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PRACTICE & PROCEDURES

received, in keeping with normal prac- is reasonable. Subsequent requests and
The local tices. For noncertified mail responses, or requests to reschedule over 45 days must
be approved by the group manager.
even certified mail responses, an effective
stakeholder liaison way to confirm that the IRS received a
is a good source for response to a notice is to have the client SB/SE collection field work
and face-to-face meetings
write a check payable to the IRS for $1
practitioners to obtain and apply the check to the tax year and For the most part, revenue officers have
phone numbers of IRS type of tax on the notice. State in the not been conducting work in the field.

personnel. response: “Enclosed find check [num- As of this writing, face-to-face meetings
ber] in the amount of $1 to be applied
are only authorized when (1) there are
toward the tax and year stated in the no alternatives to face-to-face case con-
notice.” The canceled check will be proof tact, and the failure to act poses a risk of
but an accuracy-related penalty is being of the receipt of the response. permanent loss to the government, such
proposed, a response is still necessary to as a statute expiration, pyramiding Form
prevent the assessment of the accuracy- SB/SE Examination: 941 liabilities, or assets being placed out
related penalty. Both a formal written Face-to-face meetings of reach of the government, or (2) the
protest or a Form 12203 and a letter are Most SB/SE field examinations as of taxpayer or representative has requested
needed to prevent the assessment of the this writing are being done virtually. face-to-face contact and the revenue
accuracy-related penalty, and reason- Face-to-face interactions must be agreed officer’s manager agrees to the face-to-
able cause must be shown. CP2000 to by the IRS employee and the taxpayer, face contact.
procedures are discussed in IRM Sec- and the request must be submitted
tions 4.19.2 and 4.19.3. Precomputa- through the IRS group manager to the Installment agreements:
tion notice procedures are discussed in territorial manager for approval. Office Service Center only
IRM Section 4.19.3.22.61. Extension examinations will continue to be virtual Most taxpayers who qualify for a short-
requests are discussed in IRM Section until further notice. term installment agreement currently
4.19.3.22.7.3. Accuracy-related penalty have up to 180 days to resolve their tax
procedures are discussed in IRM Sec- Other examinations issues liabilities instead of 120 days (see IRS
tion 4.19.3.22.1.4. Outgoing calls to For collectibility, see IRM Sections New Release IR-2020-248). In general,
taxpayers by Automated Underreporter 4.10.2.4.1 and 4.10.7.4.6. If collectibility individuals qualify for this extra time
Program (AUR) employees assigned is an issue, contact the examiner and/or if they owe $50,000 or less and have
the case are discussed in IRM Section group manager to request that the scope filed all required returns; businesses
4.19.3.22.2.5.1. The IRM states that of the examination be limited. qualify if they owe $25,000 or less and
the AUR employees assigned the case For a survey of a return, see IRM have filed all required returns. Certain
must call the taxpayer when an Appeals Section 4.10.2.5.1, which discusses con- taxpayers who are assessed less than
conference is being requested. Appeals ditions allowing a return to be surveyed $250,000 may set up an installment
procedures are discussed in IRM Section after assignment and after the taxpayer agreement without providing a finan-
4.19.3.22.1.8. has been contacted by the examiner, but cial statement or substantiation if the
Further instructions specific to before records have been inspected. This monthly payment proposal can pay off
income issues can be found in IRM could include circumstances where the the liability over the life of the collec-
Section 4.19.3.22.3. Rescinding statu- taxpayer is deceased or has a terminal ill- tion statute.
tory notices is discussed in IRM Section ness, has experienced a business closure, Some individual taxpayers who are
4.19.3.22.11.2 and addresses taxpayers or has other circumstances that would assessed less than $250,000 for the 2019
who request an Appeals conference. justify the survey of a return. If the deci- tax year may qualify to set up an install-
sion is made to survey the return after ment agreement without the filing of a
Status of responses to letters the taxpayer has been contacted, a Letter Notice of Federal Tax Lien and without
or notices (nonappealable) 1024, Return Accepted as Filed, is issued. providing a financial statement. Quali-
Expect delays. The IRS suggests that To reschedule an initial appointment, fied taxpayers with existing direct debit
once a notice is answered, no further see IRM Section 4.10.2.9.4, which states installment agreements may be able to
action is needed. Even so, a practitioner that the examiner should attempt to ac- use the Online Payment Agreement
should follow up on all responses to commodate the taxpayer when a request system to propose a lower monthly pay-
notices after 60 days if a response is not to reschedule the initial appointment ment amount and change their payment

30 January 2022 The Tax Adviser