The freely available Adobe Acrobat Reader software is required to view, print, and search the items listed below. The Internal Revenue Manual (IRM) sections listed below are part of the Consolidated Examination IRM for the Tax Exempt / Government Entities Division (TE/GE). The consolidated IRM provides uniform examination guidelines and procedures across all functions within TE/GE. In addition to Tax Exempt Bonds, these functions include Exempt Organizations, Employee Plans, Indian Tribal Governments, and Federal State Local / Employment Tax. The consolidated IRM provides guidance on general procedures to be followed when conducting all examinations covered by those functions. Although these procedures apply generally to all TE/GE examinations, each IRM section contains certain procedures that apply specifically to tax-advantaged bonds, including tax exempt bonds, tax credit bonds, and direct pay bonds. Certain procedures specific to tax-advantaged bonds are indicated below under each general section. IRM 4.70.11 Administrative Matters This IRM section provides procedures examiners should understand and apply throughout all phases of the examination process. IRM 4.70.11.2 Examination Jurisdiction / Authority This IRM section lists the forms which fall under the jurisdiction of each function within TE/GE, including Tax Exempt Bonds (TEB) IRM 4.70.11-1 TE/GE Form 2848 and Form 8821 Specific Elements by Function This IRM section provides elements specific to TEB for use of Form 2848 Power of Attorney and Form 8821 Tax Information Authorization IRM 4.70.12 Planning the Examination This IRM section provides guidelines for the planning phase of the examination process. IRM 4.70.12.3.3.4 TEB Case Grading This IRM section provides guidelines for determining the TEB examination case grade. IRM 4.70.12.3.6.5 TEB Specific Filing Checks This IRM section provides guidelines for pre-contact analysis for TEB examinations. IRM 4.70.13 Executing the Examination This IRM section provides procedures examiners should understand and apply in the execution phase of the examination process. IRM 4.70.13.3.2.3 Tax Exempt Bonds Internal Controls This IRM section provides procedures for evaluating internal controls of bond issuers and assessing control risk. These include post-issuance compliance monitoring procedures, accounting systems for bond transactions, records of expenditures, records of investments, and records of qualifying use. IRM 4.70.13.3.4.4 TEB Examination of Books and Records This IRM section provides guidelines and procedures for examining an issuer’s books and records pertaining to a bond issue under examination. IRM 4.70.13.9.5.9 TEB Procedures for Secured Delinquent and Late Filed Returns and Forms This IRM section provides procedures for processing secured delinquent and late filed returns and forms, including requests for waiver of penalty on failure to pay rebate on time. IRM 4.70.14 Resolving the Examination This IRM section provides procedures examiners should understand and apply in the resolution phase of the examination process. IRM 4.70.14.2.1.5 Tax Exempt Bonds Agreed Case Processing This IRM section provides procedures for the IRS to process examinations for which a. the examiner concludes the bonds are in compliance, b. operational changes were made and did not result in a change to bond qualification, c. a delinquent Form 8038 series or Form 8703 is received, or d. an issuer agrees with proposed resolution of non-compliance determined in the examination and completed a closing agreement. IRM 4.70.14.2.1.5.9 Tax Exempt Bonds Closing Agreements This IRM section provides procedures for the IRS to enter into closing agreements with governmental issuers and other parties to tax-advantaged bond transactions, with respect to the application of federal tax law requirements under the Code and corresponding Income Tax regulations, to correct compliance failures and preserve the tax-advantaged status of the bonds. IRM 4.70.14.2.4.5 Tax Exempt Bonds Unagreed Case Processing This IRM section provides procedures for the IRS to process examinations in which non-compliance is unresolved, including a. denials of claims for recovery of an asserted overpayment of an arbitrage payment under IRC 148 and b. unagreed disallowances to credit payments under IRC section 6431 (claim denials). IRM 4.70.17 Claims and Abatements This IRM section provides procedures examiners should understand and apply in conducting examinations of claims for recovery of overpayment of arbitrage payments. IRM 4.70.20 Bondholder Identification and Referrals This IRM section provides procedures for examiners and other staff to identify bondholders, extend statutes, and make referrals to other operating divisions. IRM 7.2.3 Tax Exempt Bonds Voluntary Closing Agreement Program This IRM section provides procedures for the voluntary closing agreement program for tax-exempt bonds and tax credit bonds known as TEB VCAP. IRM 4.81.12 Compliance Review of Form 8038-CP This IRM section provides procedures for the Field Assistance Support Team’s review of the refundable credit payments claimed on Form 8038-CP. IRM 4.82.3 Direct Pay Bonds This IRM section provides examination guidelines for Direct Pay Bonds, a type of tax-advantaged bonds on which interest paid is taxable to the holder and the bond issuer is allowed a refundable tax credit.
