IRS Reconsideration of Notice of Deficiency During Suspense Period

8.2.2.5  (10-24-2007)
Reconsideration of Notice of Deficiency During Suspense Period

  1. If the Appeals Team Manager (ATM) or Appeals Area Director decides to grant further consideration of a case in the suspense period, reactivate the case. When notified the case is being reconsidered:

    1. Remove the administrative file from suspense and give it to the Appeals Officer.

    2. Place a "chargeout" in the file where the administrative file is removed. Show the name of the case, the Appeals Officer, and the date this action is taken.

  2. If no agreement is reached after consideration or reconsideration in the suspense period:

    1. Ensure there is an approved informal memorandum and a signed closing letter for the unagreed case.

    2. Date the memorandum;

    3. Date and mail the closing letter.

    4. File the original memorandum and copy of the closing letter in the administrative file; file copies of each in the office file.

    5. Re-file the administrative file behind "Letter Issued—Awaiting Taxpayer’s Action File" and remove the charge out slip.


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