Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
To participate in FTS, the taxpayer must consent, pursuant to IRC 6103(c), to the disclosure of the taxpayer’s returns and return information pertaining to the issues being considered in the FTS process to those persons named on Form 14017.
Before submitting Form 14017 to Appeals:
The examiner must write up all unagreed issues under the FTS process. EP Examiners will prepare a Revenue Agent Report (RAR) per IRM 4.70.14.2.1.1, Revenue Agent Report. EO Examiners will write up issues in a RAR format using Form 5701 for this purpose. Add Form 886-A if more room is needed.
The taxpayer must prepare a full written response explaining their position on each issue.
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