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8.7.1.1
(11-06-2007)
Introduction to Cases with Special Issues
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This section provides general information about special issues found in Appeals cases, specifically Personal Holding Company-Deficiency
Dividend, Restricted Interest, and Accumulated Earnings. It also provides information on requesting assistance from Appraisal
Services within Appeals and the case procedures for jeopardy assessment, termination assessments, and refund suits.
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The section goes into detailed procedures on the provisions of IRC 7430, covering cases with Litigation and Administrative
Costs at issue.
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The information covers procedures applicable to Appeals Officers, Appeals Team Case Leaders, Tax Computation Specialists and
Appeals Processing Services employees.
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