Every TaxProc guide
All 128 guides, in the order a case meets them: representation and access, penalties, exams, Appeals and the Tax Court, collection, the BBA partnership audit regime and entity relief. Notice pages are on the notices page, forms on the forms page.
No guides match that. Try fewer words, or search the whole site.
Representation and access
CAF number: how practitioners get one, find a lost one, and keep it in good standing
What the Centralized Authorization File number is, how the CAF units assign it, how to recover a forgotten one and why a number can be suspended.
Tax Pro Account: how online POA and TIA requests work, and when you still need a paper form
The IRS's all-digital route for individual Form 2848 and 8821 authorizations: requirements, step by step, its limits and its side effects on existing authorizations.
Form 2848 vs Form 8821: which authorization you need, and what each one lets you do
Representation versus information access: who can be named, what each form authorizes, how the CAF processes them and when each is the right tool.
Why the CAF unit rejects a Form 2848 or 8821, and how to fix each problem
The five essential elements, the screening rules behind Letter 861C, designation-level traps and a checklist that keeps forms from coming back.
Revoking a power of attorney and withdrawing as representative: methods, effects and IRS processing
Every way an authorization ends: new forms, REVOKE and WITHDRAW annotations, written statements, Tax Pro Account withdrawals, death and specific-use forms.
IRS transcripts for practitioners: TDS, PPS, the SOR mailbox and what each transcript shows
Which transcript answers which question, how to get e-Services TDS access as a practitioner, delivery rules, masking, and PPS transcript limits.
How to read an IRS account transcript: transaction codes, reversals, statute dates and the patterns that matter
A working guide to the tax account transcript: the three-digit codes, reversal conventions, the dates that start the assessment and collection statutes, the codes that matter in a controversy, TC 971 action codes and masking.
Practitioner Priority Service (PPS): what it can do, what it will not do, and how to make a call count
Scope, authentication, call limits, faxing an unprocessed authorization, and where PPS sends collection, exam and AUR issues.
Circular 230 duties every representative should know: the subpart B rules in practice
Subpart B of 31 CFR Part 10 section by section, with how each duty shows up in exams, collection cases and CAF processing.
Who can represent a taxpayer before the IRS: unlimited, limited and special-case representation
Attorneys, CPAs, enrolled agents, actuaries, retirement plan agents, AFSP preparers, family members, officers, students and fiduciaries: what each may do.
Form 56 and representing a deceased taxpayer or estate: fiduciary notice, then power of attorney
Fiduciary versus representative, the June 2026 Form 56 line by line, death and existing authorizations, and disclosure to executors and heirs.
Third party designee and oral disclosure: the limited alternatives to a Form 2848
The checkbox designee, oral disclosure consent (ODC) and the oral Form 8821 (OTIA): scope, duration, how the IRS records each, and their limits.
e-Services and secure access for practitioners: ID.me, TDS, the SOR mailbox and related IRS tools
The IRS online tool set for professionals, the identity verification behind it, TDS access for attorneys, CPAs and EAs, and the help lines.
When the IRS contacts your client directly: IRC 7521(c), the bypass procedures and the exceptions
The default rules protecting representation, the exam and collection bypass procedures step by step, and what a representative can do at each stage.
The Office of Professional Responsibility: how referrals arrive, how a Circular 230 case proceeds, and the sanctions available
What triggers an OPR referral, what IRM 1.25.1 and 20.1.6.12 tell IRS employees about making one, the subpart D proceeding from complaint to appeal, burdens of proof, and censure, suspension, disbarment and monetary penalties.
The Taxpayer Advocate Service: the nine case acceptance criteria, what TAS will not take, how to file Form 911 as a representative, and when a Taxpayer Assistance Order is possible
The nine TAS case criteria with the IRM's examples, the categories TAS currently declines, Form 911 line by line for representatives, the contact and follow-up rules TAS imposes on itself, and what a TAO under IRC 7811 can and cannot order.
Penalties and abatement
First Time Abate: how the IRS applies its one-time penalty waiver
The IRS's administrative waiver for a first failure to file, pay or deposit: the lookback test, the returns it never covers, and how the IRS applies it.
Reasonable cause: what the IRS accepts and what it rejects
The ordinary business care and prudence standard, the reasons the IRM treats as acceptable or weak, and which penalties allow the defense at all.
How to write a penalty abatement request the IRS can grant
Channel, structure and attachments for a penalty abatement request, built around what IRM 20.1.1 tells the reviewing employee to check.
Failure-to-file penalty under IRC 6651(a)(1): computation and relief
The 5 percent per month addition, how months are counted, the minimum penalty, the offset for failure to pay, fraudulent failure to file, and relief.
Failure-to-pay penalty under IRC 6651(a)(2) and (a)(3): computation and relief
The 0.5 percent monthly addition on unpaid tax, the rate changes after a levy notice or under an installment agreement, the 90 percent extension rule, and relief.
Estimated tax penalty for individuals under IRC 6654, and the waivers that remove it
The required annual payment, installment dates, how the IRS computes the penalty at the underpayment rate, the exceptions, and the only two waivers.
Estimated tax penalty for corporations under IRC 6655
Who owes corporate estimates, the required payment and large corporation rules, how the penalty is computed on Form 2220, and the few ways it changes after assessment.
Accuracy-related penalty under IRC 6662: negligence, substantial understatement and the defenses
The ten grounds for the 20 or 40 percent penalty, the negligence and substantial understatement tests, no stacking, and the defenses and procedural requirements.
Civil fraud penalty under IRC 6663 and the IRS's burden of proof
The 75 percent penalty, the clear and convincing burden the IRS carries, the badges of fraud, how a fraud case is developed internally, and where the defenses are.
Written supervisory approval under IRC 6751(b): when a penalty fails without it
Which penalties need written approval, who counts as the immediate supervisor, the deadlines in the 2024 regulations, the electronic-calculation exception, and how to test compliance.
Penalty relief for erroneous IRS advice under IRC 6404(f), and for oral advice
When the IRS must abate a penalty caused by its own written advice, how to claim it on Form 843, and how the IRS treats oral advice and advisor reliance.
Late partnership return penalty (IRC 6698): per-partner computation, notices and relief
The per-partner, per-month penalty for a late or incomplete Form 1065: the 2026 and 2027 rates, how the IRS assesses it, and every relief route the IRM recognizes.
Late S corporation return penalty (IRC 6699): per-shareholder math, assessment and relief
The per-shareholder penalty for a late or incomplete Form 1120-S: current rates, how it stacks with the 6651 penalty when tax is due, and how the IRS removes it.
Rev. Proc. 84-35: reasonable cause relief for small partnerships that file Form 1065 late
When a small partnership's late or incomplete Form 1065 penalty comes off under Rev. Proc. 84-35, what the IRS checks, and why the relief can be reversed.
International information return penalties: Forms 5471, 5472, 3520, 3520-A and 8938, and how relief works
The $10,000 and $25,000 initial penalties, continuation penalties after a 90-day notice, and the narrow relief rules for international information returns.
Failure-to-deposit penalty (IRC 6656) for employment taxes: tiers, averaged penalties and relief
The four-tier deposit penalty on Forms 941, 940, 944 and 945: how the IRS computes it, how to reduce it by redesignating deposits, and when FTA, waivers or reasonable cause apply.
Interest abatement under IRC 6404(e), and when interest on a penalty comes off
Which interest the IRS can remove and which it cannot: interest on abated penalties, ministerial and managerial delay under 6404(e)(1), erroneous refunds, and the Tax Court route.
Requesting penalty abatement by phone, in writing or on Form 843
Which penalties the IRS can abate on a call, what the oral statement limits mean, what a written request needs, and how to complete Form 843 line by line.
Appealing a penalty abatement denial: the request, the Appeals review and what comes after
After Letter 854C or another denial: how to request Appeals, what the IRS sends with the case, how Appeals decides penalty appeals, and the court options if Appeals says no.
Getting paid penalties back: refund claims, the lookback period and Form 843
Why a paid penalty can be abated only within the refund statute, how the 3-year and 2-year rules and lookback limits work, and the steps from Form 843 to refund suit.
Dishonored check and payment penalty (IRC 6657): amounts, electronic payments and relief
The bad check penalty now covers EFTPS, direct debit, card and wire payments. The amounts, how it posts, the good faith exception, and the documentation the IRS requires.
Disaster postponements under IRC 7508A, and penalty relief when a disaster hits
Who counts as an affected taxpayer, how the IRS sets the postponement period, the 120-day mandatory rule, deposits, interest, self-identification, and reasonable cause outside a covered area.
The IRS Criminal Investigation Voluntary Disclosure Practice: Form 14457, the two-part process and the penalty framework
Form 14457 Part I and Part II, the timeliness test, the six-year disclosure period and the civil penalty framework the examiner applies, from IRM 9.5.11.9 and IRM 4.63.3.
Streamlined filing compliance procedures: the domestic and foreign offshore procedures, Forms 14654 and 14653, and the 5 percent penalty
Eligibility, the non-willful certification on Form 14654 or 14653, the covered periods, how the 5 percent penalty base is built, where the package goes and what the IRS does with it.
Delinquent international information returns and FBARs: the reasonable cause route when all income was reported
What the IRS delinquent international information return submission procedures and the FBAR late-filing instructions actually say, how penalties get assessed anyway, and how to position the reasonable cause statement.
ERC claim disallowed (Letter 105-C): the response, the Appeals route, Form 907 and the two-year refund suit clock
The IRS procedure behind an ERC Letter 105-C or 106-C, what the response must contain, how the case reaches Appeals, and how to keep the refund suit window open with Form 907.
Withdrawing an ERC claim, amending it, and what remains of the ERC voluntary disclosure programs
Who can still withdraw an Employee Retention Credit claim, the exact steps for each situation, the amend-instead cases, and the terms and account markers of the two closed ERC voluntary disclosure programs.
Preparer penalties under IRC 6694 and 6695: the conduct standards, the 2026 amounts, how the IRS builds the case and how to contest it
What a return preparer is penalized for and how much, the IRM's procedure from the client exam to Letter 1125 and Appeals, the 3-year statute, the 15 percent special claim and the OPR referral rules.
Examinations
How IRS examinations work: correspondence, office and field audits from first letter to closing
Correspondence, office and field examinations compared: who works them, the opening letters, the IDR and interview stages, and the three ways an exam ends.
Correspondence examinations: how the campus audit runs from Letter 566 to the notice of deficiency
The campus audit by mail: the letters in order, how long each waits, how to get more time, and the point after which Appeals is closed off.
Information document requests (Form 4564) and the IDR enforcement process
How examiners write IDRs, what the IRM requires of them, the LB&I three-step enforcement ladder, and what a sound response looks like.
LB&I examinations: issue-based exams, the acknowledgment of facts and the examination plan
The LB&I examination process in three phases: planning and the exam plan, execution through IDRs, AOF and NOPAs, and resolution through FTS, AIR and Appeals.
The assessment statute of limitations: the three-year rule under IRC 6501 and its exceptions
The three-year assessment period, when it starts, the exceptions that lengthen or remove it, the events that suspend it, and how the IRS tracks the ASED internally.
Form 872 statute extensions: fixed-date, open-ended and restricted consents, and when to refuse
What the IRS must tell your client when it asks for a consent, the forms and their differences, how restricted consents work, and the consequences of saying no.
The revenue agent's report and Form 4549: what the audit report contains and how to respond
The parts of an examination report, which report form goes with which outcome, the transmittal letters, and the rules for extensions, new information and corrected reports.
Signing Form 870 or Form 4549: what agreeing to an examination does and does not do
Agreement forms waive the Tax Court restrictions on assessment, stop interest after 30 days, and leave refund claims and further deficiencies open. Here is the detail.
The notice of deficiency (90-day letter): what it is, how it is mailed and how the Tax Court clock runs
The 90-day letter is the ticket to Tax Court without paying first. Here is how it is issued, what makes it valid, how the deadline is set, and what happens if it passes.
Audit reconsideration: getting the IRS to reopen an assessed examination
The criteria, the cases the IRS will not reopen, the letters the reconsideration unit sends, collection holds, and how to get to Appeals if the request is denied.
Fast Track Settlement: resolving exam issues with an Appeals mediator before the case leaves Examination
FTS puts an Appeals mediator with settlement authority into an open exam. Here is who qualifies, how to apply, what happens at the session, and what is lost if it fails.
Third-party contacts during an exam: the IRC 7602(c) notice, Letter 3164 and the contact list
The IRS must give 45 days' notice before contacting third parties and keep a record you can ask for. Here is what counts, the exceptions, and how to use the rule.
IRS summonses in an examination: when examiners use them, the limits, and how enforcement works
A summons is the step after an ignored IDR. Here is when examiners issue one, the statutory limits, third-party notice and quash rights, privileges, and court enforcement.
Taxpayer interviews, recordings and the right to representation under IRC 7521
When an interview must stop, whether the client has to attend, how recording works, and the limits on financial status techniques, from IRC 7521 and IRM 4.10.3.
Amended returns, qualified amended returns and refund claims during an examination
The qualified amended return cutoff, how examiners handle amended returns and claims filed mid-exam, the LB&I 30-day window, and protecting the refund statute.
No-change reports, partial agreements and closing an IRS examination
The closing letters for each outcome, how partial agreements are built, what happens when a 30-day letter goes unanswered, and the limits on reopening a closed year.
Employment tax examinations and worker classification: Section 530, IRC 3509, CSP and Tax Court review
Worker classification exams step by step: Section 530 first, then the control test, reduced IRC 3509 rates, CSP settlement offers, agreement forms and Tax Court review.
Getting the examiner's file: the activity record, workpapers and FOIA requests
Taxpayers can get most of their exam file without FOIA. Here is what is in it, what the IRS withholds, and how to use FOIA when the direct route fails.
ERC examinations: Letter 6612, what the IDR asks for, the recapture letters, and the six-year assessment statute
The ERC audit from the examiner's side: how claims are classified, what documents the IDR demands for each eligibility test, how a paid credit is recaptured, and the extended statute that keeps 2021 quarters open.
Substitute for return under IRC 6020(b) and the Automated Substitute for Return (ASFR) program: how the IRS builds a return for a nonfiler, and how to unwind it
What an IRC 6020(b) return is, how the ASFR program computes it from information returns, what the CP2566 and CP3219N letters start, and how a late-filed return or reconsideration replaces the default assessment.
Protective refund claims: when a contingency justifies one, what the IRS requires it to say, the deadline and the lookback, and what happens after it is filed
The IRM's four requirements for a valid protective claim, the IRC 6511 deadline and lookback, the forms (1040-X, 1120-X, 843, Schedule PC), the supplemental-claim trap, and how Exam Classification holds the claim until the contingency resolves.
Tentative refunds on Form 1045 and Form 1139: the IRC 6411 application, the 12-month filing window, the 90-day processing rule and how a tentative allowance is clawed back
What an application for tentative refund is and is not, the carrybacks that still exist, the deadlines on both sides, what the IRS checks before paying, and why a paid tentative refund can be reassessed without deficiency procedures.
Appeals and Tax Court
The IRS Independent Office of Appeals: what it is, what it will consider, and how a case gets there
What Appeals is, the doors into it (protests, docketed cases, collection appeals), and the limits the IRM puts on what it will consider.
Writing a formal protest to IRS Appeals: when one is required, what Publication 5 says it must contain, and what gets it returned
The required elements of a formal protest, the two perjury statements for representatives, and the defects that send a case back to the examiner.
The small case request: appealing an examination of $25,000 or less per period without a formal protest
The $25,000 per period test, who is excluded, Form 12203, and why a small case request is not the same thing as a Tax Court small tax case.
What happens at an IRS Appeals conference, from the first letter to the settlement offer
Scheduling, case file access, formats, recording rules, new information and what the Appeals Officer does after the conference, from IRM 8.6.1.
Hazards of litigation: how IRS Appeals values an issue and what kinds of settlement it can offer
The settlement standard in IRM 8.6.4, the four settlement types, why penalties are not traded, and how the Appeals Officer converts hazards into a percentage.
Ex parte communications between Appeals and the examiner: what Rev. Proc. 2012-18 allows, prohibits and how breaches are cured
What the examiner or revenue officer may and may not say to Appeals without the taxpayer, how the case file and transmittal are policed, and the remedy for a breach.
Petitioning the Tax Court: the 90-day deadline, what the petition must say, and how docketed cases go to Appeals
The petition deadline, the required contents under Rule 34, who can represent the petitioner, and the docketed Appeals process under Rev. Proc. 2016-22.
The small tax case (S case) procedure in Tax Court: who qualifies, how to elect it, and what you give up
The $50,000 test under IRC 7463, electing and discontinuing S case status, the informal trial rules, and the finality trade-off.
The Collection Appeals Program: appealing liens, levies, seizures and installment agreement decisions on Form 9423
What can be appealed under CAP, the very short deadlines after the managerial conference, how to complete Form 9423, and how CAP differs from a CDP hearing.
Post-Appeals mediation and Fast Track mediation: when a neutral can help close an IRS dispute
Post-Appeals mediation for exam, offer and trust fund cases, Fast Track Mediation for collection disputes, who is excluded, and what the mediator can and cannot do.
The statute of limitations and Appeals: the 365-day rule, statute extensions, and what happens when time runs short
The 365-day acceptance rule, the 395-day Exam cushion, the 210 and 180 day rules for returned cases, and how Appeals solicits Form 872 consents.
Refund suits: when paying and suing in District Court or the Court of Federal Claims is the better route than Tax Court
The claim-first rule, the 6-month wait and 2-year deadline, the full payment requirement, how a petition bars a refund suit, and what happens in Appeals once suit is filed.
Collection
The IRS collection process, from the first bill to levy
The notice stream, ACS versus a revenue officer, the enforcement tools, and the points where a practitioner can pause collection.
IRS installment agreements: guaranteed, simple, non-simple and partial pay
The agreement types, what makes a request pending, user fees in effect from July 5, 2026, and what happens on rejection or default.
Streamlined installment agreements are now simple payment plans: the $50,000 rules
What changed when streamlined and in-business express agreements became simple payment plans, and the criteria in the July 21, 2026 IRM.
Partial payment installment agreements: equity, waivers and the two-year review
When the IRS will take payments that will not full pay before the CSED, what it does about equity, and how the biennial review works.
Currently not collectible status: hardship, closing codes and reactivation
The hardship standard, what the IRS verifies, the closing code income triggers, and what happens to liens, refunds and the statute while an account sits in CNC.
Collection information statements: Forms 433-A, 433-B and 433-F
Choosing between Forms 433-A, 433-B and 433-F, when a financial statement is not required, and how revenue officers verify one.
IRS Collection Financial Standards: the allowable living expenses effective June 29, 2026
The 2026 national and local standard amounts and the IRM 5.15.1 rules that decide what a client is allowed.
The collection statute expiration date (CSED) and what suspends it
The 10-year rule, each suspension (IA, offer, CDP, bankruptcy, time abroad, innocent spouse), waivers, judgments and what IRM 5.1.19 says about computing it.
When a revenue officer is assigned: contact rules, the first interview and deadlines
How Field Collection makes first contact, what the initial interview covers, and the IRM rules on representatives, deadlines and field visits.
Private debt collection: when the IRS assigns an account to a private agency
Which accounts the law sends to private collection agencies, the excluded taxpayers, the CP40 notice, and how to get an account returned to the IRS.
Passport certification for seriously delinquent tax debt (IRC 7345)
Who gets certified to the State Department, which debts are excluded, and how to get a certification reversed quickly when a client has travel booked.
Offers in compromise: the three grounds and how the IRS evaluates an offer
The legal grounds for an offer, what goes in the package, what the IRS can and cannot do while it is pending, and the difference between a return and a rejection.
Reasonable collection potential: how the IRS computes an offer amount
Asset equity at quick sale value, future income over 12 or 24 months, dissipated assets and the expense rules that drive the minimum acceptable offer.
Effective tax administration offers: when the IRS settles a debt the taxpayer could pay
The ETA offer for taxpayers who can pay in full but should not have to: economic hardship, public policy and equity grounds, and the special circumstances variant.
Doubt as to liability offers on Form 656-L
Form 656-L for disputing the tax itself after other remedies are gone: who qualifies, what to attach, the statute waivers, and how the IRS investigates.
Collection due process hearings: Form 12153 and the 30-day window
The lien and levy hearing rights under IRC 6320 and 6330: deadlines, what stops while the hearing is pending, the issues you can raise and the route to Tax Court.
Equivalent hearings: the one-year window after a missed CDP deadline
The Appeals hearing available for up to a year after a missed CDP deadline: same issues, but no Tax Court review, no automatic levy stop and no statute suspension.
Federal tax liens: filing, release, withdrawal, discharge and subordination
When the statutory lien arises, when the IRS files a notice, and how release, withdrawal, discharge, subordination and non-attachment each work.
IRS levies and wage garnishment: notices, release and return of property
Pre-levy notices, bank and wage levies, the IRC 6343 release grounds, economic hardship releases, and returning levied property to taxpayers and third parties.
The trust fund recovery penalty (IRC 6672): responsibility, willfulness and Letter 1153
Who the IRS treats as a responsible person, what willfulness requires, how the investigation runs, and the Letter 1153 appeal window before assessment.
Innocent spouse, separation of liability and equitable relief (Form 8857)
Relief from joint and several liability under IRC 6015(b), (c) and (f): eligibility, deadlines, the factors the IRS weighs and the 90-day Tax Court window.
Bankruptcy and tax debts: what is dischargeable and what the IRS does
The automatic stay, priority and dischargeable taxes, the three-year, two-year and 240-day rules, liens that survive discharge, and how bankruptcy interacts with offers and agreements.
Refund offsets and the injured spouse allocation (Form 8379): tax offsets, Treasury Offset Program debts, deadlines and how the IRS splits a joint refund
Tax offsets under IRC 6402(a), TOP offsets for child support, student loans and state debts, the transcript codes, the Form 8379 deadline and allocation method, and when an offset bypass refund is possible.
Transferee liability under IRC 6901: when the IRS can collect a taxpayer's debt from the people who received the taxpayer's property, what it must prove, the statute, and the defenses
What IRC 6901 does and does not do, the at-law and in-equity theories, the five elements the IRS documents, the notice of liability procedure, the one-year statute extension, Forms 870-T and 2045, and the defenses the IRM recognizes.
Partnerships and the BBA regime
The BBA centralized partnership audit regime: what practitioners need to know
Who the centralized partnership audit regime covers, how an exam moves from Letter 2205-D to the FPA, and where the partnership, its representative and its partners fit.
Electing out of the BBA regime under IRC 6221(b)
The 100-statement test, eligible and ineligible partners, the timely-return requirement, partner notice, and what the IRS does when it finds an election out invalid.
The partnership representative and designated individual under the BBA
Sole authority, substantial presence, designated individuals for entity PRs, changing or resigning on Form 8979, what happens when no PR is in effect, and powers of attorney.
The imputed underpayment: how the IRS computes it
The seven-step IU computation from IRM 4.31.9.9.2, with the IRS's own worked example, the netting limits, and what happens to adjustments that do not produce an IU.
Modification requests under IRC 6225(c) and Form 8980
The types of modification, the 270-day period after the NOPPA, partner amended returns and the alternative procedure, rate and tax-exempt modifications, and how BBA Operations and Appeals decide.
The push-out election under IRC 6226 and Form 8988
The 45-day election, Form 8988 contents, the 60-day deadline for Forms 8985 and 8986, how reviewed-year partners compute tax and interest, revocation, and what invalidates an election.
Administrative adjustment requests (AARs) under the BBA
When a BBA partnership can file an AAR, who signs it, electronic versus paper filing, the required IU computation, paying the IU or pushing out, Forms 8985 and 8986, and how examiners treat AARs.
The BBA exam, step by step: Letter 2205-D, the NAP, the NOPPA and the final partnership adjustment
Each notice in a BBA exam, when the IRM says it goes out, who receives it, what the partnership can do at each point, and how cases move from the field to Technical Services, Appeals and BBA Operations.
The BBA adjustment period under IRC 6235, and how it is extended
The three IRC 6235(a) dates, what resets them, the special rules for fraud, no return and substantial omission, Form 872-M extensions, and the related partner-level and collection periods.
Penalties in a BBA examination
Penalties computed on the imputed underpayment, the IRM's ordering rules for negative adjustments, the substantial understatement test, reasonable cause at the partnership level, push-out penalties, and the penalties that sit outside BBA.
Tiered partnerships and pass-through partners under the BBA
What a partnership, S corporation or trust that receives a Form 8986 must do, the deadline, how to compute and pay an IU instead of pushing further, modification through the chain, and the consequences of doing nothing.
Collecting a BBA imputed underpayment, and when partners become liable
When the IU can be assessed, how to pay it, the higher interest rate after notice and demand, the two-year IRC 6232(f) assessment against partners, and what happens when a partnership ceases to exist.
TEFRA partnership procedures for pre-2018 years
Which pre-2018 partnerships are TEFRA, the tax matters partner and notice partners, the NBAP and 45-day rule, settlements and consistent settlement, the FPAA petition periods, and the IRC 6229 statute.
BBA partnership cases in Appeals and Tax Court
When a BBA case can go to Appeals, what Appeals hears and how often, the NOPPA and FPA Appeals issues, the 90-day petition, Tax Court's BBA rules, and deposits for district court or Claims Court.
Amended return or AAR: which a partnership can file
The IRC 6031(b) bar on amending K-1s, who can still amend (elected-out partnerships, superseding returns, IRS guidance), how a BBA partnership corrects a return, and what partners can do on their own.
Forms 8985 and 8986: pass-through statements and partner adjustments
What the two BBA push-out forms do, who prepares them, the 60-day and extended-due-date deadlines, electronic versus fax submission, the December 2024 revisions, TIN corrections, and partner reporting on Form 8978.
Entity elections and relief
Late S corporation election relief under Rev. Proc. 2013-30
Who qualifies for the simplified late Form 2553 procedure, what the filing must contain, and what the campus does with it.
Late entity classification election relief (Form 8832 and Rev. Proc. 2009-41)
The simplified procedure for a late entity classification election, which revenue procedure applies to which situation, and what the campus checks.
Section 9100 relief for missed regulatory and statutory elections
The automatic extensions under 301.9100-2, the letter ruling standards under 301.9100-3, and what a complete request contains.
Inadvertent S corporation terminations and invalid elections under IRC 1362(f)
What terminates or invalidates an S election, which problems need no ruling at all, and how a 1362(f) request is built.
S corporation reasonable compensation: what examiners look at
The rules and IRM procedures behind recharacterizing S corporation distributions as wages, and the factors the IRS and courts weigh.
EIN responsible party changes and Form 8822-B
Reporting a new responsible party on Form 8822-B, what the IRS checks, and when an ownership change means a new EIN instead.
Closing a business with the IRS: final returns, Form 966 and the EIN
The federal filings that close each type of business and how the IRS deactivates the EIN and filing requirements.
Changing a tax year with Form 1128: automatic approval, ruling requests and late filing
Which tax year changes are automatic, how the 25-percent gross receipts test works, the filing deadlines, and how the campus processes Form 1128.
Late QSub, ESBT and QSST elections under Rev. Proc. 2013-30
Deadlines for subsidiary and trust elections, what happens when they are missed, and the Rev. Proc. 2013-30 relief procedure for each.
Estate tax closing letters (Letter 627), requests for prompt assessment (Form 4810) and discharge of the executor from personal liability (Form 5495): what each one does and how the IRS processes it
The $56 Pay.gov closing letter and the free transcript alternative, the 18-month prompt assessment request under IRC 6501(d), and the nine-month executor discharge under IRC 2204 and 6905, with the IRM procedures for each.