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TEB - Resolutions Involving Specified Amounts

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

In certain exams, the examiner, specialist, group manager or Committee may recommend a resolution be conditioned on payment of a specified amount. Generally, such an amount is only appropriate when described in a formal closing agreement program or in a Notice or an Announcement.

The specified amount is generally listed in the program, but if not listed, it must be less than $5,000. Specified amounts have included:

An amount equal to the par amount of the bonds held by the issuer multiplied by a specified percentage and then multiplied by a number of specified time intervals (for example, monthly).

The amount required to be paid for a request for a closing agreement, as published annually in the Internal Revenue Bulletin (for example, the amount for 2021 based on paragraph (A)(3)(d) of Appendix A to Rev. Proc. 2018-1 would be $38,000 (for requests received after February 3, 2021).

An amount (for example, $500) multiplied by a number of specified time intervals (for example, monthly). d. A fixed amount per bond issue (for example, $5,000 in exam cases).

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▸Contents — Internal Revenue Manual Part 4. Examining Process
Internal Revenue Manual Part 4. Examining Process

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