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

For all documents secured from third parties and provided to the organization, be very careful to avoid disclosing a confidential source or making an unauthorized disclosure.

  1. Newspaper articles concerning the organization clipped from the paper by the agent.

Same as in item number 3.

  1. Internet articles or information concerning the organization downloaded from the Internet by the agent.

Provide copies of the downloaded information to the organization with a cover letter or IDR requesting comments on the accuracy of the information. If copies are sent by letter to the organization, send it certified. If hand- delivered to the organization with an IDR, ask the receiving person to acknowledge receipt by signing a copy of the IDR to be retained by the IRS. Make certain that copies of the downloaded information are attached to the copy of the IDR retained by the IRS.

  1. Copies of the organization's cancelled checks provided to the agent by a former employee of the organization.

To protect the identity of the former employee, make a written request for the organization to provide copies of the cancelled checks.

  1. A copy of a rental agreement between the organization and a related IRC 501(c)(3) organization for the use of the organization's facilities provided to the agent by the related organization.

Request a copy of the contract from the organization or provide a copy to the organization with a written request that the organization confirm that it is a true copy of the contract.

  1. A letter sent to the Internal Revenue Service by the organization a week after the final adverse determination letter was mailed to the organization.

None. There is no way to include documents received after the issuance of the final adverse determination letter in the administrative record. However, send the letter for association with the files in the case.

  1. Documents that substantiate the revocation and enhance the Service's chances of sustaining the issue that were submitted to the Internal Revenue Service by a third party the day after a final revocation letter was mailed to the organization.

None. There is no way to include documents received after the issuance of the final adverse determination letter in the administrative record. Collect the information and call attention to it by memo or otherwise.

  1. Workpapers and computations prepared by the agent.

Use either of two methods to include workpapers in the administrative record: (a) Mail a copy of the workpapers to the organization with a cover letter requesting comments. (b) Provide a copy of the original workpaper to the organization during the audit and request a receipt of acknowledgment.

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