Skip to content
ChatProjectCodes

If...

Note:

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

Notice 1036 contains early release copies of the withholding tables and includes the backup withholding rates (for example, the backup withholding rate in effect as of January 2018 is 24%).

Step 4. Compute the present value of the amount calculated in Step 3 for each calendar year per IRM 4.70.14.2.1.5.9.14, TEB – Excessive Arbitrage Profit, by assuming it was due on April 15 in the following calendar year.

Step 5. Add the present value amounts determined in Step 4 for all calendar years. This is the taxpayer exposure for exam closing agreements.

Get a plain-English answer with a citation back to this text.

Ask AI about this code
Export this section
▸Contents — Internal Revenue Manual Part 4. Examining Process
Internal Revenue Manual Part 4. Examining Process

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.