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4 - Erroneous AbatementThe timely filed TC 150 return for TY 2018 is determined to be a nullity. The valid taxpayer filed a return reporting tax of $.00 and withholding of $2,500 which posted as a TC 976. Form 14039 is included with the return. The ASED for the valid return is expired. Based on the original return, the account shows TC 150 tax of $5,000, and withholding of $6,000. A CP 2000 proposing a tax increase of $2,000 based on unreported income is issued to the valid taxpayer’s last known

Closing Letter Paragraph Selections

Internal Revenue Manual Part 25. Special Topics · 2026-10-03 edition · updated 2026-10-04 · United States

(1) To ensure the taxpayer receives a quality response by providing accurate and professional communication, you must review all paragraphs included prior to issuing a closing letter. See IRM 25.23.4.18.1, General IDTVA Letter Procedures, for additional information.

(2) There may be instances when selectable paragraphs contain language that does not apply. When this occurs, select an open paragraph, to provide only the language that is appropriate. When necessary, a floating paragraph (*) may be used to ensure all information is included and communicated clearly.

(3) Special paragraphs are those that are required for specific account circumstances. They are identified as special paragraphs and are included in the applicable IRM, where appropriate. You may need to include one or more special paragraphs in addition to the paragraphs selected for your closing letter.

(4) Refer to the paragraphs below for recommended use of open and special paragraphs in place of selectable paragraphs which may include inaccurate information for certain case types when issuing a closing letter. You may use a selectable paragraph, special paragraphs listed in the table below, or similar verbiage for various IDT case types, as appropriate, depending on the facts and circumstances of the case.

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▸Contents — Internal Revenue Manual Part 25. Special Topics
Internal Revenue Manual Part 25. Special Topics

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