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25.1.9.8
(01-01-2003)
Identifying Penalty File Examination Cases
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To facilitate identification by service centers
of closed TEGE fraud cases to be filed in the penalty file, TEGE must attach
Form 3198, Special Handling Notice, to the folder of each case file of:
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Taxpayers who have been prosecuted whose civil liabilities
(tax and additions) are determined and whose cases are closed by TEGE; and
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Taxpayers whose underpayment of tax is determined
and whose cases are closed in TEGE with assertion of an additional 75% (see
IRC 6663(a) of the underpayment due to fraud but without involving prosecution.
Note:
Form 3198 should be annotated,
"Civil Penalty Assessment."
See IRM 20.1.8.1.3.1 for additional
TEGE Penalty Processing Procedures.
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