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8.4.3.5
(11-02-2007)
Recomputation Under Rule 155
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If the United States Tax Court requires a recomputation of tax in a tried case, they will request a Rule 155 computation (the
name comes from the Tax Court's Rules of Practice). Counsel will send the administrative file to Appeals using Form 1734,
Transmittal Memorandum, and request recomputation of the petitioner's tax liability.
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Appeals Processing Services (APS) will send the complete file to the Tax Computation Specialist (TCS) function.
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TCS will follow the procedures found in IRM 8.2, Settlement and Rule 155 Computations.
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After the recomputation is completed, TCS will send the administrative file, with the completed Rule 155 computation, back
to APS for forwarding to Counsel.
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APS will:
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Prepare Form 2828 or locally required transmittal memorandum indicating return of the administrative file to Counsel. Send
the administrative file, including the recomputation, to Counsel.
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Retain a copy of the transmittal and a copy of the Rule 155 computation in the office file.
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Transmit the administrative file to Counsel and establish a follow-up tickler control until receipt of the administrative
file is acknowledged.
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