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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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There may be circumstances that warrant referring a bondholder or other party to the transaction to another business unit under current referral procedures. Consider, among other factors, whether the bondholder holds a significant amount or percentage of the bonds. Consult your manager to determine if a referral is warranted.
If your manager concurs and the PM approves closing the case pursuant to this subsection, and there is no indication that there is a compliance problem with the bonds:
Issue closing letter (Letter 649, Examination Closed -, No Change)
Close on RCCMS with disposal code 107, No Change.
This resolution method does not apply if:
The bonds are redeemed with other tax-advantaged bonds.
The bonds are direct pay bonds.
The issuer did not make appropriate rebate payments on the bonds.
The issuer asks to negotiate or enter into a closing agreement. (See IRM 4.70.14.2.1.5.9, Tax Exempt Bonds Closing Agreements, if they request a closing agreement.)
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