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Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
The Committee may seek advice from the designated counsels from TEGEDC and Chief Counsel when questions of procedure or content make it appropriate, such as when proposed terms of a closing agreement are substantively modified from the model agreement.
If the Committee, after consulting the Chief Counsel ad hoc members, determines that changes are needed to make the agreement enforceable, they share those changes with the examiner and the group manager. Generally, the examiner must make those changes. If the Committee concludes that the proposed resolution is inconsistent with other TEB closing agreements, or they recommend other changes, they list the changes and their reasons on the Closing Agreement Approval Document and discuss alternative resolutions with the group manager and the examiner. After review and any discussion, the Committee sends the Closing Agreement Approval Document and attached documents to the TEB Program Manager.
If the TEB Program Manager approves the closing agreement, he/she sends the Closing Agreement Approval Document and attached documents to the Field Exam group manager and examiner. If the TEB Program Manager doesn’t agree, he/she discusses any concerns with the Committee and the group manager.
The TEB Program Manager may send the exam case back to the examiner for further consideration and resubmission. The TEB Program Manager may determine that it is in the best interest of TEB to proceed with execution of the agreement without full Committee concurrence. In such a case, the TEB Program Manager must notate such on the Closing Agreement Approval Document. The TEB Program Manager may make or approve changes in the closing agreement which don’t impact enforceability or deviate from the model closing agreement language without Committee review or any special notation on the Closing Agreement Approval Document.
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