DECENT
Internal Revenue Manual Part 8. Appeals · 2026-10-03 edition · updated 2026-10-04 · United States
DEFINITION: This report lists all cases in Appeals inventory in which the Tax Court has entered a decision but for which no final closing action has been recorded. This list is critical for protecting short statutes.
OBJECTIVE:
To monitor the statute on Tax Court cases which have an entered decision.
To identify and monitor decisions which have an appeal period (no waiver paragraph with deficiency).
FREQUENCY: The DECENT report will be generated and worked on a monthly basis in ACTION TODATE order.
DECENT Follow-up Number of Days: 45
PROCEDURES:
Review the statute on the entire list. You are responsible to perform follow-up on all cases prior to statute expiration.
Determine your "cut-off" date. For reports that are due monthly, use a cut-off date equal to the current date/report run date. Draw a line under the last case with a date in the follow-up column equal to your cut-off date.
Cases listed above the line are to be located. Annotate your research findings. LACTION may be used to reflect where the case is located.
If the decision has no waiver paragraph, Counsel must hold the case for the 90-day appeal period. The LTODATE may be used to record the date the appeal period will expire.
IMPACT: The DECENT report works in conjunction with the statute list.
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