Reminder:
Internal Revenue Manual Part 25. Special Topics · 2026-10-03 edition · updated 2026-10-04 · United States
A case reassigned to the Centralized Distribution Site (CDS) in error may be returned to the originating site.
(7) There may be instances when you do not have 3 years of returns filed. If your research supports a determination of valid or invalid, refer the case to your lead/manager for concurrence. The CSR/TE must input a case note documenting their determination prior to requesting lead/manager concurrence. The lead and/or manager cannot concur with a determination that is not noted on the case. See the following example:
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