeding" ” $2 million

Unagreed refund claims

The TEB Technical Manager assigns one or more TLS from Technical to perform mandatory reviews.

The TLS reviews the refund claim using the following procedures and may discuss any questions with the examiner:

Action

Explanation

Review the refund claim case file to identify errors or issues of particular significance.

Your review is mostly to:

Confirm the examiner’s determination for technical accuracy.

Verify the supporting documentation is included in the file.

Perform a cursory review of the unagreed issue(s) in the case to determine the scope of your review. Then, review the underlying documentation.

For example, you may decide to limit your review to the issue that’s the basis for a denial. You may also:

Review arbitrage computations and supporting documentation to confirm they’re substantially correct and technically accurate.

Test computations for select funds and/or investments to independently confirm the calculation method's accuracy.

Review the case file to identify any factors that might substantially impact the calculations’ accuracy or otherwise affect the claim’s validity.

Document any needed case development and return the refund claim case to the examiner.

If you determine that additional development is needed to concur with the examiner’s determination.

Close the refund claim case

If you agree with the TEB Exam determination.

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▸Contents — Internal Revenue Manual Part 4. Examining Process

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