Note:

If more than one person is liable for IRC 4975 excise tax with respect to any one prohibited transaction, all persons shall be jointly and severally liable, and a separate 30-Day Letter package needs to be prepared and processed for each disqualified person.

After you mail the letter, update the case to status 13 and call the taxpayer to discuss the issue(s) being raised.

The examiner’s phone call should be:

No earlier than 14 calendar days after the initial letter is mailed (unless first contacted by the taxpayer).

No later than 21 calendar days after the letter is mailed.

Verbally explain the issues either by telephone or through an arranged face-to-face meeting.

A minimum of 12 months must remain on the statute when Appeals receives the case.

It may be necessary to send out Form 872 with the 30-Day Letter to make sure Appeals has at least 12 months when they receive the case.

Take processing time into consideration when you mail out the 30-Day Letter.