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Exhibit 13.1.20-2
(12-15-2007)
TAO Case Folder Assembly
A TAO case folder should be clearly tabbed and assembled in the order
listed below. The outside front of the folder should be labeled with the taxpayer
name and TAMIS case file number. Not all of the information listed below will
be relevant to the issuance of the TAO in every case. In addition, only information
relevant to the tax year(s) of the TAO should be included. Unless otherwise
indicated, copies, not originals, of all information should be submitted.
The tab headings are listed in bold and may not be all inclusive:
Left Side of Folder (top to bottom)
-
Form 9102
- Original Taxpayer Assistance Order (TAO).
-
TAO Summary Attachment
(required) - CA Facts of the case, including a detailed timeline
of case actions.
-
(SB/SE, W & I, LMSB, TE/GE, Appeals
or Counsel) Rebuttal
- Original written
appeal to the Form 9102 from the OD/Function.
-
Form 911 or Incoming Correspondence -
Copy of the Form 911, Request
for Taxpayer Advocate Service Assistance (And Application for Taxpayer Assistance
Order), or written/verbal request for assistance.
-
Hardship Validation -
Documentation
to confirm IRC § 7811 determination
of significant hardship, which may include oral statements documented in TAMIS.
-
Operation Assistance Requests (OARs)
-
Copies of OARs that have been issued.
Right side of Folder (top to bottom)
-
TAMIS
(required)
- Form 911 prints for all cases
relating to the TAO issue [ See IRM 13.1.20.2.
].
-
IDRS
(required)
- All appropriate IDRS prints (ENMOD, SUMRY, TXMOD, IMFOL, BMFOL,
INTST, AMDIS, etc.)
Note:
The starting page for each command code should
also be tabbed.
-
i-trak- Copy of any i-trak control and incoming
correspondence, if it exists.
-
Returns
- If warranted,
copies of returns (not originals), in descending order (most
recent return on top).
EXAMINATION INFORMATION
- Of the tab headings listed below, only include the
information that is relevant to the issuance of the TAO.
-
Open Exam
- Documentation
taxpayer has submitted to Exam for consideration.
-
Revenue Agent Reports (RAR)/CP2000
-
Copies of CP2000 or Revenue Agent Reports (not originals).
-
Statutory Notices of Deficiency (SNOD)
- Copies of any Statutory Notices of Deficiency.
-
Audit Reconsideration
-
Audit reconsideration support ( Form 886-H information,
substantiation of disallowed/questioned expenses, etc.).
COLLECTION INFORMATION
- Of the tab headings listed below, only include the
information that is relevant to the issuance of the TAO.
-
Notice of Federal Tax Liens (NFTL’s)
- Copies of any Notices of Federal Tax Lien filed, released
or withdrawn.
-
Collection Information Statement (CIS)
- Taxpayer financial information (Form 433A/B) including national
asset locator research.
-
Notices of Levy
- Copies
of any Notice of Levy or Release of Levy.
-
Collection Appeals Process (CAP)/ Collection
Due Process (CDP)
- Any information relating to the Collection
Appeals Process or Collection Due Process (or Equivalent Hearing), including
a copy of Form 12153, Request for a Collection
Due Process Hearing (Also included under this tab would be any response from
Appeals regarding a CDP hearing).
-
Installment Agreements (IAs)
-
Copies of any Installment Agreements.
-
Offer In Compromise (OIC) Information
- Form 656, rejection letter(s),
taxpayer appeal of rejected OIC, etc.
-
Trust Fund Recovery Penalty (TFRP)
-
Trust Fund Recovery Penalty information, including the
Form 4180, Report of Interview with Individual Relative to Trust
Fund Recovery Penalty or Personal Liability for Excise Tax.
-
Bankruptcy
- Any bankruptcy
information.
APPEALS INFORMATION
-
Only include information that is relevant to the issuance of the TAO issue.
OTHER INFORMATION
-
Of the tab headings listed below, only include the information that is relevant
to the issuance of the TAO.
-
Internal Revenue Manual (IRM)
-
Copies of relevant IRM Sections (TAS IRM, Function IRM’s, SERP Alerts,
Operating Division Memorandums, etc.).
-
Legal Research
- Copies
of the IRC, regulations and court cases in support/defense of TAO court cases.
-
Counsel Opinions
- Opinions
from Counsel regarding the TAO issue, LTA/Area Director position on Counsel
opinion.
-
Waivers
-
Form 900 (CSED) or Form 2750 (ASED).
-
Correspondence
- Copies
of correspondence sent between TAS and the IRS, in descending order (most
recent date on top).
-
Automated Collection System (ACS)
-
Applicable ACS screen prints, including the history in descending order.
-
Integrated Collection System (ICS)
-
Applicable ICS screen prints, including the history in descending order.
-
Desktop Integration (DI)
-
Applicable DI screen prints.
-
Power of Attorney POA
-
Form 2848, Power of Attorney, or Form 8821, Tax Information Authorization.
-
Other
- Any misc. documents
(payroll records, Form W-2 & Form W-3) and anything not included in one of the categories
above.
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