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Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
In these instances contact the Manager, EP Mandatory Review to discuss the short statute and the need to issue a 90-Day Letter. Document the CCR accordingly.
When the 30-Day Letter is mailed and the taxpayer timely files a valid protest to Appeals, close the case to Appeals. See IRM 4.70.14.7, Closing Cases to Appeals.
If the taxpayer agrees and files Form 5330, Form 990-T or signs Form 870-EP, close the case per IRM 4.70.14.2.1.2.4.6, EP – Processing Agreed Forms 5330 and 990-T, and process any returns or checks received per IRM 4.70.14.3, Payment Processing.
If the taxpayer does not protest within the 30-day period, but previously indicated his/her intention to do so, you may send Letter 923-A to the taxpayer to allow an additional 15 days to file a protest. Send Letter 923-A no later than seven calendar days after the response date of the original 30-Day Letter.
If the taxpayer fails to timely file a valid protest to Appeals, close the case to Mandatory Review to issue a 90-Day Letter.
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