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

The FTS AO updates the FTS Report after the FTS Session with the developments of the session.

Generally, the FTS AO will consider only those issues outlined in the FTS Report, except by mutual agreement of the parties.

If the taxpayer presents information during the FTS Session that the taxpayer had not previously presented during the exam, the FTS AO will adjust the targeted completion date to give the appropriate IRS officials time to evaluate the information.

During the FTS Session, the FTS AO may propose settlement terms for any or all issues and may consider settlement terms proposed by either party.

If the parties resolve any disputed issue at the conclusion of the FTS Session:

The parties and the FTS AO sign the FTS Report acknowledging acceptance of the terms of settlement for purposes of preparing computations.

The case is processed under normal case processing procedures.

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