Part IV. Applicable Federal Interest Rates.
SECTION 4. PROCESSING AN EARLY
Internal Revenue Bulletin 1996-2 · 2026-10-03 edition · updated 2026-10-04 · United States
REFERRAL REQUEST
.01 Approving or denying the re- quest for early referral. An approval of an early referral request requires the concurrence of both the District Director and the ARDA. The early referral request will be processed as follows:
(1) The CEP case manager will send the taxpayer’s request for early referral to the District Director. The CEP case manager also may include a recommendation that the early referral request be approved or denied.
(2) The District Director will note the district’s approval or denial and forward the request, whether approved or denied, to the ARDA for consideration.
(3) The ARDA will note his or her approval or denial of the early referral request and will return the request to the CEP case manager.
.02 Notification of action. The CEP case manager will advise the taxpayer of the decision generally within 45 days of receipt of the request. If any issue is approved, the CEP case manager will forward the early referral file for this issue to Appeals as described in section 5 below. If the request for early referral is denied with respect to
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any issue, the taxpayer retains the right to pursue the administrative appeal of any proposed deficiency related to that issue at a later time.
.03 No Appeal. There is no formal taxpayer appeal if the early referral request is denied in whole or in part; however, the taxpayer can request a conference with the organization(s) that denied the early referral request.
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