Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
This only applies for the years in which the IRA-based plan is determined to be non-compliant.
You and your manager determine which Form 1040 discrepancy adjustments to pursue (such as highly compensated participants or non-highly compensated participants with significant income tax adjustments).
Follow the procedures in IRM 4.70.15.4.5, Preparation of the Discrepancy Adjustment Package, when you/manager decide to make a Form 1040 discrepancy adjustment.
You prepare the 30-Day letter packages for any Form 1040 discrepancy adjustment related to an IRA-based plan will be prepared and mail them.
Follow the procedures in IRM 4.70.15.7.1, Taxpayer Disagrees, if the taxpayer files a Protest to Appeals or doesn’t agree with the proposed discrepancy adjustment within the allotted time-frame.
When you close a discrepancy adjustment to Mandatory Review before you forward the discrepancy adjustment case to issue the 90-Day Letter, you’re strongly encouraged to close the related NRU paper and the NRU RCCMS case file(s) to Mandatory Review as a ride-along case. Include all supporting documentation for the discrepancy adjustment (such as the plan sponsor generated documents) in the case file.
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