 |
8.6.2.7
(10-18-2007)
Settlement Computations as Part of ACM
-
Except as noted below, whenever adjustments to the prior determination are recommended, the settlement computation is prepared
setting forth the resulting tax liability and the necessary underlying computations.
-
The settlement computations are attached to, and become part of, the administrative file. A copy is also part of the ACM and
one must be included in the local office file.
-
The following forms are generally used in settlement computations:
-
Form 3610, Audit Statement
-
Form 5278, Statement-Income Tax Changes
-
Form 4862, Statement of Income Tax Changes (rarely used).
-
A settlement computation is not required in the following situations unless needed for other computation purposes:
-
the findings of Compliance are sustained in full.
-
the findings of Compliance are completely reversed.
-
a "split issue"
settlement in which a settlement computation is not feasible.
-
a Statutory Notice of Deficiency issued which adequately covers all adjustments.
-
the determination in the Notice of Deficiency is agreed in full.
-
the only issues in the case involve exempt status, private foundation classifications, or employee plan qualification questions.
-
Ordinarily settlement computations are not required in an unagreed docketed case, but if the AO raises a new issue or concedes
an issue, one might be necessary.
-
For some cases, Form 3623, Statement of Account, is prepared and attached to the settlement computation. See IRM 8.17.3, Preparing
a Statement of Account.
|
|
|
