part8-9

8.4.1 
Processing Docketed Cases

8.4.1.1 
(10-26-2007)
Introduction to Docketed Cases

  1. This section covers the processing of a docketed case from the time it appears on the Docket Information Management System
    (DIMS) until the time the case is closed.

  2. This section covers the procedures for all docketed cases regardless of the type of tax involved.

  3. Many of the same procedures are used on Campus S Docketed cases. However, there are some unique procedures that apply solely
    to the Campus S Docketed cases which are covered in IRM 8.4.2.

  4. See IRM 8.7.1.10 for information covering Appeals Involvement in Docketed IRC 7430 Cases.

  5. The procedures explain and/or provide references to cover Tax Examiners, Appeals Officers, and Tax Computation Specialists
    involved in processing docketed cases.

  6. References to Appeals Officers also include the Appeals Team Case Leaders.

  7. References to Examination include the Examiners in Small Business and Self Employed (SB/SE), Large and Mid-Size Business (LMSB)
    and Tax Exempt and Government Entities (TE/GE) groups.

8.4.1.2 
(10-26-2007)
Defining Docketed Cases

  1. Appeals mission statement states Appeals will close as many docketed cases as possible to avoid going to trial.

  2. A docketed case is a tax case assigned a docket number in the U.S. Tax Court. These cases include petitions filed in response to:

    1. Notices of deficiency;

    2. Final adverse determination letters; and

    3. Final partnership administrative adjustments (FPAA).

  3. A regular case is a tax case with a deficiency of more than $50,000 (including deficiency amount, additions to tax, additional amounts and
    penalties) for any one taxable period.

  4. Taxpayers may elect to have their case conducted under the Courts simplified small tax case or “S”
    case     procedures. Trials in small tax cases generally are less formal and result in speedier disposition. However, decisions entered
    pursuant to small tax case procedures cannot be appealed. See IRC 7463 for details. Taxpayers may elect small tax case procedures
    for tax disputes involving $50,000 or less (including tax and penalties.

  5. Rev. Proc. 87-24, 1987–1 C.B. 720, describes the procedures for handling docketed cases in Appeals and Counsel.

  6. Direct questions concerning Tax Court jurisdiction through the Field Counsel assigned to the case, to Branch 3 of the Office
    of Administrative Provisions and Judicial Practice.

  7. Refer to IRM 13.1.7, Taxpayer Advocate Case Processing, for criteria to determine when it is necessary to refer a case to
    Taxpayer Advocate Services (TAS), and guidelines for processing TAS cases from assignment to completion.

8.4.1.2.1 
(10-26-2007)
Designation Identifying Types of Docketed Cases

  1. The Tax Court uses the following identification terms or letters after the docket number to designate the different types
    of docketed cases:

    Designation Description
    S Small or “S”
    cases
    D Disclosure Actions ( IRC 6110) (with the prefix number next in order among all cases)
    L Collection Due Process Cases ( IRC 6320 and IRC 6330)
    ABATEMENT Interest Abatement Actions ( IRC 6404)
    X Exempt Organization Cases ( IRC 7428)
    EMPLOYMENT Worker Classification Cases (IRC 7436)
    R Employee Plan Cases ( IRC 7476 )
    B Governmental Obligation Actions (Bonds) ( IRC 7478)

8.4.1.3 
(10-26-2007)
Appeals Authority Over Docketed Cases

  1. Appeals has settlement authority in conjunction with Counsel over docketed cases. This authority remains in Appeals unless
    procedures require the case be returned to Counsel.

  2. The Office of Chief Counsel (or the Associate Chief Counsel with subject matter jurisdiction over the case or issues) may,
    after consulting with the Chief, Appeals and the appropriate Area Counsel, determine that a case, or an issue or issues in
    a case, not be considered by Appeals. In such a situation, Appeals foregoes settlement authority on the case or issues.

8.4.1.4 
(10-26-2007)
Reconsideration Cases (Closing Code 42) – Jurisdiction Returned to Appeals by Counsel

  1. Counsel and Appeals may agree jurisdiction will be returned to Appeals for settlement in a docketed case with strong likelihood
    of settlement for all or part of the case.

  2. When the case is in Counsels jurisdiction, it is in Part 3 on ACDS. When the case is returned to Appeals for reconsideration,
    APS inputs Closing Code 42 and a date closed equal to the date the case is received for reconsideration. This changes the
    “Part”
    on the open ACDS record from 3 to 2. The closed ACDS record retains Part 3 and the closing information

8.4.1.5 
(10-26-2007)
Common Terms and Definitions in Docketed Cases

  1. Some Tax Court terms and definitions are described in IRM 35.1.2. In addition, common definitions for docketed cases include:

    Term Definition
    Acquiescence Commissioners acceptance of a decision reached by the Tax Court adverse to the position of the Government. These are published
    in the Internal Revenue Bulletin.
    Action on Decision Chief Counsels recommendation, if any, of action to be taken on an adverse decision.
    Cases on Remand When a case is sent back to a lower court with orders about further action.
    Decision of the Tax Court In a deficiency case, the decision of the Tax Court memorializes the Tax Courts determination of the correct amount of the
    deficiency, penalty, additions to tax or overpayment. A decision needs to dispose of any claims for award of attorneys fees
    under IRC 7430. The time to appeal a decision of Tax Court is within 90 days after the decision is entered.
    Defaulted Case A case where a party fails to plead or otherwise proceed with the case as provided by the Tax Court Rules of Practice and
    Procedure and the Tax Court enters a decision against the defaulting party. A decision rendered upon a default operates as
    an adjudication on the merits.
    Dismissed Case A case where a party failed to properly prosecute or comply with the Tax Court Rules of Practice and Procedure, causing the
    Tax Court to enter an order of dismissal either for lack of prosecution, lack of jurisdiction or other reason. A decision
    rendered in consequence of a dismissal, other than a dismissal for lack of jurisdiction, operates as an adjudication on the
    merits.
    Legal File A file maintained by Counsel containing all legal documents pertaining to a docketed case.
    Non acquiescence Commissioners non-acceptance of a decision reached by the Tax Court that is adverse to the position of the Government. These
    are published in the Internal Revenue Bulletin.
    Original Consideration Appeals consideration of a docketed case not considered by Appeals in non-docketed status.
    Petition Taxpayers request to the Tax Court for a redetermination of the deficiency. A petition in a declaratory judgment proceeding
    is the pleading filed by the taxpayer or fiduciary.
    Petitioner A taxpayer or fiduciary who files a petition with the Tax Court.
    Proposed Schedule of Trial Sessions Schedule prepared by the Tax Court for each trial term. This schedule is used primarily by Tax Court to arrange courtroom
    facilities.
    Reconsideration An Appeals consideration of a docketed case previously considered by Appeals in either non-docketed or docketed status.
    Respondent In a Tax Court case, the respondent is the Commissioner of Internal Revenue.
    Rule 155 Case After trial, the Tax Court renders an opinion. If the opinion requires a recomputation of tax, the Court withholds entry of
    its decision to permit a computation as provided by Rule 155 of the Rules of Practice Before the United States Tax Court.
    An Appeals Tax Computation Specialist generally does the recomputation.
    Session Settlement Settlement effected by Counsel after the date a docketed case is set for trial or the opening date of the Pre-trial Hearing
    or Request Session.
    Settlement Stipulation Settlement document filed with the Tax Court. This document memorializes the settlement of:
    a deficiency,
    a penalty,
    addition to tax,
    an overpayment, or
    some other issue agreed to by the Government and petitioner in a docketed case. Claims for attorneys fees under IRC 7430
    may also be included.
    Stipulation of Facts A formal legal document filed with the Tax Court setting forth those mutually agreed statements of fact which require no proof
    in Court.
    Trial Calendar Tax Courts list of cases scheduled for trial at a certain time and place. The trial calendar is issued several months before
    the opening date of the trial session.
    Trial Calendar Period The period beginning with the issuance of the calendar and ending on the opening day of the session.
    Trial Terms Three time periods the Tax Court divides the fiscal year for trial sessions of the court. The three terms are:

    • Fall Term – 12 weeks beginning September,

    • Winter Term – 9 weeks beginning in January, and

    • Spring Term – 9 weeks beginning in April.
    Trial Session Actual time Tax Court sits and hears cases during a term.

8.4.1.6 
(10-26-2007)
Docket List

  1. The Docket List is a list of cases docketed by U.S. Tax Court. The list is prepared by Counsel after the Tax Court serves
    the taxpayers petition(s) to the Commissioner. Counsel E-mails the list as an attachment to employees in various Operating
    Divisions/functions who are members of an E-mail distribution list maintained by Counsel. The list is used as a tool to assist
    source functions determine if a case is docketed.

  2. The hard-copy Docket List shows:

    • Docket List Number

    • Date List Prepared (by Counsel)

    • Date Petition Served (on IRS)

    • Docket number(s)

    • Notice Date (date of notice of deficiency or other determination letter or notice)

    • Taxpayer(s) name, address, and TIN(s)

    • Year(s) petitioned

    • Signed by Both? (Y , N or Blank)

    • Postmark (Date or Blank)

    • Source of Notice (If known. Where no deficiency notice is attached to the petition, the source is listed as unknown.)

    • Appeals Office

    • Counsel Office

  3. In addition to creating and distributing the hard-copy Docket List by E-mail, Counsel also posts the Docket List as a file
    to a server. Appeals downloads the Docket List file from the server and posts it on its automated system, “Docket Information
    Management System (DIMS)”
    , a sub-system of the Appeals Centralized Database System (ACDS). DIMS is used in lieu of the hard-copy Docket List.

  4. After the electronic file from Counsel is posted to DIMS, users are able to print either the entire list or sort the list
    so that it contains only the cases they control or need to locate.

  5. The automated DIMS system is available to both Appeals and non-Appeals employees responsible for issuing and monitoring notices
    or letters containing Tax Court rights.

  6. Access to DIMS is obtained through the Online 5081 process.

  7. Appeals Processing Services (APS) uses DIMS to monitor the Docket List. See IRM 8.4.1.6.3.

8.4.1.6.1 
(10-26-2007)
Docket List Responsibilities

  1. Operating Divisions and functions who issue notices of deficiency, notices of determination, or any other letter or notice
    with United States Tax Court rights are responsible for monitoring the Docket List to determine if a petition is filed in
    response to a letter or notice they issued.

  2. If a petition is filed, the case must be located, processed for closing and transmitted to Appeals within ten (10) calendar
    days of the receipt of the Docket List.

  3. The U.S. Tax Court requires the filing of an “answer”
    by the Commissioner of Internal Revenue in all docketed tax cases.

  4. Employees responsible for monitoring the Docket List must be aware of and take all necessary actions to ensure Counsel receives
    docketed administrative files with sufficient time remaining to meet the due date established by the U.S. Tax Court to answer
    the petition.

  5. The “answer due date”
    , or the time within which the petition must be answered, is set by the Tax Court at sixty (60) days from the date the
    petition is served on the IRS. The answer due date for small tax case petitions is the same as it is for regular tax case
    petitions.

    Note:

    The answer due date is clearly identified on the TLCATS Case Screen 1 in the “Answer Due Date”
    field.

  6. Counsel needs time to prepare its answer, therefore APS must make every effort to card the administrative file and send it
    to Counsel via a mail delivery system that ensures it is received in Counsel no later than twenty (20) days prior to the answer
    due date.

8.4.1.6.2 
(10-26-2007)
Time Line From Date Petition Served to Answer Due Date

  1. The following table provides a time line for various actions required, beginning on the day the petition is served on the
    IRS.

    DAY ACTION REQUIRED
    1 Petition served on IRS
    1 – 3 Docket List prepared and distributed
    Docket List uploaded to DIMS
    1 – 10 ODs/functions monitor Docket Lists to identify, locate, close, and transmit docketed files to Appeals.
    11 – docketed administrative file received in Appeals ODs/functions continue process to identify, locate, close, and transmit docketed files to Appeals.
    APS (Centralized DIMS) searches for docketed files not yet received.

    Note:

    Within 2 days of receipt, APS acknowledges, cards and transmits file to Counsel for answer.
    40 APS creates dummy file for answer if file not received timely.
    60 Answer Due Date

8.4.1.6.3 
(10-26-2007)
Docket Information Management System (DIMS)

  1. In Appeals, Brookhaven APS is responsible for downloading the Docket List file Counsel placed on the server and posting it
    on Appeals automated system, “Docket Information Management System (DIMS)”

  2. In Appeals, the responsibility for locating administrative files for all docketed cases is centralized in Brookhaven APS and
    Fresno APS. These two campuses are referred to as “centralized DIMS”
    .

    1. Brookhaven APS is responsible for securing administrative files for Appeals Field Operations East offices.

    2. Fresno APS is responsible for securing administrative files for Appeals Field Operations West offices.

  3. The source function sends the administrative file directly to the Appeals office designated on the Docket List. The centralized
    DIMS offices are responsible for making the initial and follow-up contacts to locate the administrative files if the file
    is not received in Appeals within ten (10) calendar days of appearing on a Docket List.

  4. Centralized DIMS contacts the source function responsible for sending the case to Appeals to obtain the file(s).

  5. If the case is not on AIMS, centralized DIMS takes the following steps to secure the case file.

    1. Requests the file using command code ESTAB or FAX the request to the appropriate Campus. Enter the full name and mailing address
      of the Appeals office where the file is to be sent, along with the statement “Appeals – Expedite Request”
      ,

    2. If the case is not received within seven (7) workdays, follows up by telephone with the appropriate Campus.

    3. If the case was on AIMS, contacts Examination to ensure AIMS is re-opened and updated to Appeals.

    4. Adds a DIMS Tracking contact to record the actions taken

  6. Within two (2) workdays of receipt, the APS office that receives the file:

    1. Acknowledges receipt.

    2. “Cards”
      the docketed case on ACDS CASES using all available information contained in the administrative file and on TLCATS and
      in accordance with established procedures. See IRM 8.4.1.7.1.

    3. Transmits the file to Counsel for answer.

    4. Closes DIMS.

8.4.1.6.3.1 
(10-26-2007)
DIMS Tracking

  1. DIMS Tracking is a feature within DIMS used to record the actions taken to locate administrative files for docketed Tax Court
    cases.

  2. DIMS Tracking allows users to electronically track and monitor receipt of the administrative file. Users enter contact information,
    such as the dates and names, action notes, responses received, date the file was received, and other information, i.e. defaulted,
    TC 922 (AUR case), AIMS status etc.

  3. When the Docket List file is posted, the following Docket List items are automatically uploaded and displayed in DIMS Tracking
    as “read only”
    information about each case:

    • DktNo

    • List #

    • Xmittal

    • Name

    • Address

    • TIN1

    • TIN2

    • SND Date

    • SND +90

    • Issuing Off

    • Appeals Off

    • Counsel Off

    • D/L Yrs Petitioned:

  4. The following DIMS Tracking fields are updated as applicable:

    Field Name Description
    CTIN1 & CTIN2 Enter corrected TINs if research shows the information provided on the Docket List is incorrect or incomplete
    Addl Yrs Petitioned: Enter additional years petitioned if research shows the information provided on the Docket List is incorrect or incomplete
    Petition Date Enter the date the petition is received from Counsel, if received
    TC 922* (required) This transaction code is used to identify Automated Underreporter (AUR) returns. Options are:

    • Y = TC 922 on TXMOD

    • N = no TC 922 on the account

    • UNK = unknown or not yet determined
    SN defaulted* (required) Options are:

    • Y = a default assessment was made.

      Note:

      If Y, then an entry to reflect the date assessed is also required.

    • N = a default assessment was not made.

    • UNK = unknown or not yet determined if a default assessment was made
    Date Assessed Enter the date assessed if a default assessment was made
    AIMS status If the case is on AIMS, enter current status and date from AMDISA
    Campus If the notice of deficiency was issued by a Campus, select the Campus location from the drop-down list
    CATS Admin Enter the CATS Admin file location of the Appeals office who will be handling the case.
    Attorney Counsel employee’s name per CATS.
    Case on ACDS* Enter a date in this field when the docketed case is properly controlled on ACDS.

    Caution:

    Entering a date in this field closes the case on DIMS.

    Non-Appeals issued notices – the APS unit that receives and cards the case should enter the date the case is created on ACDS in this field.
    Appeals Issued Notices – The Centralized DIMS employee will:

    • send an E-mail to notify the issuing office the case is docketed

    • add a DIMS contact to record the action taken

    Within two days of receipt of the E-mail, the issuing office will:

    • pull the file

    • update ACDS to Part 3

    • send the case to Counsel for answer

    • close DIMS by entering the date the case was sent to Counsel for answer/trial preparation in this field
    Contacts Click on “Add”
    to add a contact to document the actions taken to locate the case. The contact fields are:

    • Date – The date the action occurred

    • Name – the name of the person contacted

    • Notes – description of the action taken

    • Userid – systemically generated to identify the user who added the contact. Click on the hyperlink to view the name of the
      user

    * Required Field to close DIMS

8.4.1.7 
(10-26-2007)
Docketed Case Not Received Timely in Appeals

  1. After an established number of days (ranging from an additional 15 to 30 days) after the expiration of the period of time
    in which to file a petition to the Tax Court specified in the notice or letter, a case that does not appear on the Docket
    List is considered defaulted. See IRM 8.2.2, Processing 90-Day Cases and Defaulted Notices.

  2. Although source functions are required to timely send docketed cases to Appeals, some docketed administrative files are not
    received timely. Cases are sometimes prematurely defaulted or defaulted in error for a variety of reasons.

  3. In order to provide all available information regarding the case to Counsel for use in preparing and filing the answer, if
    a case appears on the Docket List or DIMS but is not received in Appeals within forty days after the date the petition is
    served on the IRS, APS will:

    1. create a dummy file for answer. See IRM 8.4.1.14.

    2. send the dummy file to Counsel by fax or overnight mail.

    3. card the dummy file on ACDS.

8.4.1.8 
(10-26-2007)
APS Receives Petition but Awaits Administrative File

  1. When the notice of deficiency was issued by Compliance or Campus and the administrative files for these cases are not received
    within ten (10) calendar days from the date the petition is received, contact the appropriate office to obtain the files.

  2. If the Docket List indicates you have the administrative file of a case where jurisdiction is in another office, contact the
    office that has jurisdiction and transfer the administrative file. See IRM 8.20.6, Appeals Case Processing Procedures, Interim
    Actions, Remittances, Partials, Transfers and Returns.

8.4.1.9 
(10-26-2007)
APS Receives File but Awaits Petition

  1. If the administrative file is received first, establish ACDS control by using ACTION code FILERCVD.

  2. If the petition is not received within seven (7) workdays from the receipt of the administrative file, contact the appropriate
    Counsel office to obtain a copy.

  3. Annotate the case file with the date of contact or update ACDS.

8.4.1.10 
(10-26-2007)
Case On Tax Court Calendar But Not ACDS

  1. If a case appears on the Tax Court calendar but not on ACDS, create the case on ACDS. This ensures the case will appear on
    the TAXCAL listing and will receive Appeals consideration.

  2. The APS office servicing the Appeals office responsible for the Tax Court calendar is responsible for creating the case on
    ACDS. APS creates a “dummy”
    administrative file containing all available information regarding the case.

8.4.1.11 
(10-26-2007)
Original Return Required

  1. The original return must be requested in all docketed cases because it may be needed if the case goes to trial.

  2. If the original return was not used as part of the examination process, the source function should not wait until the original
    return is received to send all other available documents to Appeals, such as the notice of deficiency, computation, workpapers,
    correspondence, etc. Instead, if the original return is not readily available, the source function must transmit the docketed
    case to Appeals without the original return, but include an unfilled requisition, a transcript of account, and a copy of the
    return in the case file. APS accepts docketed administrative files without the original return(s) to facilitate providing
    all available information as soon as possible to Counsel for use in answering the petition.

    Note:

    Do not reject docketed administrative files to the originator if the original return is missing.

  3. If the docketed case file does not contain the original return, take steps to ensure it was requested or if necessary, requisition
    it as soon as possible.

    • Verify a request was made by the source function.

    • If no request for the original return was made by the source function, coordinate with them to determine who will request
      it. Although it is the responsibility of the source function to request the original return(s), APS may agree to make the
      request for the original return.

    • Follow up on unfilled requests.

    • In any case, if no original return is included, use Tax Period Modifier “N”
      for each tax period to indicate the original return is missing.

    • Upon receipt of the original return, remove the Tax Period Modifier “N”
      . A “blank”
      in the Tax Period Modifier field indicates the original return is in the file.

8.4.1.12 
(10-26-2007)
Procedure APS Takes to Locate the Administrative Files

  1. If the case is not on AIMS and the notice was issued by the Campus, take the following steps to secure the case file.

    1. Enter full name and mailing address of the requester along with the statement Appeals – Expedite Request.

    2. If the case is not received within seven (7) workdays, telephone the appropriate Campus.

    3. Contact Examination to ensure that AIMS is re-opened and updated to Appeals.

  2. The responsibility for locating administrative files for all docketed cases is centralized in Brookhaven Appeals Processing
    Services (APS) and Fresno APS. These two campuses are referred to as centralized APS DIMS Offices.

    1. Brookhaven APS is responsible for securing administrative files for Appeals offices in Appeals Field Operations East offices

    2. Fresno APS is responsible for securing administrative files for Appeals offices in the Field Operations West offices

  3. The centralized APS DIMS Offices are responsible for making the initial and follow-up contacts to locate the administrative
    files. The source function sends the administrative files directly to the appropriate Appeals office.

  4. There is a tracking system within DIMS used to record the actions taken to locate administrative files for docketed Tax Court
    cases, and to electronically track and monitor receipt of file. DIMS Tracking allows the user to enter contact information,
    such as the dates and names, action notes, responses received, date the file was received, and other information, i.e. defaulted,
    TC 922 (AUR case), AIMS status etc.

  5. If the administrative files of these cases are not received from the Compliance office or the Campus which issued the notices
    of deficiency within ten (10) calendar days from the date the list is received, contact the employee assigned responsibility
    for locating the case at the appropriate office to obtain the files.

  6. Acknowledge receipt of the administrative file.

8.4.1.13 
(10-26-2007)
APS Tax Examiner Assigned a New Docketed Case

  1. Upon receipt of a newly assigned docketed regular OR “S”
    case administrative file from the APS Processing Team Manager (PTM), promptly takes the following steps.

    Note:

    Promptly means within two calendar days after receipt of the file in APS (and no later than 40 days after the petition is
    served, to prevent the preparation and processing of unnecessary “dummy”
    files).

  2. Verify the contents of the administrative file to determine if all documents, returns, etc. listed on transmittal Form 3210
    are present in the file. If everything was received, sign the acknowledgment copy of the Form 3210 and return it to the originator
    by mail or fax. Keep a copy of the Form 3210 in the case file.

  3. Print TLCATS Case Screen 1 – Identify and highlight the Answer Due Date, Caption, and Years Petitioned.

  4. Card the case on ACDS using the administrative file and TLCATS documents.

  5. Verify and act upon non-petitioned years (NPY) and non-petitioning spouses (NPS). Rely on TLCATS for the years and parties
    identified in the petition. Take immediate and appropriate steps to assess, when necessary. Upon receipt of the case file
    from the Campus, examine TLCATS and the notice of deficiency to determine whether all of the parties named, and all the years
    covered, in the notice of deficiency are included in the petition. If any of the parties or years shown in the statutory notice
    are not listed on TLCATS, follow procedures in IRM 8.20.6, Appeals Case Processing Manual, Interim Actions, Remittances,
    Partials, Transfer and Returns.

    Note:

    IF… THEN…
    Any of the parties or years shown in the notice of deficiency are not listed on TLCATS…

    • Contact Counsel to see if there is a non-petitioning spouse or year

    • If it is necessary to protect the statute, make the assessment before verification from Counsel is received.

  6. Identify, based upon existing case routing guidelines, which Appeals office will consider the docketed case when it is returned
    by Counsel after answer and which APS office will process the case upon closing. Complete the Appeals/Counsel Routing Cover
    Sheet (A copy of the Cover Sheet is posted on the Appeals web site). This document instructs Counsel to send the administrative
    file to the specified Appeals office address, to the attention of the Lead Appeals Team Manager (ATM), for assignment and
    consideration. It also clearly identifies the Appeals office and APS address the administrative file must be returned to for
    closing.

    Caution:

    If the docketed administrative file has an Form 872-A alert on the cover do not place an Appeals/Counsel Routing Cover Sheet
    over it until the APS employee verifies all periods in the Notice of Deficiency are addressed in the petition.

  7. Update ACDS for EACH docketed work unit where the administrative file is sent to Counsel for answer with ACTION = “ANSWER”
    and a “TODATE”
    equal to the date the file was sent. This ensures the “ANSWER”
    follow-up report is generated and worked.

  8. Send the administrative file to the appropriate Counsel office for answer, as identified in TLCATS Screen 1.

  9. Close the DIMS record by entering a date in the “Case on ACDS”
    field = the date the case was created on ACDS (ACDS CREATED).

    Note:

    All APS employees must ensure they timely card cases and consistently close DIMS records. This practice reduces or eliminates
    the need for Covington APS to create dummy files for cases in which the original administrative files are already in Appeals.

8.4.1.13.1 
(10-26-2007)
APS Review of File After Receipt

  1. Upon receipt of the case file from the Campus, examine the petition and the notice of deficiency to determine whether all
    of the parties named in, and all the years covered by, the notice of deficiency are included in the petition. If any of the
    parties or years shown in the notice of deficiency are omitted from the petition, follow procedures in IRM 8.20.6, Appeals
    Case Processing Procedures, Interim Actions, Remittances, Partials, Transfers and Returns.

  2. Verify the contents of the administrative file to determine if all documents, returns, etc. listed on transmittal Form 3210
    are present in the file.

  3. Determine if the items listed on the Form 3210 were received, sign the acknowledgment copy of the Form 3210 and return it
    to the originator. Keep a copy of the Form 3210 in the case file.

  4. If any of the parties or years shown in the notice of deficiency were omitted from the petition take the following steps:

    1. Contact Counsel to see if there is a non-petitioning spouse or non-petitioned year.

8.4.1.13.2 
(10-26-2007)
APS Docketed Case ACDS Carding Procedures

  1. Establish each docketed receipt on ACDS prior to transmitting the administrative file to Counsel for filing an answer.

  2. Complete items on the case inventory and return information screen as applicable and in accordance with established procedures.
    See IRM 8.20.3, Appeals Centralized Database System (ACDS), for ACDS fields and acceptable data.

  3. The following items are automatically entered into ACDS based on information from the Docket List:

    • Docket Number – DKTNO — If docketed, enter the docket number as it appears on the petition or Docket List.

    • List Number

    • Xmittal Date (date of Docket List)

    • Petitioners Name & Address

    • Issuing Office

    • Appeals Office

    • Counsel Office

    • Docket List years petitioned

    • Additional Years

    • SN Date – If applicable, enter the date the statutory notice was issued.

  4. The same instructions used to establish normal cases, as outlined in IRM 8.20.3, apply when establishing docketed case on
    CASES. In addition, follow the additional instructions described below:

    1. PART is computer generated and displays the number “2″
      if the case is docketed and under Appeals jurisdiction. It displays the number “3″
      if the case is docketed and under Counsel jurisdiction.

    2. Leave the AO = Appeals Officer (userid/POD/Group) field blank on a docketed case where an answer to a petition is required
      by Counsel and an assignment is not being made.

    3. REQAPPL (Request Appeal – Date Taxpayer Requested Appeal) – Use the date the petition was filed.

    4. DKTNO (Docket Number) is the number used by Tax Court for control purposes when a petition is filed, or by District or Claims
      Court when a complaint is filed. This item is only completed in docketed cases. Every docket number is a separate work unit.
      Obtain the information for this from various documents in the administrative file, i.e., petition, Docket List, etc. The docket
      number for Tax Court cases is written in NNNNN-YY format, with N being the number and Y being the year docketed. If it is
      a small tax case, enter S after the year. For District or Claims Court cases use the characters and numbers shown on the filed
      complaint.

    5. DC OFFICE (Counsel Office) is only completed in docketed cases. Enter the three digit code identifying the Counsel Office
      assigned to the case. See IRM Exhibit 8.20.3-3 for a list of Counsel codes. Obtain the information for this item from documents
      in the administrative file, i.e., Docket List, petition, etc., or from CATS.

    6. ATTORNEY (Counsel Attorney) is only completed in docketed cases. Enter the name of the counsel attorney assigned to the case,
      last name first. Obtain this information from TLCATS or Form 1734, Transmittal Memorandum.

    7. SNTYPE is completed on all docketed cases if a notice of deficiency or determination letter or other notice was issued. Also
      enter the SNTYPE if the case is received in 90 or 150 day status. IRM 8.20.3.3.28, SNTYPE (Source and Type of Notice of Deficiency/Determination
      Letter Issued), contains descriptions of valid SNTYPEs.

    8. SNDATE is the date the notice of deficiency or determination letter or other notice was issued.

    9. If the return being established is docketed before the Tax Court, enter DOCKT in the Statute Code field.

  5. Update AIMS using IDRS command code AMSTUA to:

    1. STATUS 82 if the return is docketed.

      Note:

      Each Appeals Office is assigned a 2-digit code called the AIMS Office Code (AOC). This code is used to designate a location
      of the primary office. When establishing a docketed case, a “2″
      precedes the 2-digit code. See Document 6209, Section 12.

    2. STATUS 80 if the return is non-docketed. If the work unit involves a non-docketed reference return, establish the case as
      a related record with the same work unit number . The AIMS status is 80 for the reference return. When establishing a non-docketed
      case, a “1″
      precedes the 2-digit code. See Document 6209, Section 12.

8.4.1.14 
(10-26-2007)
Dummy File Procedures

  1. The Covington Campus APS office is currently assigned responsibility for preparing the dummy file for answer, carding the
    case on ACDS, and promptly sending it to Counsel by fax or overnight mail. The most current information regarding assignment
    of dummy file responsibilities in APS is found on the APS page of the Appeals web site.

  2. The dummy file for answer consists of copies of all available information obtained from a variety of sources. Most IRS Campus
    Exam sourced cases are controlled on the Correspondence Examination Automation System (CEAS). In Appeals, designated centralized
    DIMS and Covington Campus APS employees have permission to access CEAS for research only.

  3. A “dummy”
    administrative file contains all available information related to the case. The dummy file for answer purposes must contain,
    at a minimum: A “dummy”
    administrative file contains all available information related to the case. The file contains the following:

    • CATS prints

    • CEAS information, if available, or if not, a clearly visible statement that no CEAS is available

    • Appeals/Counsel Routing Cover Sheet (posted on the Appeals web site)

    • Copy of Counsel legal file documents

    • RTVUE

    • Transcript of account

    • Petition

    • IDRS research

    • Other relative documents.

8.4.1.14.1 
(10-26-2007)
Dummy File Carding Procedures

  1. The ACDS record is created based on all available information, such as the petition, notice of deficiency (if available),
    CATS, IDRS, AIMS and CFINQ information. Use all obtainable information to card the case on ACDS. Card the case using the correct
    Appeals Area office by selecting it from the drop down list on the Main CASES menu.

  2. Be sure to promptly and accurately verify and act upon Non-petitioning Spouse, Non-petitioned Years and potential dismissals
    on all dummy file cases. However, do not abate premature assessments on dummy file cases. The APS office with ACDS control
    of the case abates premature assessments when directed to do so by Counsel.

  3. On ACDS, write “DUMMY FILE”
    in “Notes”
    to indicate it is a “dummy”
    file and the actual administrative file was received.

    Note:

    Remove the “DUMMY FILE”
    entry from “Notes”
    when the actual administrative file is received.

  4. In addition, enter the following information on ACDS:

    • RECDATE = date dummy file created

    • REQAPPL = date petition filed

    • ACTION = ANSWER

    • TODATE = equal to the date the case was created – also equal to the date the dummy file is forwarded to Counsel

    • FROMDATE = Blank

    • LACTION = DKTLST XXX (Dkt List #)

    • LTODATE = equal to the date the case was created – also equal to the date the dummy file is forwarded to Counsel

      Note:

      Use of LACTION DKLST XXX with a valid TODATE and blank FROMDATE indicates the actual administrative file was not received.

      Caution:

      If the original administrative file is later received, do not change the ACDS RECDATE field to the new date.

  5. Include the following special instructions on the ACDS record.

    • ACTION = PETNRCVD

      Note:

      Use of ACTION PETNRCVD with a valid TODATE and blank FROMDATE indicates the actual administrative file was not received and
      also causes the case to appear on the PETNRCVD follow-up report.

    • TODATE = date the “dummy file”
      case was created.

    • FROMDATE – leave blank

  6. Do not close DIMS until the original admin file is received.

8.4.1.14.2 
(10-26-2007)
Administrative File Received After Dummy File Created/Carded

  1. When the original administrative file is received after a dummy file for answer is created and carded on ACDS, research to
    determine the location of the dummy file so the administrative file can be associated.

    • Research ACDS to determine if Appeals has possession of the dummy file. If the dummy file is currently assigned to an AO/SO,
      prepare a Form 3210 and send the original administrative file to the AO/SO to associate with the dummy file. (Notes field
      = “admin file received, associate with dummy file”
      .)

    • Research CATS to determine if Counsel has possession of the dummy file. If the dummy file is currently in Counsel, prepare
      a Form 3210 and send the original administrative file to Counsel to associate with the dummy file. If the dummy file location
      is unclear on CATS, call Counsel to verify the dummy file location. (Notes field = admin file to Counsel to associate with
      dummy file)

  2. Do not change the ACDS RECDATE field to the new date.

  3. Update ACDS as follows:

    • In “NOTES”
      , record the actual received date as follows: “ADMIN FILE RECD MM/DD/YYYY ASSOCIATED W/DUMMY FILE”
      .

    • Input a FROMDATE in LACTION = to the date the original administrative file is received.

    These entries indicate the case was originally assigned as a dummy file but the actual administrative file was later received
    and associated with the dummy file.

  4. Close the DIMS Record by entering a date in the “Case on ACDS”
    field equal to the date the original administrative file was received.

8.4.1.14.3 
(10-26-2007)
Dummy File for Consideration

  1. If no administrative file is received and Counsel answers the petition using the dummy file documents, Counsel includes a
    copy of the petition, answer, Designation of Place of Trial, and any other pertinent information from the legal file, in the
    dummy file. Counsel sends the dummy file for consideration DIRECTLY to the Appeals office and Appeals Team Manager (ATM) identified
    in the Cover Sheet previously placed on top of the dummy file for answer by APS.

  2. For additional information see section entitled, Docketed Case for Assignment and Consideration After Answer. See IRM 8.4.1.14.

8.4.1.15 
(10-26-2007)
APS Procedures on Non-Petitioning Spouse Cases

  1. If the notice of deficiency is issued to both a husband and wife who filed a joint return and only one spouse petitions the
    U.S. Tax Court and the other spouse agrees or does not take appeal action, this is considered a non-petitioning spouse case.

  2. Verify the address of both taxpayers on all non-petitioning spouse cases. Use IDRS command code SPARQ to determine if the
    last known address of both taxpayers is the same as the address on the notice of deficiency.

  3. When it is clear the notice of deficiency was sent to the last known address, ensure a default assessment is made on the non-petitioning
    spouse. If not, make the default assessment.

  4. If separate residences were established and it is not clear from the administrative file that both taxpayers received the
    notice of deficiency, take the following actions:

    1. Immediately input the case on CASES following the procedures set forth below to control the statute date on ACDS for the taxpayer
      who did not receive the notice of deficiency.

    2. In notes, indicate “spouse at different address”
      .

    3. Immediately deliver the case to the Processing Team Manager (PTM) to determine the appropriate action.

    4. The PTM may need to immediately transmit the case to Counsel to determine the appropriate action to take on the case.

      Note:

      A notice of deficiency sent to an address other than the last known address is NOT valid. When this occurs, an assessment
      cannot be made as a default assessment. (In some cases, a protective assessment may be requested by Counsel until it is determined
      if the notice of deficiency was mailed to the proper address.) The statute for the taxpayer with the invalid notice of deficiency
      is the normal or extended statute (before the notice of deficiency was issued).

    5. If the statute is still open, issue a new notice of deficiency. Refer the case to the lead Appeals Team Manager (ATM). The
      lead ATM determines whether to return the case to Compliance or issue a notice of deficiency.

    6. If the statute is not open, follow established procedures for preparing Form 3999, Barred Statute Report. See 8.21.7.

  5. Information pertaining to closing a non-petitioning spouse case is found in a subsequent section. See IRM 8.4.1.32.

8.4.1.15.1 
(10-26-2007)
Order of Carding the Non-Petitioning Spouse Work Unit

  1. A non-petitioning spouse case requires special CASES procedures to create a work unit that includes a key case (the joint
    return) and two related cases, one for each spouse. First establish the non-petitioning spouse, next establish the petitioning
    spouse, and lastly, establish the key case for the joint return.

8.4.1.15.1.1 
(10-26-2007)
Carding the Non-Petitioning Spouses Case

  1. Establish a separate case for the non–petitioning spouse using the same work unit number as the petitioning spouse. Follow
    normal ACDS procedures and follow the additional instructions described below:

    1. TPName — Enter the name of the non-petitioning spouse.

    2. Address — Enter the address of the non-petitioning spouse.

    3. TIN — Enter the TIN of the non-petitioning spouse.

    4. MFT — Enter MFT 31.

    5. TYPE — Enter REF.

    6. FEATRCD — Enter NS to identify a non-petitioning spouse case.

    7. REQAPPLS — Leave blank.

    8. DKTNO — Leave blank.

    9. KEYTP — Enter the name of the joint return.

    10. KEYTIN — Enter the primary TIN of the joint return.

    11. SNTYPE — Leave blank unless a separate notice of deficiency was issued.

    12. SNDATE — Leave blank unless a separate notice of deficiency was issued.

    13. NOTES — You may want to enter “Non-Petitioning Spouse”
      .

  2. On the case return information screen, follow the normal ACDS procedures except for the following:

    1. AIMS Indicator — Enter E since the individual return is not controlled on AIMS.

    2. Statute Date — Enter the normal or extended statute date.

    3. Statute Code — Leave blank.

    4. PropdTax and PropdPen — Leave these fields blank.

    5. Duplication — Leave blank.

8.4.1.15.1.2 
(10-26-2007)
Carding the Petitioning Spouses Case

  1. Establish a separate case for the petitioning spouse following normal ACDS procedures and follow the additional instructions
    described below:

    1. TPName — Enter the name of the petitioning spouse.

    2. Address — Enter the address of the petitioning spouse.

    3. TIN — Enter the petitioning spouse TIN.

    4. MFT — Enter MFT 31.

    5. TYPE — Enter I.

    6. FEATRCD — Enter NS to identify a non-petitioning spouse case.

    7. REQAPPL — Enter the date the petition was filed..

    8. DKTNO — enter docket number as it appears on the petition

    9. KEYTP — Enter the name of the joint return.

    10. KEYTIN — Enter the name of the primary TIN on the joint return.

    11. SNTYPE — enter type of SN issued.

    12. SNDATE — enter date notice of deficiency was issued.

    13. NOTES — You may want to enter “Petitioning Spouse”
      .

  2. On the case return information screen, follow the normal procedures except for the following:

    1. AIMS Indicator — Enter E since the individual taxpayer is not on AIMS.

    2. Statute Date — Leave blank.

    3. Statute Code — Enter DOCKT.

    4. PropdTax and PropdPen— Leave these fields blank.

    5. Duplication — Leave this field blank.

8.4.1.15.1.3 
(10-26-2007)
Carding the Joint Return

  1. Establish a separate record for the joint return using the same work unit number as the petitioning spouse. Follow normal
    ACDS procedures and follow the additional instructions described below:

    1. FEATRCD — Enter NS to identify a non-petitioning spouse case.

    2. TP Type – valid with only MFT 30 Enter

      P – if the petitioner is the primary TIN

      S – if the petitioner is the secondary TIN

    3. REQAPPLS — Enter the date the petition was filed by the petitioning spouse.

    4. DKTNO — Enter the docket number as it appears on the petition or Docket List.

    5. KEYTP — Leave blank.

    6. KEYTIN — Leave blank.

  2. On the case return information screen, follow normal ACDS procedures except for the following:

    1. Statute Date — Leave blank.

    2. Statute Code — Enter NPS.

    3. PropdTax and PropdPen — Enter the tax deficiency and penalty(s) amounts shown on the notice of deficiency.

    4. Duplication — Leave blank.

8.4.1.16 
(10-26-2007)
Non-Petitioned Year(s)

  1. See IRM Part 8.2.2.12, APS Actions on Non-Petitioned Year(s) in Multiple Year Statutory Notice, for procedures relating to
    assessment of a year included on the notice of deficiency but not on the petition.

8.4.1.17 
(10-26-2007)
Joint Return — Separate Petitions

  1. If the notice of deficiency is issued to both a husband and wife who filed a joint return and each files a separate petition
    with the U.S. Tax Court, each docket number is a separate work unit number. Follow the procedures in the following subsections
    to establish the returns on ACDS.

8.4.1.17.1 
(10-26-2007)
Card the Primary TIN of a Joint Return when Taxpayers File Separate Petitions

  1. When one notice of deficiency is issued to both a husband and wife and each files a separate petition, each docket number
    is a separate work unit number.

  2. Establish a work unit for the primary TIN of a joint return on the case inventory screen. This is a related case record. Follow
    normal ACDS procedures and follow the additional instructions described below:

    1. TPName — Enter the name of the taxpayer with the primary TIN on the joint return.

    2. Address — Enter the address of the taxpayer with the primary TIN on the joint return.

    3. TIN — Enter the primary TIN of the joint return.

    4. MFT — Enter MFT 31.

    5. DKTNO — Enter the docket number as it appears on the petition or Docket List.

    6. KEYTP — Enter the name of the joint return.

    7. KEYTIN — Enter the primary TIN of the joint return.

    8. NOTES — Enter “Taxpayers Filed Separate Petitions – Related DKTNO (enter the docket number of the other spouse)”
      .

  3. On the case return information screen, follow the normal ACDS procedures except for the following:

    1. AIMS Indicator — Enter E since the individual taxpayer is not controlled on AIMS.

    2. Statute Date — Leave blank.

    3. Statute Code — Enter DOCKT.

    4. PropdTax and PropdPen — Leave blank.

    5. Duplication — Leave blank.

8.4.1.17.2 
(10-26-2007)
Carding the Joint Return when Taxpayers File Separate Petitions

  1. Establish a separate record for the joint return using the same work unit number as the primary TIN key case This record is
    the key case record. On the case inventory screen follow normal ACDS procedures and follow the additional instructions described
    below:

    1. REQAPPLS — Enter the date the petition was filed for the primary taxpayer of the joint return.

    2. DKTNO — Enter the docket number as it appears on the petition or Docket List.

    3. KEYTP — Leave blank.

    4. KEYTIN — Enter the secondary taxpayers TIN for cross referencing.

    5. NOTES — Enter “Taxpayers Filed Separate Petitions – Related DKTNO (enter the docket number of the other spouse)”
      .

  2. On the case return information screen, follow normal ACDS procedures except for the following:

    1. Statute Date — Leave blank.

    2. Statute Code — Enter N/A.

    3. Proposed Def/O/A (Tax and/or (Pen)) — Enter the tax deficiency and penalty(s) for each year as they appear on the statutory
      notice.

    4. Duplication — Leave blank.

8.4.1.17.3 
(10-26-2007)
Card the Secondary TIN when Taxpayers File Separate Petitions

  1. Establish a separate record with a new work unit number for the secondary TIN of a joint return. On the case inventory screen
    follow normal ACDS procedures and follow the additional instructions described below:

    1. TPName — Enter the name of the taxpayer with the secondary TIN on the joint return.

    2. Address — Enter the address of the taxpayer with the secondary TIN on the joint return.

    3. TIN — Enter the secondary TIN of the joint return.

    4. MFT — Enter MFT 31.

    5. REQAPPLS — Enter the date of the petition of the secondary taxpayer.

    6. DKTNO — Enter the docket number as it appears on the petition or Docket List.

    7. KEYTIN — Enter the primary TIN of the joint return for cross referencing.

    8. NOTES — Enter “Taxpayers Filed Separate Petitions – Related DKTNO (enter the docket number of the other spouse)”
      .

  2. On the case return information screen, follow normal ACDS procedures except for the following:

    1. AIMS Indicator — Enter E since the individual taxpayer is not controlled on AIMS.

    2. Statute Date — Leave blank.

    3. Statute Code — Enter DOCKT.

    4. PropdTax and PropdPen — Leave blank.

    5. Duplication — Leave blank.

8.4.1.17.4 
(10-26-2007)
Premature Assessments and Command Code AMSTUR

  1. If the AIMS account for a docketed tax period is in Status 90 because the Compliance function processed an assessment before
    being notified a petition was filed, contact Case Processing who is responsible for this action. IRM 4.14.1.21.3 outlines
    their process.

  2. Premature assessments need to be abated. Secure a transcript or TXMOD, prepare and process Form 3870, Request for Adjustment,
    using Priority Code 2, Hold Code 2 and annotating in Item 11, priority abatement needed

8.4.1.18 
(10-26-2007)
Substitute for Return (SFR) Program Cases Received in Docketed Status

  1. Usually these cases are received from the Campus in docketed status. Although it is possible for the taxpayers to request
    an Appeals hearing, time constraints limit the number of cases received in non-docketed status.

  2. When received, establish them on AIMS (CC/AM424A) if not done by the Campus prior to sending the case.

  3. These cases are IMF accounts only.

  4. Establish on CASES following normal procedures except for:

    • FEATRCD – Enter “NF”

    • STATUTE CODE – Enter “DOCKT”
      or “SUB”
      as appropriate

    Note:

    If a delinquent return was secured by Compliance subsequent to a processed SFR, if non-docketed and a return is signed by
    the taxpayer, the statute date is entered – three years from the received or signature date, whichever is later.

  5. Typically, the SFR only involves one spouse even though both husband and wife may have petitioned the Tax Court. Until a joint
    filing status is approved by the Appeals Officer, only the name/TIN reflected on the SFR are established on AIMS/ACDS. When
    appropriate, the case is converted from Separate to Joint at closing.

8.4.1.19 
(10-26-2007)
Delinquent Joint Return Received – Docketed Case Exists for One Spouse

  1. Delinquent returns are sometimes filed with the Appeals Officer. Guidance is provided for processing the delinquent returns
    in various situations most common in Appeals.

  2. If Appeals receives a delinquent JOINT return when a docketed case already exists for one spouse or the other, the return
    must be processed to APS to “post as an amended return”
    against the docketed spouses account and to assess.

  3. Once a notice of deficiency is issued, the election of “joint filing status”
    must be made on a return. A Form 870 or stipulated decision document does not constitute a return for this purpose.

  4. Control the statute on the non-docketed spouse as a reference return.

8.4.1.19.1 
(10-26-2007)
Delinquent Return Received – SFR Previously Processed

  1. If Appeals receives a delinquent return for a non-filer when a substitute for return was previously processed and a TC 150
    has posted to Master File, assess the amount of tax and credits shown on the return and any applicable penalties (as directed
    by AO).

  2. For docketed cases, the liability can and generally is assessed. The exception is when the taxpayer is clearly protesting
    rather than admitting to the liability. Counsel must be consulted before making an assessment. In addition, penalties are
    not assessed on docketed cases unless the Appeals Officer or Counsel Attorney determines the amounts are no longer in dispute.

  3. When the Appeals Officer determines an interim assessment should be made, he/she verifies:

    1. the name and social security number;

    2. the address. If the address is incorrect, the non-filer is asked to line through the address shown and enter the correct address;

    3. the math on the return for accuracy. (the Tax Computation Specialist can also do this).

  4. APS will:

    1. Prepare Form 2363 and input the entity changes (name, TIN, address, filing status, etc.) to correct Master File as directed
      in IRM 25.7.

    2. Process a partial assessment for the amounts reflected on the return. Include a copy of the return for APS. Follow the procedures
      described in IRM 8.20.6.4.6, Assessing the Non-Petitioning Spouse. (Do not forward the delinquent return to the Campus for
      processing because an “SFR”
      was previously processed and a TC 150 already posted to establish the account. The delinquent return is considered an
      amended return).

    3. Request input of the return processible date, RPD. This is the date the return is received. The RPD can be updated through
      IDRS using REQ54.

    4. Prepare Form 3177 or Form 4844 (which is input on IDRS using REQ77). Enter TC 971, AC 013 with Transaction Date as of the
      return received date. Transaction Code 971 with Action Code 13 indicates an amended return was received. Master File computes
      the Assessment Statute Expiration Date (ASED) based on the return received or signature date.

  5. The following special rules apply for entries on Form 5403:

    1. Enter Hold Code 2 in Item 07.

    2. Do not make an entry in Item 08, Agreement Date.

  6. Take the following line items from the return and enter appropriate transaction code/reference numbers as indicated below:

    • Tax Liability – TC 300, Item 12

    • Adj. Gross Income – IMF only Ref 888, Item 15

    • Taxable Income – Ref 886, Item 15

    • Self Employment Income – Ref 878/879, Item 15

    • Withholding Credit – Ref 806, Item 15. Include excess FICA in this adjustment. Do not include estimated tax payments since
      such payments are already posted to Master File.

    • Self Employment Tax – Ref 889, Item 15

    • Earned Income Credit – Ref 764, Item 15

  7. After verification of the partial assessment, update ACDS to reflect the revised statute date and the statute code “ASESD.
    ”

  8. If the Appeals Officer accepts the delinquent return as filed by the taxpayer and has concluded consideration, process the
    case as a final closing. See IRM 8.20.7, Appeals Case Closures.


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