Note:

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

For this reason, it is advisable to include Form 872 with the 30-Day Letter if 15 months or less remain on the statute.

If the taxpayer refuses to extend the statute, the taxpayer basically forfeits their Appeal rights. Prepare the 90-Day Letter package (SNOD) using Letter 531-B (DO NOT SEND) and process to Mandatory Review to issue.

If the statute of limitations will expire within 12 months and the taxpayer refuses to extend the statute of limitations, close the case to Mandatory Review to issue the 90-Day Letter package.

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▸Contents — Internal Revenue Manual Part 4. Examining Process

Internal Revenue Manual Part 4. Examining Process

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