Sample Joint Committee ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there are reported the following refunds or credits of income tax in favor of [identification of taxpayer] Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State.Second paragraph of template - Tabulation of examination results - Summary table of Refunds or CreditsSummary table includes columns for the Year, Deficiencies, Proposed Refunds Section 6405(a), Tentative Allowances Section 6405(b), Net Refunds or Credits for years 201312 through 201512.Third paragraph of template - Note for Deficiencies column of above tableOnly use the Deficiency column if appropriate. If a refund was prematurely allowed, it should be included in the 6405(a) column. If there are only proposed non-jurisdictional amounts, do not include this column in the tabulations. Instead, add as a narrative here.Fourth paragraph of template - Proposed refunds and deficiencies for non-reportable yearsIn addition, there is a proposed refund in the amount of $53,450 for 201212.Fifth paragraph of template - Primary reason for the refundThe refunds resulted primarily from the carryback of a net operating loss (NOL) and unused credits from the year 201612.

Continuation of Sample Joint Committee ReportFirst paragraph of template - Reference to enclosed spreadsheetsThe taxable income and tax liability reported on the returns and as finally determined are shown on the enclosed spreadsheets. Also note the following here if applicable:tentative refunds from unexamined source years,related taxpayers for which reports are being submitted concurrently,prematurely allowed refunds or credits,claims from unexamined source years (modified expedite refund report)statement that the case is being submitted under the unagreed case procedures per IRM 4.36.3.7.1, Cases with Unagreed Issues — Minimum Refund, and that a supplemental report will be submitted. See sample language for each situation below]Second paragraph of template - Tentative refunds from unexamined source yearsFurther, under IRM 4.36.3.7.2, this is to advise you that there is the following tentative allowance carryback arising from the unexamined source year 201712, whose examination will not be completed for a substantial period of time (estimated to be in excess of six months). Upon completion of such examination, the refund will be the subject of a supplemental reporting, provided the refund amount satisfies the reporting requirements of IRC Section 6405.Third paragraph of template - Summary table of tentative allowance carrybacks Summary table includes columns for Carryback Year, Tentative Allowance and Source Year.Fourth paragraph of template - Related taxpayersIn addition, refunds resulted from the carryback of a net operating loss and a capital loss from (name of related taxpayer) 201612 tax return.Fifth paragraph of template - Prematurely allowed refundsThe proposed refund of $5,000,500 for 201412, included above, was not previously reported as requiredSixth paragraph of template - Previously unreported refundsThe tentative refund of $5,450,000 for 201312, included above was previously examined but not reported as required.Seventh paragraph of template - Claims from unexamined source years (modified expedite refund report)This report is submitted under the procedures contained in IRM 4.36.3.7.3. The taxpayer has requested that this refund be made since the examination for the 201412, 201512 and 201612 tax years will not be completed within six months. It has been determined that no disadvantage will occur to the Government in paying the refund. Security will be posted for the amount of the proposed refund and a copy of the Collateral Security Agreement is enclosed for your consideration. A supplemental report will be submitted after the completion of the examination if required.Eighth paragraph of template - Unagreed issues/minimum refundThis report is submitted under the procedures contained in IRM 4.36.3.7.1. The unagreed issues will require a substantial period of time to resolve and the delay would deprive the taxpayer of a timely refund. The refunds reported reflect the minimum amount to which the taxpayer is entitled, regardless of the outcome of the unagreed issues. A supplemental report will be submitted after the completion of the examination and/or resolution of the unagreed issues.

Continuation of Sample Joint Committee ReportFirst paragraph of template - Taxpayer HistoryThe taxpayer was incorporated on [date of incorporation] May 4, 1949, [principal business activities and products] and is engaged in real estate development. [Changes in activity or products if pertinent to understanding the adjustments or causes of the overassessments.] The taxpayer is also active in the family entertainment business and has interests in soft drinks and heavy construction equipment. [Description of stock ownership] The company’s stock is widely held and traded on the New York Stock Exchange. [Explanation of structure and any changes in capital structure, mergers, or corporate acquisitions/dispositions] There were no major acquisitions during the years covered by this report. [Also include here: names or number of subsidiaries or affiliates, causes for short taxable years.]Second paragraph of template - Continuation of Taxpayer History[Brief statement of the economic reason for any net operating loss or capital loss, or the reason for the refund or credit] The primary reason for the loss was due to competition from major rivals. Also, technological improvements caused rapid obsolescence of equipment.Third paragraph of template - Prior Examination History[Mention prior examinations and Appeals settlements; enclose copies of prior RARs and Appeals Memorandums] Enclosed is the examination report, dated November 14, 2016, for the 201312 year.Third paragraph of template - Continuation of Prior Examination History[Statement of no prior examination] None of the other years in this report were previously examined. Third paragraph of template - Continuation of Prior Examination History[State release date of previous Joint Committee report, if applicable]Fourth paragraph of template - Current Examination Activity[List of claims and applications for tentative refund filed by the taxpayer, including the amounts and basis for filing. If numerous filings, list on a separate attachment.] On June 30, 2017, the taxpayer filed a timely application for tentative refund on Form 1139 requesting the income tax refunds of $1,325,000 for 201412 and $4,600,000 for 201512 based on an NOL and unused credits from 201612. [Or use the following or similar type format] On June 30, 2017, the taxpayer filed a timely application for tentative refund on Form 1139 requesting the income tax refunds listed below, based on an NOL and unused credits from 201612.Fourth paragraph of template - Continuation of Current Examination ActivitySummary table includes columns for Year, Refund Requested and Type of Carryback.Fifth paragraph of template - Continuation of Current Examination Activity[Explanation of Premature Refund] On May 3, 2016, the taxpayer filed a Form 1120X to claim additional operating expenses for the year 201412. The refund in the amount of $5,000,500 was prematurely issued by the IRS Service Center prior to submission of a report to the Joint Committee on Taxation and is now being reported.

Continuation of Sample Joint Committee ReportFirst paragraph of template - [Statement of survey action if all or some of the years were surveyed]In a Form 1900, Income Tax Survey, report dated January 3, 2019, the examiner recommends acceptance of the reported NOL for 201612 and unused credits, as well as its carryback into 201412 and 201512, resulting in the indicated tentative allowances. The examiner’s analysis of the returns did not disclose any large, unusual or questionable items that would warrant examination. The examiner contacted the taxpayer to learn the economic reason for the reported NOL.Second paragraph of template - [Statement of examination report]Enclosed is the examination report, May 21, 2019, for the years 201212 through 201612.Third paragraph of template - [If applicable, (1) explanation of a jurisdictional amount that was not previously reported; (2) change of accounting method comments.]On April 30, 2014, the taxpayer filed a timely application for tentative refund on Form 1139 requesting the income tax refund of $5,450,000 for 201312 based on an NOL from 201512. This year was previously examined. In accordance with IRM 4.36.5.5, this jurisdictional amount was not previously reported to your Committee and is being reported at this time.Fourth paragraph of template - [Statement whether it is a Large Corporate Compliance case]This is (not) a Large Corporate Compliance case.Fifth paragraph of template - [Statement whether there is a Power of Attorney and if it is enclosed]There is no power of attorney on file for the years covered by this report or There is a power of attorney on file for the years covered by this report, and a copy is enclosed.Sixth paragraph of template - [Statute of Limitations dates (regular and special) for each year]Summary table includes columns for the Year, Original Statute as Extended and Special Statute for years 201312 through 201612. If applicable, include all source years.Seventh paragraph of templateThe above overassessments are approved. If you have any questions, please contact the JC Specialist at [JCS email address] and myself at [JCR team manager email address].End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosures:Joint Committee Spreadsheet for Regular Tax, AMT & Credits, Prior RAR dated 11/14/2016 and Forms 886-A, Current RAR dated 05/21/2019 and Forms 886-A, Power of Attorney, [Other: Exhibits, Form 3115]

Sample Regular ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there are reported the following refunds or credits of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year, Deficiency, Tentative Allowances Section 6405(b), Net Refunds or Credits for years 201412 through 201612.Third paragraph of templateIn addition, there is a proposed refund in the amount of $23,759 for 201312.Fourth paragraph of templateThe refunds resulted primarily from the carryback of a net operating loss (NOL) and unused credits from 201712.Fifth paragraph of templateThe taxable income and tax liability reported on the returns and as finally determined are shown on the enclosed spreadsheets.Sixth paragraph of template - Taxpayer HistoryThe taxpayer was incorporated on May 4, 1949, and is engaged in real estate development. The taxpayer is also active in the family entertainment business and has interests in soft drinks and heavy construction equipment. The company's stock is widely held and traded on the New York Stock Exchange. There were no major acquisitions during the years covered by this report.Sixth paragraph of template - Continuation of Taxpayer HistoryThe primary reason for the loss was due to competition from major rivals. Also, technological improvements caused rapid obsolescence of equipment.

Continuation of the Sample Regular ReportFirst paragraph of template - Prior Examination HistoryEnclosed is the examination report, dated November 14, 2017, for the 201412 year. None of the other years in this report were previously examined.Second paragraph of template - Current Examination ActivityOn June 30, 2018, the taxpayer filed a timely application for tentative refund on Form 1139 requesting the income tax refunds of $450,000 for 201412, $325,000 for 201512, and $4,600,000 for 201612 based on an NOL and unused credits from 201712.Third paragraph of template - Continuation Current Examination ActivityEnclosed is the examination report, dated May 21, 2019, for the years 201312 through 201712.Fourth paragraph of template - Continuation Current Examination ActivityThis is not a Large Corporate Compliance case. There is no power of attorney on file for the years covered by this report.Fifth paragraph of template - Statutes of LimitationsSummary table includes columns for the Year, Original Statute or as Extended and Special Statute for years 201312 through 201712. Sixth paragraph of templateThe above overassessments are approved.End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosures:Joint Committee Spreadsheet Analysis for Regular Tax, AMT & Credits, Prior RAR dated 11/14/2017 and Forms 886-A, Current RAR dated 05/21/2019 and Forms 886-A

Sample Short Form ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there are reported the following refunds or credits of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year and Tentative Allowances Section 6405(b), for the year 201412.Third paragraph of templateThe case has been fully surveyed. The refund resulted primarily from a net operating loss carryback from tax year 201612. XXX, a holding company incorporated in 1995 and headquartered in Anytown, CA, is a privately held media company. The principal business is newspaper publishing. The primary reason for the loss in 201612 was a decline in revenue.Fourth paragraph of templateThe above overassessment is approved. There is a POA on file if needed.End of Letter - ClosingSincerely, Team manager signature, Team Manager

Sample Expedite Refund ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there are reported the following refunds or credits of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year and Proposed Refunds Section 6405(b) for years 201412 through 201612.Third paragraph of templateThe refunds resulted primarily from claims for adjustments to various income and expenses.Fourth paragraph of templateThe taxable income and tax liability reported on the returns and as finally determined are shown on the enclosed spreadsheets.Sixth paragraph of template - Taxpayer HistoryThe taxpayer, a holding company, was incorporated in the State of California on January 1, 2010. The headquarters are located in Anytown, California. The taxpayer operates branches throughout the Anytown, CA metro area. The company offers full-service banking services designed to meet the needs of retail and commercial customers in the markets in which it operates with a significant focus on the resolution of assets acquired from the FDIC. The bank is subject to the regulations of certain federal and state agencies and is periodically examined by those regulatory agencies.Sixth paragraph of template - Continuation of Taxpayer HistoryThe company is privately held with the majority of the company owned by private equity companies. The ABC, LP holds the largest share of ownership at 45%.Seventh paragraph of template - Continuation of Taxpayer HistoryThere were no acquisitions or dispositions of subsidiaries and no SRLY or CERT issues.Eight paragraph of template - Continuation of Taxpayer HistoryThe primary reason for the refunds is the overstatement of income and the omission of deductions from the return as originally filed.

Continuation of the Sample Expedite Refund ReportFirst paragraph of template - Prior Examination HistoryNone of the years included in this submission have been previously examined.Second paragraph of template - Current Examination ActivityOn June 30, 2018, the taxpayer filed three timely amended returns (Forms 1120X) requesting the income tax refunds listed below. The returns reflect a number of changes to income and expenses for the reason discussed above. The returns were not processed by the IRS Service Center but are allowed in full in this audit report.Third paragraph of template - Continuation of Current Examination ActivitySummary table includes columns for the Year, Refund Requested Type of Change for the years 201412 through 201612.Fourth paragraph of template - Continuation of Current Examination ActivityEnclosed is the examination report, dated October 15, 2019, for the years 201412 through 201612.Fifth paragraph of template - Continuation of Current Examination ActivityThis is not a Large Corporate Compliance case. There is a power of attorney on file for the years covered by this report and a copy is enclosed.Sixth paragraph of template - Statutes of LimitationsSummary table includes columns for the Year, Original Statute or as Extended and Special Statute for years 201412 through 201612. Seventh paragraph of templateThe above overassessments are approved.End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosures:Joint Committee Spreadsheet Analysis for Regular Tax, AMT & Credits, RAR dated 10/15/2019 and Forms 886-A, Power of Attorney

Sample Minimum Refund ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there is reported the following refund or credit of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year and Proposed Refund Section 6405(a), for the year 201512.Third paragraph of templateThe refund resulted primarily from the carryback of a net operating loss (NOL) from 201712.Fourth paragraph of templateThis report is submitted under the procedures contained in IRM 4.36.3.7.1. The unagreed issues will require a substantial period of time to resolve and the delay would deprive the taxpayer of a timely refund. The refund reported reflects the minimum amount to which the taxpayer is entitled, regardless of the outcome of the unagreed issues. A supplemental report will be submitted after the completion of the examination and/or resolution of the unagreed issues.Fifth paragraph of template - Minimum Refund ComputationTable includes rows for Agreed Overassessment, Unagreed Deficiency and Minimum Refund Amount for year 201512.Sixth paragraph of templateThe taxable income and tax liability reported on the returns are shown on the enclosed spreadsheets.

Continuation of the Sample Minimum Refund ReportFirst paragraph of template - Taxpayer HistoryThe taxpayer was incorporated on January 1,1950, and is engaged in the business of operating a steel mill. The net operating losses were due primarily to high interest expense deductions, the write-off of capitalized debt costs subject to amortization due to refinancing required by the merger, and charges related to the restructuring of the mill system, closings of duplicate location facilities, abandonments, severance costs and litigation settlements.Second paragraph of template - Prior Examination ActivityTax year 201512 was not previously examined.Third paragraph of template - Current Examination ActivityOn November 15, 2018, the taxpayer filed a timely amended return (Form 1120X) requesting the income tax refund of $30,000,000, for tax year 201512 based on an NOL carry back from 201712. The return was not processed by the IRS but was considered in this audit report.Fourth paragraph of template - Continuation of Current Examination ActivityEnclosed is the examination report dated April 16, 2020, for the year 201512.Fifth paragraph of template - Continuation of Current Examination ActivityThis is not a Large Corporate Compliance case. There is a power of attorney on file for the year covered by this report and a copy is enclosed.Sixth paragraph of template - Statutes of LimitationSummary table includes column for the Year and Original Statute or as Extended for the year 201512. Seventh paragraph of templateThe above overassessment is approved.End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosures:Joint Committee Spreadsheet Analysis for Regular Tax, AMT & Credits, RAR dated 04/16/2020 and Forms 886-A, Power of Attorney

Sample Modified Expedite Refund ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there is reported the following refund or credit of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year and Proposed Refund Section 6405(a), for the year 201512.Third paragraph of templateThe refund resulted primarily from the carryback of a net operating loss (NOL) from 201712.Fourth paragraph of templateThis report is submitted under the procedures contained in IRM 4.36.3.7.3. The taxpayer has requested that this refund be made since the examination for the 201412, 201512, 201612 and 201712 tax years will not be completed within six months. It has been determined that no disadvantage will occur to the Government in paying the refund. Security will be posted for the amount of the proposed refund and a copy of the Collateral Security Agreement is enclosed for your consideration. A supplemental report will be submitted after the completion of the examination if required.Fifth paragraph of templateThe taxable income and tax liability reported on the returns are shown on the enclosed spreadsheets.

Continuation of the Sample Modified Expedite Refund ReportFirst paragraph of template - Taxpayer HistoryThe taxpayer was incorporated on January 1,1950, and is engaged in the business of operating a steel mill.Second paragraph of template - Continuation of Taxpayer HistoryThe net operating losses were due primarily to high interest expense deductions, the write-off of capitalized debt costs subject to amortization due to refinancing required by the merger, and charges related to the restructuring of the mill system, closings of duplicate location facilities, abandonments, severance costs and litigation settlements.Third paragraph of template - Prior Examination ActivityTax year 201512 was not previously examined.Fourth paragraph of template - Statute of LimitationsSummary table includes column for the Year and Original Statute or as Extended for the year 201512. Fifth paragraph of templateThe above refund will be processed subject to the subsequent consideration of the 201412 through 201712 returns and review by your Committee of a supplemental report to be submitted upon completion of such action.End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosures:Collateral Security Agreement, Joint Committee Spreadsheet Analysis for Regular Tax, AMT & Credits

Sample Supplemental ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there is reported the following refund or credit of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year and Tentative Allowance Section 6405(b) for year 201512.Third paragraph of templateThe refund resulted primarily from the carryback of a net operating loss (NOL) from 201712.Fourth paragraph of templateThis report is being submitted as a supplemental report (for the tax year 201512) pursuant to the provisions of IRM 4.36.3.7.2 dealing with tentative allowances from unexamined source years.Fifth paragraph of templateThe taxable income and tax liability reported on the returns and as finally determined are shown on the enclosed spreadsheets.Sixth paragraph of template - Taxpayer HistoryThe taxpayer was incorporated in the State of Delaware on October 23, 1969 and has 47 subsidiaries. The taxpayer is wholly owned by a foreign company. The primary business of the taxpayer during the examination years was property and casualty insurance. Effective with the 201512 tax year the taxpayer's life insurance companies were included in the consolidated return. The company's other subsidiaries include insurance agencies, investment, annuity and risk management companies, and leasing companies.Seventh paragraph of template - Continuation of Taxpayer HistoryThe taxpayer carried back an alternative minimum tax net operating loss from the 201712 year to 201512.

Continuation of the Sample Supplemental ReportFirst paragraph of template - Prior Examination ActivityA prior audit report dated December 15, 2017, for 201512 was previously reported to and released by your Committee on April 18, 2018.Second paragraph of template - Current Examination ActivityEnclosed is the examination report dated April 2, 2020, for tax years 201512 and 201712.Third paragraph of template - Continuation of Current Examination ActivityThis taxpayer is not a Large Corporate Compliance case. There is no power of attorney on file for the years covered by this report.Fifth paragraph of template - Statutes of LimitationsSummary table includes columns for the Year and Original Statute or as Extended for the years 201512 and 201712. Sixth paragraph of templateThe above overassessment is approved.End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosures:Joint Committee Spreadsheet Analysis for Regular Tax, AMT & Credits, RAR Sated 04/2/2020 and Forms 886-A

Sample Foreign Sales Corporation (FSC) ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, name of JC specialist, phone number, fax number, related cases and date.Start of Letter - SalutationDear Mr. Chairman:First paragraph of templateIn accordance with the provisions of Section 6405 of the Internal Revenue Code, there are reported the following refunds or credits of income tax in favor of Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State:Second paragraph of template - Summary table of Refunds or CreditsSummary table includes columns for the Year and Proposed Refunds Section 6405(a), for the years 201512 and 201612.Third paragraph of templateThis report is submitted under the procedures contained in IRM 4.36.5.2.6. The refunds resulted from the adjustment of allocated and apportioned operating expenses. Corresponding adjustments have been made to the returns of the domestic parent, Taxpayer, Inc. and Subsidiaries.Fourth paragraph of templateThe above overassessments are approved.End of Letter - ClosingSincerely, Team manager signature, Team Manager

Sample Large Deficiency Case ReportLetter begins with letterhead on the top of the page. Below the letterhead is the addressee information, such as the name, title and address. On the right side of the page is a continuation of the addressee information, such as the office symbols, examination area, Industry, JCR Program Manager, phone and date.Start of Letter - SalutationAttn: Senior Refund Counsel:First paragraph of templateAs requested under the authority contained in section 6103(f)(2) of the Internal Revenue Code, the following deficiencies in income tax are reported for Taxpayer Inc. and Subsidiaries, (EIN: XXXXXXXXX), City, State, for the six-month period ended March 31, 20XX:Second paragraph of template - Summary table of DeficienciesSummary table includes columns for the Year and Deficiencies.Third paragraph of template - Examination ActivityThe enclosed examination report covers a concurrent examination of the returns for the period noted above.Fourth paragraph of template - Continuation of Examination ActivityExplanations of the recommended agreed adjustments are included in the enclosed Forms 5701 and/or Forms 886A.Fifth paragraph of template - Continuation of Examination ActivityThis large deficiency report is submitted for your review.End of Letter - ClosingSincerely, Team manager signature, Team ManagerEnclosuresRAR, Forms 5701/886A