Reminder:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
TEGEDC generally requires up to 45 days to provide legal advice.
If you had not issued a 30-day letter by the time a statute date is imminent, do the following:
Consult with Area Counsel whether to issue a substitute transmittal letter in lieu of a 30-day letter.
If the substitute transmittal letter is to be issued, determine the content, format, timing and issuance of the letter with Area Counsel.
Include in the transmittal letter why a standard 30-day letter can’t be issued if so advised by Counsel.
Include the most recent Taxpayer Advocate Service (TAS) paragraph in the cover letter by reviewing TAS paragraphs in recently published 30-day letters.
Enclose your report of examination if so advised by Counsel.
Issue the substitute transmittal letter transmitting your report of examination, either before or on the day of issuance of the 90-day letter to which it pertains.
Close the imminent statute case to Mandatory Review for suspense and storage within five (5) business days of issuance of the 90-day letter.
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