College of Law
II.A. 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
