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Administrative Review

The Audit

Types of Audit

  • Selection for Audit
  • Correspondence of Audit
  • Office Audit
  • Field Audit

 

Authority of Examinig Revenue Agent

  • Treasury Regulations
  • Revenue Rulings
  • I.R.S. Manual

     

Review by Examining Agent Supervisor

 

II.B. Administrative Review

The Administrative 30-Day Letter (Pre-assessment)

The proposed deficiency 30-Day letter
  • Not a statutory notice
  • Several other 30-Day letters

Reasons for receipt of 30-Day letter

  • Disagree with findings of auditor
  • Ignore contact

Content of 30-Day letter

  • Pay proposed deficiency
  • Request conference

Form of response

  • Up to $2,500 of liability - Oral request
  • Over $2,500 of liability - Respond on form
  • Over $10,000 - Formal protest

Mission of Appeals office

  • Resolve controversy without litigation
  • Fair and impartial: two hats
  • Enhance voluntary compliance
  • Generally new issues not raised
  • Hazards of litigation

Jurisdiction of Appeals Office

  • Generally exclusive and final authority
  • Exceptions
    • Docketed cases
    • Religious, political, moral, etc.
    • Criminal fraud
    • Refunds Exceeding $1,000,000
    • Certain Banruptcy