• Issues are fully developed; • The taxpayer has stated a position in
Internal Revenue Bulletin 2006-36 · 2026-10-03 edition · updated 2026-10-04 · United States
writing (or filed a small case request for cases in which the total amount for any tax period is less than $25,000, as described in Publication 5, Your Ap- peal Rights and How To Prepare a Protest If You Don’t Agree) ; and
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