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Internal Revenue Manual Part 8. Appeals · 2026-10-03 edition · updated 2026-10-04 · United States

At the time the 100-day suspense period expires, there are 50 or fewer days remaining on the 150-day statute date. Prompt action must be taken to complete the assessment and close the case before the expiration of the statute

The DECENT Report is used to alert APS that a decision has been entered. Appeals may have only 150 days to make the assessment. If necessary, APS will locate the administrative file to ensure the assessment is made and the case is closed prior to the 150-day period.

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▸Contents — Internal Revenue Manual Part 8. Appeals

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