4.25.1. Estate and Gift Tax Examinations

(1) This section provides general instructions for protecting tax returns, protecting the statute of limitations, scope of examinations, surveying returns and general examination guidelines.

(2) Examiners should also refer to the following examination chapters for guidance: IRM 4.10, Examination of Returns; IRM 4.11.55, Examining Officers Guide (EOG), Power of Attorney Rights and Responsibilities; and IRM 25.27.1, Third-Party Contact Program.

(1) Estate and gift tax examiners and managers assigned to examine and oversee the examination of estate and gift tax returns and issues are responsible for complying with servicewide policies and authorities set forth in IRM 1.2.1.5, Servicewide Policies and Authorities, Policy Statements for the Examining Process.

(2) Examination of estate and gift tax returns should be conducted in a manner that will promote public confidence as stated in the Mission of the Service. See IRM 1.2.1.2.1, Policy Statement 1-1.

(3) Policy Statement 4-52 established a general guideline that examination and processing of returns should be completed within 18 months of the filing date. See IRM 1.2.1.5.18, Policy Statement 4-52, Establishment of 18-month Examination Cycle.

(4) Estate and gift examiners and managers assigned to examine and oversee the examination of international estate and gift tax returns and issues are responsible for complying with all applicable servicewide examination delegation orders and SB/SE delegation orders. A table summarizing estate and gift delegation orders is available at IRM 4.25.14.8, Estate and Gift Tax, Miscellaneous Procedures, Signature Authority.

(5) Section 3504 of RRA 98, Public Law 105-206 requires the Service to include an explanation of the examination and collection process, as well as information about assistance from the Taxpayer Advocate with any first report/notice of proposed deficiency. Pub 3498, The Examination Process, must be used for this purpose.

(6) Statement of Procedural Rules 601.506 requires that examiners must forward any correspondence (or copy), discussions, reports and/or other material to the taxpayer at the same time it is sent to the representative.

(7) The Form 706 return instructions and CFR 20.6018-4, CFR 25.6019-3, and CFR 25.6019–4 list required filing documents.

(1) The National Quality Review System (NQRS) is a web-based review system used by Estate and Gift Tax Policy, Estate and Gift Tax Examination Management and Field and Specialty Examination Quality to generate and review reports analyzing national quality performance based upon standardized quality attributes set forth in Document 12499, Estate and Gift Tax Examination Embedded Quality Job Aid. NQRS report data is compiled by Field and Specialty Examination Quality on a quarterly basis, but ad hoc reports may be obtained monthly. The use of NQRS is explained in additional detail in IRM 4.25.1.11, Manager Embedded Quality Review and Specialty Exam National Embedded Quality Review Programs.

(2) Operational reviews and related NQRS reports are conducted by territory managers and the Chief of Estate and Gift to measure national adherence to quality standards and managerial performance and/or oversight.

(3) Customer (i.e., taxpayer) satisfaction reports are generated by SB/SE Operation Support Research on a quarterly basis. These reports provide masked taxpayer narratives that are responsive to a pre-defined set of survey questions. The quarterly survey reports are to be used to identify areas for examination quality improvement.

(4) Frequent front-line manager reviews are conducted under the Examination Quality Review System (EQRS), with the frequency based on annual personnel requirements.

(1) The following table sets forth the Estate and Gift Tax program specific terms and definitions:

(2) The following table sets forth common Estate and Gift Tax program acronyms:

(1) The Estate and Gift Tax program is required to follow all servicewide examination procedures and those set forth in the SB/SE examining process IRM. The following IRM subsections provide additional information relating to the processing, classification and examination of Estate and Gift Tax program returns and claims:

• IRM 4.25.2, Campus Estate and Gift

• IRM 4.25.3, Planning, Classification and Selection

• IRM 4.25.4, International Estate and Gift Tax Examinations

• IRM 4.25.5, Technical Guidelines for Estate and Gift Tax Issues

• IRM 4.25.6, Report Writing Guide for Estate and Gift Tax Examinations

• IRM 4.25.7, Estate and Gift Tax Penalty and Fraud Procedures

• IRM 4.25.8, Delinquent Returns and SFR Procedures

• IRM 4.25.9, Requests for Abatement, Claims for Refund and Doubt as to Liability in Estate and Gift Tax Cases

• IRM 4.25.10, Case Closing Procedures

• IRM 4.25.11, Special Examination Procedures

• IRM 4.25.12, Valuation Assistance

• IRM 4.25.13, Appeals, Mediation and Settlement Procedures

• IRM 4.25.14, Miscellaneous Procedures

• IRM 4.2.8, Guidelines for SB/SE National Quality Review

• IRM 4.10, Examination of Returns

• IRM 25.6.1, Statute of Limitations Processes and Procedures

• IRM 25.6.22, Extension of Assessment Statute of Limitations By Consent

• IRM 25.6.23, Examination Process-Assessment Statute of Limitations Controls

• IRM 3.5.61, Submission Processing, Accounts Services, Files Management and Services

(2) Document 12499, Estate and Gift Tax Examination Embedded Quality Job Aid, is issued by Estate and Gift Tax Policy, and is relied upon for the application and interpretation of the quality attributes. The job aid includes complete instructions, definitions, and examples of how cases are evaluated.

(1) The group manager and examiner are responsible for verifying and protecting the statute of limitations on all assigned cases. As tax returns are received in the group, the manager is required to ensure controls verifying the accuracy of the assessment statute expiration date (ASED) are in place. See IRM 25.6.23.5.1.2, Screening for Statute Accuracy. Controls are for filed returns and non-filer examinations. At the time a case is assigned, an examiner is required to verify the statute of limitations by comparing the original tax return received date and postmark date with the statute date reflected on Master File.

(2) The statute of limitations is to be calculated pursuant to IRC 6501.

(3) The Statute Verification Lead Sheet is a mandatory workpaper that must be completed and uploaded to the Issue Management System (IMS) case administrative issue within 45 days of the examiner’s case receipt.

(4) When a signed return is filed by a taxpayer, the statute of limitations begins to run. If there is uncertainty after review of the guidance on statute date determination, use of the earliest potential statute date is encouraged. The examiner should document any uncertainty pertaining to the statute of limitations in the Statute Verification Lead Sheet.

(5) Two digit alpha codes located in the "day" portion of the Statute of Limitations on Master File indicates there are special circumstances surrounding the statute. See IRM 25.6.23-3, Instructions for Updating the Statute on AIMS, paragraph (4) for a description of the available alpha codes.

(6) The use of BMFOLT and/or AMDISA transcript will be necessary to verify the statute date.

1. A BMFOLT will provide the examiner with the statute date of record (next to Assessment Statute Expiration Date (ASED)). It will also reflect the due date (next to RET DUE DT), any approved extensions (TC 460 under VARIABLE DATA), and the received date (TC 150 under VARIABLE DATA) on Page 1. An extension may be requested by the taxpayer by filing a Form 8892 or a Form 4868.

2. An AMDISA will reflect the current statute date of record at the top left of the transcript next to ASED. It also reflects the date the return was received in the middle of the page next to RET-RECVD-DT.

(7) If it is determined that the ASED is incorrect, update the ASED date as instructed in IRM Exhibit 25.6.23-3, Instructions for Updating Statute on AIMS.

(8) Once the correct ASED is determined and updated, if necessary, the statute date must be closely monitored to ensure the Government and Taxpayer's interests are protected. The statute date will not change unless it is updated to reflect the execution of a Form 872, Consent to Extend the Time to Assess Tax, or when input of an alpha statute code is appropriate. The manager and examiner must continue to monitor the statute using the monthly Inventory Validation List (IVL), ERCS Statute Reports and Table 4.1, Returns with Statute Date Pending (Status Codes 10, 12, 13, 14, 15, 17, and 18), to ensure statute control procedures are started within 180 days of the expiration of the ASED.

(9) Additional statute of limitations resources can be found in:

• IRM 4.7.3, Examination Returns Control System (ERCS), Statute of Limitations

• IRM 25.6.1, Special Topics, Statute of Limitations, Statute of Limitations Processes and Procedures

• IRM 25.6.22, Extension of Assessment Statute of Limitations by Consent

• IRM 25.6.23, Examination Process-Assessment Statute of Limitations Controls

(1) At the time a case is assigned, an examiner is required to verify any assessments and payments made to the account by comparing the original tax return with a transcript of the tax account.

(2) The verification of the assessments and payments should include the amounts indicating whether any tax, interest, or penalties are owed at the time the examination begins.

(3) Command code BMFOLT will provide current data on the account activity.

(4) See the CFOL Express guide available on the Estate and Gift SharePoint.

(1) The Audit Information Management System (AIMS) is a computer system used by Appeals, Examination, and TE/GE to control returns, input assessment/adjustments to Master File, and provide management reports. While the return is charged to Estate and Gift, the AIMS database tracks its location, age, and status.

(2) Every Estate and Gift employee is responsible for ensuring the accuracy of the AIMS database.

(3) This section will identify codes common to Estate and Gift Tax examinations, along with the IDRS command codes used to secure the current information reflected on Master File.

(4) The following IDRS transcripts will be helpful in verifying account information. An examiner may request transcript PDF prints for one or all of the command codes listed below if they are not already in the file or if they are more than 60 days old:

• AMDISA (Data on current audits)

• BMFOLT (Instant transcript of tax module)

• BMFOLI (List of online modules for a taxpayer)

• CFINK (Information on Power of Attorney for an entity)

• INOLES (Entity information such as name, address, date of birth, date of death, and scrambled SSNs)

• MFTRA Type C and Type E (Overnight transcript request for complete account data for a specific SSN)

• MFTRA Type M, 51 (if applicable) (Overnight transcript request for all Gift Tax returns filed by a taxpayer)

(5) The following codes should be verified by the examiner at the start of an examination:

• Activity Code

• Aging Reason Code

• Project Code

• Source Code

• Status Code

• Tracking Code

(6) See Document 6209, IRS Processing Codes and Information, for a complete listing and explanation of the codes used in Estate and Gift Tax examinations.

(1) Required filing checks are necessary to ensure voluntary compliance. Examiners should determine that taxpayers are in compliance with all federal tax return filing requirements and that all returns reflect the substantially correct tax. Required filing checks are documented on the return specific mandatory case examination lead sheet and administrative case file workpapers. Required filing checks and related return research will vary based on the facts of each case.

(2) IRM 4.10.5.2, Examination of Returns, Required Filing Checks, General Guidelines provides definitions and background information. Additional information on required filing checks can also be found at:

• IRM 4.10.5.3, Prior and Subsequent Year Returns

• IRM 4.10.5.4, Related and Spin Off Returns

• IRM 4.10.5.6, Information Returns

• IRM 4.10.5.7, Information Returns and Forms Involving Foreign Entities

• IRM 4.10.5.9, Report of Foreign Bank and Financial Accounts (FBAR)

(3) In addition to the filing check requirements discussed in paragraph (2), examiners are required to complete a filing check to ensure timely filing of Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent.

1. Executors are required to file Form 8971. As a result of this filing requirement, estate tax return examinations will include a filing check for estate tax returns filed on or after July 31, 2015. If the return was due on or before July 31, 2015, but is filed after July 31, 2015, the Form 8971 rules and requirements also apply to that return. See Prop. Reg. 1.6035-1(d)(2). An executor of an estate or other person(s) required to file Form 706, Form 706-NA, or Form 706-A (hereinafter referred to collectively as Form 706) under IRC 6018(a) and 6018(b) or a qualified heir required to file Form 706-A under IRC 2032A, if the return is filed after July 2015, and whether or not that form is filed timely, is required to file Form 8971, and Schedule(s) A with the IRS and to provide each beneficiary listed on the Form 8971 with that beneficiary’s Schedule A. The IRC 6035 filing requirement for Form 8971 and Schedule(s) A does not apply to estates filing to only elect portability of DSUE or make an allocation or election respecting generation-skipping transfer taxation. The Form 8971 is due 30 days after the filing of Form 706.

2. To determine whether the Form 8971 was timely filed the examiner must secure a BMFOL-T transcript. The transcript will show a 971 transaction code and a 368 action code if the Form 8971 was filed.

(1) Historical gift tax returns are stored at a consolidated site in Independence, MO referred to as the C-Site.

(2) A document locator number (DLN) is assigned to a Form 709 at the time of processing. While gift tax returns are stored in Alpha order at the C-Site, they are stored in DLN order in Files, where current year returns are housed.

(3) Gift Tax returns are temporarily stored until the donor is deceased at which time they are either associated with the estate tax return or scheduled for destruction if no estate tax return is required.

(4) IDRS research must be conducted prior to submitting a request for a historical gift tax return. Using Command Code MFTRA Type C, verify the record for the gift tax return shows a transaction code (TC) 150 posting indicating a tax return has been filed. If a TC 421 is present on the account, the controlling DLN will appear next to it on the transcript.

(5) For older returns, the MFTRA transcript may indicate that the MFT 51 has been removed to retention. An offline Retention Register is an account module that has been removed from Master File and stored on microfilm. If a Retention Register is needed, complete Sections 1-5 of Form 3774 and process as follows:

1. Section 1 – Check "BMF"; input SSN with V definer; leave V.D. box blank; the "District Code" is the ULC code which is found on a MFTRA transcript; the MFT is always 51; enter the tax period; the six-digit cycle is found on a MFTRA transcript near the ULC code.

2. Section 2 – Check "Original Request".

3. Section 3 - Enter the taxpayer’s full name. No address needed.

4. Section 4 – Enter requester’s information in b. – d. Leave "a" blank. Provide the requester’s complete mailing address on the Fax Cover Sheet.

5. Section 5 – Check "Transcript".

6. Fax the completed Form 3774 to the appropriate Service Center as shown in the table in IRM 3.12.179-2, refer only to the table from this exhibit. Wait up to 14 days for a response before submitting a follow up request. When the microfilm transcript is received, use Form 2275 to request the return.

7. If Form 3774 is returned without a transcript, verify the information on the original request and submit again.

(6) Complete Form 2275 using the data from the MFTRA transcript or Retention Register. For returns filed within the last two years, use a separate Form 2275 for each tax year. For returns filed more than two years ago, a request may be made on a single Form 2275 for the entire Alpha file. Provide all names and nicknames used by the taxpayer. See IRM 3.5.61.6 paragraph 2. Only complete the following information:

(7) Route Form 2275 to Files for servicing. Fax requests per IRM 3.5.61.26. Wait 21 days for a response. Follow up with Files if no response.

(8) When Form 2275 is stamped “DNIF” (Document Not In File) indicating the return was not located, it may indicate the document is waiting to be shelved. Wait 30 days for enough time to pass for the document to be refiled and submit the request again. Complete the Form 2275 as described in IRM 4.25.1.3.1 paragraph (6) except in Box 15, check B, Second.

(9) When original Forms 709 need to be returned to the C-Site, use UPS. See the UPS address in IRM 3.5.61.3.3 paragraph (4).

(1) Related estate tax returns, including a predeceased spouse’s return, may provide valuable information on a current examination.

(2) Closed estate tax returns are stored in DLN order in Federal Records Centers (FRC). Estate tax returns are retained for 40 years.

(3) IDRS research must be conducted prior to submitting a request for an estate tax return. Using Command Code MFTRA Type C, verify the record for the estate tax return shows a TC 150 posting indicating a tax return has been filed. If a TC 150 is present on the account, research the controlling DLN, which appears next to TC 421 on the transcript.

(4) For older returns, the MFTRA transcript may indicate that the MFT 52 has been removed to retention. An offline Retention Register is an account module that has been removed from Master File and stored on microfilm. If a Retention Register is needed, complete Sections 1-5 of Form 3774 and process as follows:

1. Section 1 – Check "BMF"; input SSN with V definer; leave V.D. box blank; the "District Code" is the ULC code which is found on a MFTRA transcript; the MFT is always 52; the tax period is always 000000; The six-digit cycle is found on a MFTRA transcript near the ULC code.

2. Section 2 – Check "Original Request".

3. Section 3 - Enter only "Estate of . . .". No address needed.

4. Section 4 – Enter requester’s information in b. – d. Leave "a" blank. Provide the requester’s complete mailing address on the Fax Cover Sheet.

5. Section 5 – Check "Transcript".

6. Fax the completed Form 3774 to the appropriate Service Center as shown in the table in IRM 3.12.179-2. Refer only to the table from this exhibit. Wait up to 14 days for a response. When the microfilm transcript is received, use Form 2275 to request the return.

7. If Form 3774 is returned without a transcript, verify the information on the original request and submit again.

(5) The location for fulfilling the request depends on the status code and EGC:

(6) Complete Form 2275 using the data from MFTRA or Retention Register. See IRM 3.5.61.6 paragraph 2. Only complete the following information:

(1) During classification, returns may be identified as limited scope examinations.

(2) Estate and Gift Workload Selection and Delivery (WSD) applies a project code 0902 on AIMS/ERCS before shipping the return to field offices.

(3) The field offices may conduct limited scope examinations of items conducive to correspondence examinations and that do not require significant substantiation by the taxpayer.

(4) Limited scope examinations do not require a probe for omitted assets and undisclosed transfers. The only lead sheets that are required for a limited scope examination are the Limited Scope Examination Mandatory Lead Sheet, the Statute Verification Lead Sheet and the Form 9984, Activity Record. See IRM 4.25.1.9, Estate and Gift Tax Exam Process and Documentation (EPD).

(5) To make adjustments, complete reports in accordance with IRM 4.25.10, Case Closing Procedures.

(1) Occasionally, special issues or circumstances related to estate and gift are identified and Estate and Gift Workload Selection and Delivery (WSD) initiates project cases. Project cases may have a defined cycle time. See IRM 4.25.4.8, Classification of Non-Filer and Under-Reporter Project Cases.

(2) Typically, specific directions and procedures are provided upon the assignment of the project case. Project Case Lead Sheets are available in Notebook.

(3) Refer to IRM 4.25.8, Delinquent Returns and SFR Procedures, for detailed information regarding project codes, tracking codes and case procedures.

(1) In pre-planning an examination, the examiner should use sound judgment to determine the significant issues to be examined. This may necessitate declassifying issues and or adding issues in lieu of those classified. The scope of the examination should be documented in the workpapers.

(2) When a Risk Summary (e.g., gift tax return picked up during the course of an estate tax return examination) is not included with the return, the scope of the examination should be documented in the workpapers.

(3) Depth is the extent to which an issue is developed. It demonstrates the degree of intensity and thoroughness applied in order to make a determination as to the correctness of an item.

(4) Examiners must exercise judgment in determining the depth required for the examination. Determining the depth for different issues will help to estimate the time needed to complete the examination. The following factors should be considered:

• Type of evidence available or expected for the issue

• Complexity of the issue

• Materiality of the issue

• Internal controls and accuracy of the books and records

(1) Time spent reviewing a return and its attachments and/or perfecting the file may be shown as below-the-line time on ERCS/IMS, by using Code 615, Survey. The number of hours spent reviewing the return and perfecting the file is not a consideration in determining whether the return was examined.

(2) If an examiner decides that a case is likely to result in a change in tax and there is a plan to examine the return, the case should be opened (AIMS status code 12) and time charged to the case. This time may include time for further review and/or file perfection. If it is later determined that contact with the taxpayer or the taxpayer's representative will not be made, the examiner may survey the return, even with time charged to the case on ERCS, provided there has been no activity beyond that of a survey.

(1) See IRM 4.25.10.3, Survey, for instructions on closing a surveyed case.

(2) If the estate has elected and qualifies for the election under IRC 6166 and there appear to be no substantive audit issues on the return, the return may be surveyed.

(1) Policy Statement 4-52 established a general guideline that examination and processing of returns should be completed within 18 months of the filing date. See IRM 1.2.1.5.18, Policy Statement 4-52.

1. Returns will be examined in accordance with the required Examination Process and Documentation (EPD) tools and procedures.

2. An examiner will make initial taxpayer contact or survey the assigned case within 45 days measured from case receipt.

3. Significant activity is required at least every 45 days.

4. When a taxpayer or a taxpayer's representative has failed to meet two deadlines to provide information or documentation requested by the examiner, the manager should be informed and get involved in the examination to prevent further delays.

5. Examinations extending beyond 18 months may require frequent managerial involvement and monitoring.

6. When an examination is beyond the 18 month cycle, managers should ensure that the Service does not become a party to the continuing delay affecting the completion of the examination.

(2) The term significant activity is defined as any activity where the examiner performed substantial work that moved the case toward a conclusion. This does not include phone calls to or from the taxpayer to cancel or change appointments. It would include phone calls that discussed items which helped move the case toward a conclusion, appointments, requests for information, research, etc. Significant activity would also include follow-up contacts either to or from Engineers or other specialists. Examples of significant activity include but are not limited to:

1. Discussions with the taxpayer or the taxpayer’s representative which significantly move the examination toward completion.

2. Researching classified examination issues.

3. Reviewing documentation provided by the taxpayers.

4. Discussing the case with the group manager for guidance, including workload or open case reviews.

5. Documenting the Plan to Close (PTC) meeting in the case activity record.

6. Verifying the statute of limitations and filling out the necessary paperwork to change the ASED date to the correct SOL date.

7. Reviewing the Risk Summary, tax return, related returns, and attached documentation in order to conduct an examination pre-plan.

8. Reviewing income tax returns to identify potential omitted assets and to verify consistent reporting amongst transfer tax returns.

9. Holding in-depth conference call(s) with an IRS Engineering or Outside Fee Appraiser to discuss the scope of a potential referral, documentation needed, examination strategies, etc. Reviewing a rough draft of an engagement letter and discussing the scope of the engagement with group manager to determine whether the proposed Engineering hours were reasonable given the valuation issues present in the case.

10. Having discussions with management regarding potential badges of fraud and whether or not to seek Fraud Technical Advisor (FTA) assistance.

11. Preparing a third party summons to obtain specific documentation or information not in the possession of the taxpayer or the taxpayer’s representative.

12. Writing a memorandum to the file to eliminate a classified issue using approved risk analysis techniques.  

(3) The group manager may assign returns for examination and direct the scope of items to be investigated, the depth of the examination, the records for examination and examination techniques employed consistent with IRS Policy Statements. The case file should be clearly documented to reflect such directions.

(4) While complexity of workload and conflicting demands are considered, the examiner should prioritize, plan, and schedule work accordingly. Generally, estate tax returns are examined in the order in which they are filed.

(5) Certain matters are considered priority work requiring immediate, prompt or preferred attention. The following list contains examples of matters that are considered priority work.

• Cases where the statute of limitations is close to expiring

• Cases returned after review

• Cases where the 18 month cycle is about to run

• Collateral examinations

• Claims for refund

(6) Instances also occur where it is more practical to advance a recently filed case. Factors to consider:

• Program priorities or initiatives

• Return complexity

• Cases in similar geographic areas

(7) Examiners may be required to examine cases in states other than their own. Online resources are available to assist in understanding distinctions among state laws. The online resources below are meant to be a starting point for the research and not a comprehensive listing.

1. Online resources for researching state law include LexisNexis, Accurint, Commercial Clearing House (CCH), Westlaw, IRM Online, the Estate and Gift Knowledge Management page, and the Estate and Gift SharePoint.

(1) Case actions should be completed in an efficient manner that does not unnecessarily delay resolution of the examination.

(2) The national standard timeframes (unless noted, measured in calendar days) by which action should be taken are as follows:

(3) All delays should be documented on the Form 9984, Activity Record.

(1) Examination activity should be commensurate with the time charged to the case. Factors to be considered in determining appropriate use of time are issue complexity and potential, condition of the books and records, depth of legal research required, taxpayer/representative cooperation, and other problems that affect use of time.

(1) Communications with taxpayers, authorized representatives, and third parties must be made in a timely fashion and in a firm, businesslike, and professional manner.

(2) RRA ‘98 section 3705(a) requires that all oral and written communication with a taxpayer or authorized representative of a taxpayer shall include the name, telephone number and the unique identifying number (e.g., Smart-ID badge number) of the IRS employee the taxpayer may contact. The examiner will document the case Form 9984, Activity Record, to show that the taxpayer and/or representative was provided with the required identifying information during oral communications.

(1) The examiner should advise the taxpayer of all rights and provide the taxpayer appropriate publications. The examiner should also keep the taxpayer or authorized representative informed throughout the examination process. Proper documentation regarding taxpayer rights and notification should be included in the case file.

(1) A new case can be created in IMS through the ERCS Case Inventory or through a manual case entry.

(2) IMS will generate a Case Tree when the case is created. The Case Tree contains auto-populated Case Attributes. The Case Attributes menu option in each Case Tree contains options for the management of Entities, Team Members, and Issues. The Case Attributes apply to all returns included in the case folder.

(3) IMS has features that allow the user to customize the grids displayed on several of the screens. Once the grid is customized, IMS will show the information for all cases in that format.

(1) The Entities section of the case tree is used to show the returns in the case.

1. The entities screen is where returns can be added or copied for a case. ERCS update forms can be created and data can be exported from the case into IMS from the Estate and Gift Notebook Job Aid (Notebook). See IRM 4.25.6.3, Estate and Gift Tax Notebook Job Aid.

(2) The Return section of the case tree is used to view all returns in a case.

(3) The Returns screen is also used to merge manually added returns with an ERCS record in IMS and to add a Form 5344, Examination Closing Record, Form 5351, Examination Non-Examined Closings, and Form 8278, Assessment and Abatement of Miscellaneous Civil Penalties, when required, prior to closing a return off IMS.

(1) The Team Members (IRS) screen is used to add, edit, and remove contacts from returns on the case.

(2) IRS Team Members can be added and assigned case issues.

1. Team Coordinator permissions are not automatically given to IRS Team Members, but may be granted to each Team Member as appropriate. Team Coordinator Permissions are managed from the Case Attributes screen.

(3) Taxpayer contacts

1. The taxpayer contacts portion of IMS is where authorized personal representative contacts are added so they are displayed on the Form 9984, Examining Officer’s Activity Record. Only one contact can be listed on the Form 9984 as the Taxpayer and the Taxpayer’s Power of Attorney.

2. Taxpayer contacts need to be checked-in for the Export Data from IMS to Notebook command to work.

(1) Time spent examining claims is tracked using three different tracking codes. These codes are referred to as "Protection of Revenue Base" (P of RB). Time spent examining the P of RB issues is separate from regular examination time. The P of RB indication in ERCS allows tracking of claim examinations. On IMS, these indicators are Revenue Protection Codes (RPCs). The three codes are:

1. N − Used when there is no filed request for refund." N" applies to regular examination activities prior to any request for refund. Once there is a request for refund, all subsequent time charges should be made to either "P" or "R".

2. P − Used to record time spent protecting the revenue base (i.e., working the claim issue). Examiners cannot charge "N" and "P" for the same return. However, N can change to a P during an examination.

3. R − Used to record time spent examining regular (non P of RB) issues on returns where a request for refund has been filed. ERCS allows time charges to "P" and "R" for the same return on the same day.

(2) The issue must be checked out to edit the Revenue Protection Code (RPC) in IMS.

(3) Charging time to "P" and "R" does not change the process for requesting an update to the return for claim purposes. Although IMS will allow the correct P of RB codes to be input, the items ERCS needs to update the return are not included. See IRM 4.25.9, Requests for Abatement, Claims for Refund, and Doubt as to Liability in Estate and Gift Tax Cases.

(1) Time is charged to the issues identified in the case. Issues are categorized in two ways: by selecting a Standard Audit Index Number (SAIN) and a number from the Uniform Issue List (UIL). Generally, the SAIN code relates to how an issue is reported on a return. Tracking issues using both the SAIN code and the UIL number will allow the IRS to plan and allocate resources more efficiently. Consequently, at least one SAIN code and one UIL number must be selected for each return within a case. Employees will use their professional judgment to determine the appropriate SAIN codes to apply to the case issues. SAIN codes will be entered for case issues, however, workpapers will be associated with the Administrative SAIN code. Employees may charge time to the Administrative issue. However, where an examining employee spends a significant amount of time on a particular issue the time charge should be associated with the SAIN code for that issue. In situations where a case is not started on IMS and therefore time needs to be entered retroactively, these time charges may be input in IMS in blocks of up to 99 hours, and a specific SAIN code need not be identified.

(2) All returns must have the following SAIN Code issues added on IMS. An Administrative Issue (EG080) and Case Issues (Classified Issues for Issue Tracking and Feedback Form purposes) are required on all cases. An Administrative Issue (EG080) is created automatically. All case issues (classified issues) for the return and major issues that were not classified in the case file (i.e., any issues in the case that resulted in significant time expenditures regardless of change that was not identified during classification) must be added. Reference documents identifying applicable SAIN and UIL codes used by the Estate and Gift Program are located in the "CBF Support Materials" folder on the Estate and Gift SharePoint.

(3) Administrative Issues and Case Issues may be established for the Team Coordinator or assigned to other team members. From the Add Issue screen, select the team member to be assigned to the issue from the drop-down list. IMS defaults to the user adding the issue and can be changed by clicking the drop-down list and selecting a different Assigned Team Member.

(4) Once an examiner’s referral request to engineering is accepted and assigned, the examiner should add the assigned Engineer as a team member within IMS using the following steps:

1. The LB&I employee should be assigned a "Referral to Specialist Issue" (SAIN EG081) issue.

2. If not already identified in IMS, enter a UIL code that best represents the referred issue. Do not use UIL "00001.06-00 – Estates and Trusts." For resources identifying the applicable UIL codes see the "CBF Support Materials" folder on the Estate and Gift SharePoint.

3. Consult with the assigned LB&I employee about the number of days to enter in the Original Days Assigned field when assigning the Referral to Specialist issue.

(5) In the Add Issue Screen, enter the date the examination began in both the Start Date and End Date fields. Both dates should be the same. Having the dates consistently entered will keep the detailed case issue(s) from being displayed when time is entered into the time sheet screen.

(1) The UIL number relates the issue or SAIN to the applicable primary section. If not already populated in the Add Issue screen, add a UIL code that corresponds to the Issue. A UIL Code is required to close all cases off IMS.

(1) A case may have multiple entities and each entity or return can close at a different time. There are two types of "Actual Closed Dates" - one date for the case and another date for each entity on the case. For the return that has been closed, close the case on the "Edit Entity" screen.

(2) A Form 5344, Examination Closing Record, must be generated for each entity within IMS, before an actual closed date will be accepted for the case.

(1) The Time Sheet window allows the IMS user to enter the various categories of time applied. Time may be entered as direct examination time or below the line time.

(2) The Time Sheet window includes fields to explain the examination activity completed during the recorded time. This information is transferred to the Form 9984, Examining Officers Activity Record. The Form 9984 is used to document each action taken on the case. Documentation should include the date, location, time charged, and an explanation of each activity or contact. The activity record should provide a complete and concise case history. Recordation of events should be made by examiners or other employees responsible for activity on the case (e.g., group managers, engineers, clerical staff, team members, administrative staff, etc.)

(3) Information recorded on the Form 9984 should include, but is not limited to:

• The date the case was received.

• When forms and documents were sent or received.

• All internal contacts.

• Any other significant contacts or activities.

• Delays with explanations for the delay (i.e., leave, details).

• Documentation of all significant actions taken on the case. Significant case action should occur at least every 45 days. See IRM 4.25.1.1.4 for a definition of significant activity.

• The examination start date. The examination should begin within 45 days of case receipt.

• Documentation of the initial contact letter mailing date. The initial contact letter should be mailed within 45 days of case receipt. The examiner should document any reasons for not timely mailing the initial contact letter.

• Notate whether the taxpayer was provided Pub 1 and Notice 609 upon initial contact.

• Discussions with the taxpayer regarding their rights.

• Work performed prior to, during, and subsequent to the initial taxpayer contact, including a general outline of research activities conducted.

• Documentation of any tour or site visit of the taxpayer’s business or real property.

• Brief summaries of telephone conversations. However, lengthy telephone conversation notes should be uploaded to IMS.

• Documentation of all contacts with taxpayers, representatives, and third parties.

• Causes for any delays by the Service (training, details, etc.), the taxpayer, and/or representative. Examiners must ensure that they have notated and explained any delays, causes of delays, and whether or not delays were communicated to any of the affected parties (explain any lack of communication).

• Group manager involvement (including informal discussions, formal discussions, in-process case reviews, on-the-job-visitations, and workload reviews, manager plan to close meetings, managerial approval for deviations from IMS document upload requirements, fraud awareness, and penalty assessments/abatements, etc.).

• Documentation when collateral requests and referrals (e.g., Engineering or Art Appraisal Services) are made or accepted, when work begins, and when progress reports are received.

• All actions with respect to the statute of limitations (e.g., verification, steps to protect the statute of limitation, Form 895 completion date(s), and consents to extend) should be fully documented in the Form 9984.

• The date the draft report was issued and the response date.

• Document that a Pub 3498 was issued if required in order to close the case. See IRM 4.10.8.2.3.2, Publications

• Documentation of the date when the examiner notified the taxpayer of their recommendation to close the case as a No-Change, when appropriate.

• If a No Change No Adjustments report was issued, the examiner should confirm "NO CHANGE SUBJECT TO CHIEF, ESTATE AND GIFT TAX APPROVAL" language was included on the face of the report, when appropriate.

(4) The Primary Team Coordinator may obtain copies of other team members' (engineers, other examiners assigned to the case, etc.) Forms 9984 through the IMS team website.

(1) The IMS case file includes tax returns, lead sheets, completed forms, workpapers and supporting documentation, including the pre-audit/pre-planning notes. The IMS case file documentation provides detail about the examination trail, indicates the status throughout the examination and supports the conclusions reached. See IRM 4.25.1-2.

(2) Case building documents from the Case Built File must be imported to the workpapers IMS folder within 30 days of receipt of the CBF Notification Email.

• Beginning with IMS version 3.9.10, users will be able to import documents from Case Built File to the "workpapers" folder within IMS.

• The import will not occur automatically. Users must select the "Import" button within IMS or refer to the user manuals for alternative import methods.

(3) The examiner must upload and synchronize all case documents to IMS per Exhibit 4.25.1-1, Required Uploads to IMS.

(4) In IMS, workpapers are issue specific and uploaded from the Case Tree or in the Issue Tree. Workpapers, lead sheets, forms and letters can be created in IMS or they can be uploaded from previously created files. Workpapers, lead sheets, forms and letters can also be added to either an open or closed case file from the team website. For additional workpaper upload and sorting instructions see the Issue Management System (IMS) Estate and Gift User Guide.

(5) The following documents should not be uploaded to IMS:

• Blank forms, instructions, workpapers or lead sheets

• Duplicate copies or versions of workpapers or lead sheets

• IRS Publications and Notices

• Copies of code sections, regulations, PLRs, cases, articles, etc.

• Multiple copies of a workpaper or lead sheet

• Copies of job aids and quality tips

(1) Synchronization is the process of transferring specific material to/from the examiner’s computer and the IMS Server. Once the synchronization is complete, any material synchronized on the examiner’s computer will be identical to the material on the IMS Server. There are five types of synchronizations performed in IMS: Summary, ERCS, Case, Reminder and Time.

(2) Summary − A Summary Synchronization downloads the case information for any case for which the user is a team member or manager.

(3) ERCS − An ERCS Synchronization will download return data assigned to the user in ERCS. IMS receives a download from ERCS nightly.

1. ERCS changes made in IMS will not appear in ERCS. If information from ERCS is incorrect, the examiner should complete Form 5348, AIMS/ERCS Update, to change the data on ERCS. The ERCS record will be updated and downloaded through the ERCS synchronization.

2. If the recorded TIN is incorrect in ERCS, the examiner must complete Form 5351, Examination Non-Examined Closings, to dispose of the wrong record on ERCS. Examiners can also establish a new record on ERCS with the correct TIN using Form 5345-D, Examination Request − ERCS (Examination Return Control System Users).

(4) Case Synchronization allows the examiner to ensure that all uploaded work is saved to the IMS Server in the event of computer failure. Case specific information such as Issues, Information Document Requests (IDRs), and Workpapers upload and download using the Case Synchronization process. Examiners must run an IMS case synchronization at least once every week that they have taken action on a case. Examiners are not required to run a case synchronize for a case if no action was taken on that case since the last synchronization. The examiner will also check-in and synchronize all case documents at the time the examiner closes the case.

(5) Reminder Synchronizations − The IMS Reminder menu is located on the IMS Toolbar. Users may view, edit, add, delete, activate, or deactivate reminders. Others cannot view an examiner's reminders. IMS also generates system reminders. The user should run a Reminder Synchronization to view the IMS generated reminders. These system reminders include:

1. A reminder five days prior to the end of each ERCS monthly reporting cycle.

2. A reminder for any case not having a new activity record (or modifying an existing activity record), or a case comment on a particular case for more than 25 days.

(6) Time Synchronizations − The IMS timekeeping system will track case time, miscellaneous direct examination time (MDET), and below-the-line (BTL) time. To input time on a return, the user must have created issues for the return. All direct examination time applied on IMS is by standard audit index number (SAIN) and uniform issue list (UIL) codes.

1. The time needs to be on the IMS Server by Thursday at 8:00 pm EST.

2. The user must synchronize their timesheet at least once a week (usually Thursday).

(1) The Estate Tax Mandatory Lead Sheet replaced the essential elements of the Examination Planning and Work Paper Index, the Administrative Lead Sheet, the Other Tax Return Lead Sheet, and the Asset Probe Lead Sheet. The combined lead sheet serves as an index and summary of supporting workpapers and provides the following benefits:

• Identifies applicable dates, referrals, taxpayer related contacts, examination and penalty issues

• Establishes a consistent format, making the case file easier to prepare and review

• Streamlines the audit process by helping the examiner establish an effective pre-audit plan

• Includes audit steps that assist the examiner through issues with which they are unfamiliar

• Allows audit steps to be added, modified or eliminated through risk analysis

• Addresses the administrative items requiring comment by the examiner (e.g., required filing checks, minimum income probes and related return research)

(2) The Estate Tax Mandatory Lead Sheet is required for estate tax case examinations not designated with a limited scope audit project code. However, all fields are not required in all examinations. The examiner will exercise judgment in determining which items are required based on the facts and circumstances of the specific case.

(3) The following examination techniques should be addressed in all estate tax examinations:

1. Transcript review and related return research

2. Identification of examination issues

3. Completion of asset probe and minimum filing checks

4. Penalty and fraud analysis when the audit results in a deficiency

5. Documentation of the issuance of applicable taxpayer rights publications and notices

   Note: The Estate Tax Mandatory Lead Sheet addresses each of the required examination techniques. However, the examiner may need to expand the documentation of their actions and analysis using issue specific lead sheets, workpapers, correspondence and the activity record. Cross references should be provided when applicable.

(1) The Limited Scope Audit Mandatory Lead Sheet replaced the essential elements of the LSA Examination Planning and Work Paper Index, the Administrative Lead Sheet, the Other Tax Return Lead, and the Asset Probe Lead Sheet. The new combined lead sheet serves as an index and summary of supporting workpapers and provides the following benefits:

• Identifies applicable dates, referrals, taxpayer related contacts, examination and penalty issues

• Establishes a consistent format, making the case file easier to prepare and review

• Streamlines the audit process by helping the examiner establish an effective pre-audit plan

• Includes audit steps that assist the examiner through issues with which they are unfamiliar

• Allows audit steps to be added, modified or eliminated through risk analysis

• Addresses the administrative items requiring comment by the examiner (e.g., required filing checks, minimum income probes and related return research)

(2) In addition to the Limited Scope Audit Mandatory Lead Sheet, the examiner must complete a Form 9984, Activity Record and a Statute Verification Lead Sheet.

(3) Limited Scope Audits will have specific examination issues designated in the Risk Summary or by the group manager. Unless permitted by the group manager, the examination issues will not be expanded beyond the selected/assigned issues.

(1) The Gift Tax Mandatory Lead Sheet is required for gift tax case examinations not designated as limited scope audits. However, all fields are not required in all examinations. The examiner will exercise judgment in determining which items are required based on the facts and circumstances of the specific case.

(2) The following examination techniques should be addressed in all gift tax examinations:

1. Transcript review and related return research

2. Identification of examination issues

3. Completion of minimum filing checks

4. Penalty and fraud analysis when the audit results in a deficiency

5. Documentation of the issuance of applicable taxpayer rights publications and notices

   Note: The Gift Tax Mandatory Lead Sheet addresses each of the required examination techniques. However, the examiner may need to expand the documentation of their actions and analysis using issue specific lead sheets, workpapers, correspondence and the activity record. Cross references should be provided when applicable.

(3) In examining a gift tax return, it is the responsibility of the examiner to determine if prior gift returns were filed, and to verify the amount of Deceased Spousal Unused Exclusion (DSUE) used, when appropriate. The examiner should review the complete procedures for securing historic estate and gift tax returns. See IRM 4.25.1.3.1, Retrieving Historical Gift Tax Returns, and IRM 4.25.1.3.2, Retrieving Estate Tax Returns for Reference.

(4) The examiner must verify the statute of limitations for each gift tax return under examination and discuss the actions necessary to protect the statute of limitations with the group manager. The examiner should document the verification of the statute of limitations on the Form 9984, Activity Record, and on the Statute Verification Lead Sheet. See IRM 4.25.1.9.4, Statute Verification Lead Sheet, IRM 4.25.1.2.1, Verify and Protect the Statute of Limitations, and IRM 25.6.23-3, Instructions for Updating the Statute on AIMS.

(5) Pub 1, Your Rights as a Taxpayer, and Notice 609, Privacy Act and Paperwork Reduction Act, must be provided to the taxpayer in all gift tax examination cases where the taxpayer is contacted.

(6) The examiner should document the case Form 9984, Examining Officer’s Activity Record, with all actions relating to taxpayer rights. See IRM 4.25.1.8.8, IMS Time Sheet and Form 9984, Activity Record.

(7) Except for a limited scope audit, the examiner should probe for undisclosed transfers.

(8) The examiner must maintain significant examination activity every 45 days, and record their actions in the case Form 9984, Examining Officer’s Activity Record. See IRM 4.25.1.8.8, IMS Time Sheet and Form 9984 Activity Record.

(9) Request support from internal specialists, outside fee appraisers, and paraprofessionals, when their participation enhances the quality, accuracy, and fairness of the examination. However, the examiner to whom the return was assigned, under the direction of the group manager, is responsible for making the recommendation of tax liability, ensuring conclusions are properly supported by the facts and law, and explaining adjustments to the taxpayer. See IRM 4.25.12, Valuation Assistance.

(10) Obtain omitted copies of documents and information required to be filed with the return. Original documents should not be marked.

(11) Information and copies of documents should not be obtained and made a part of the case file unless they are:

• Required to be filed with the return.

• Necessary to support adjustments.

• Necessary for a complete examination of the return.

• Needed for complete explanation of questioned items which resulted in a no-change.

(1) The purpose of the Statute Verification Lead Sheet is to verify the correct statute of limitations date. See IRM 4.25.1.2.1.

(2) The examiner must verify the statute of limitations, complete the Statute Verification Lead Sheet and correct any statute inaccuracies on IDRS (e.g., ASED date) for all assigned cases within 45 calendar days from case receipt.

(3) The examiner may need to update the Statute Verification Lead Sheet throughout the examination in order to document changes to the statute date as a result of consents or to confirm required statute control procedures.

(1) The Form 9984, Examining Officer’s Activity Record, is used to document the hours charged to a case and to briefly record the examiner’s actions. The Examining Officer’s Activity Record is created in IMS from time sheet entries. See IRM 4.25.1.8.8, IMS Time Sheet and Form 9984, Activity Record.

(2) The case file must contain a Form 9984 for all team members (e.g., engineers, paraprofessionals, etc.) who charged time to the case.

(1) The Manager Plan to Close Lead Sheet should not be completed until the examination has been in process for 120 days. Even at that point in the audit cycle, a further exception exists for examinations that are substantially complete and do not require further managerial involvement. The plan to close meeting between the examiner and manager provides for an opportunity to discuss the status of the examination, problems or difficulties obtaining requested items, and follow up actions to be taken.

(2) A Mutual Commitment Date should be discussed and documented during the Manager Plan to Close meeting. If a Mutual Commitment Date cannot be established, the examiner should provide an Estimated Closing Date.

(3) The Manager Plan to Close meeting can be held independently or as part of a workload or Technical Time Report (4502) review.

(1) The applicability of penalties should be considered during every audit and, if warranted, developed as the audit progresses. Only after all facts and circumstances surrounding an audit have been developed can a determination be made as to the application of appropriate penalties. See IRM 20.1.5, Return Related Penalties.

(2) IRC 6751(a) requires that the Service provide the taxpayer with the name of the penalty, the Internal Revenue Code section under which the penalty is imposed, and a computation of the penalty on the notice (report) imposing the penalty.

(3) The Penalty Approval Lead Sheet must be used by the examiner to determine whether an assessment of penalties is warranted in all cases with an increase in tax. The Penalty Approval Lead Sheet requires that the examiner seek their immediate supervisor’s approval. See IRM 20.1.1.2.3, Approval Prerequisite, and IRM 20.1.1.2.3.1, Timing of Supervisory Approval.

(4) The assertion or non-assertion of penalties must be documented in the case file whenever an audit results in a deficiency. The extent of the documentation will depend on the nature of the adjustments and the amounts involved. Summary statements (e.g., negligence penalty applicable or negligence penalty deemed not applicable), are not sufficient. The examiner must cite the appropriate regulations, rulings or court decisions that are specific to the case’s facts and circumstances for assertion or non-assertion of penalties. Alternative penalty positions must be documented in the workpapers when applicable.

(5) The examiner must use the Penalty Approval Lead Sheet to document the verification of previously assessed penalties.

(6) See IRM 20.1, Penalty Handbook, for more information regarding the assessment or abatement of penalties. See also IRM 4.25.7, Estate and Gift Tax Penalty and Fraud Procedures.

(7) IRC 6751(b) generally prohibits assessment of a penalty unless the initial determination of the penalty assessment was approved, in writing, by the immediate supervisor of the individual who made the determination or such higher level official as the Secretary may designate. The immediate supervisor must perform a meaningful review of the penalty determination. Proper written approval of the primary penalty and any alternative penalties included in the case file is mandatory. The examiner should document all formal and informal immediate supervisor involvement relating to any assessment or non-assessment of penalties in the Form 9984, Examining Officer’s Activity Record.

(8) The examiner should also briefly address the assertion or non-assertion of penalties in the penalty portion of the case specific mandatory lead sheet (e.g., Estate Tax Mandatory Lead Sheet).

(9) The examiner should review the accuracy of any previously assessed or abated penalties and document their findings in their workpapers.

(1) The examiner should use the Reasonable Cause Lead Sheet to document a taxpayer or preparer’s reasonable cause defense to the assessment of penalties.

(2) See IRM 20.1, Penalty Handbook and IRM 4.25.7, Estate and Gift Tax Penalty and Fraud Procedures, for reasonable cause analysis guidance.

(1) During every audit, examiners must be alert to fraud indicators and assert the civil fraud penalty when there is clear and convincing evidence to prove that some part of the adjustment increasing the tax was due to civil fraud. See IRM 25.1.2.3, Indicators of Fraud. Such evidence must show the taxpayer's intent to evade tax, which the taxpayer believed to be due. For every case resulting in a deficiency, examiners must document their consideration of fraud, including applicable fraud indicators, even if the civil fraud penalty is not pursued or developed.

(2) The Fraud Development Lead Sheet should be used to assist the examiner in determining whether the assessment of fraud penalties is warranted. For more information regarding fraud see IRM 25.1, Fraud Handbook, and IRM 4.25.7.7, Estate and Gift Tax Penalty and Fraud Procedures, Fraud.

(3) Fraud considerations and factors should also be documented on the case specific mandatory lead sheet and conversations with the examiner’s group manager regarding fraud should be documented in the case Form 9984, Activity Record.

(1) Risk analysis techniques are intended to assist the examiner in making decisions that may take additional time and involve some risk of failure or uncertainty of outcome. The examiner’s risk analysis should be documented on the relevant issue specific lead sheet. Risk analysis should be used to focus the examiner’s efforts on the issues that make a difference in the audit, instead of on the ones that have little or no adjustment potential. Risk analysis helps the examiner allocate time, resources, and efforts to gain efficiency, quality determinations, and taxpayer satisfaction. The examiner should apply risk analysis techniques to:

1. Expand the scope of the examination beyond the Risk Summary document prepared during classification and/or the group manager on assignment.

2. Facilitate conversations with management regarding the decision to cease work on classified issue(s) or managerial selected issues.

3. Assist other users of the file (cases that are reassigned, reviewed or sent forward to Appeals or Counsel) in understanding examination issue development decisions.

(2) The examiner should consider the following concepts when applying risk analysis techniques:

• Materiality

• Resources

• Adjustment Potential

• Overall Compliance Considerations

(1) The use of a lead sheet is required for all issues. However, the examiner may choose whether an issue-specific lead sheet, generic lead sheet or risk analysis technique best suits their needs. Regardless of which lead sheet is chosen, the examiner must use it to identify the issue and steps or actions taken to develop the facts, determine the applicable law, arguments made (including taxpayer arguments), and determine a conclusion for all classified or managerial selected issues. The examiner should document all managerial discussions to limit the examination issues in the relevant issue lead sheet and in the caseForm 9984, Activity Record.

(2) Issue lead sheets must reflect the issue name, adjustments (when applicable), conclusion, audit steps, facts, law, risk analysis, taxpayer's position, and conclusions reached. This information should be presented in a logical order so that the audit steps taken to support the conclusions can be easily determined. See IRM 4.10.9.6.2, Issue Lead Sheet, IRM 4.10.9.6.2.1, Issue Lead Sheet Format, and IRM 4.10.9.6.2.2, Issue Lead Sheet Content.

(1) The "All-in-One" lead sheet combines all Estate and Gift EPD into one Microsoft Word document and uses the Navigation feature of Word to navigate through the lead sheet.  The All-in-One lead sheet changes Notebook's current "Deploy the Lead Sheets You Need One at a Time" method to a "Delete the Lead Sheets that You Do Not Need" method.  The purpose behind the All-in-One lead sheets is to provide an "audit map" to guide the examiner through examination issues and an "audit trail" for a team member or reviewer to follow when reviewing the actions taken and the examination conclusions reached by the examiner.  

(1) An attorney advisor on the Estate and Gift Policy Program Manager's staff shall be assigned responsibilities for the Estate and Gift Embedded Quality Program.

(2) At the direction of the Estate and Gift Policy Program Manager, such attorney advisor's responsibilities include:

1. Establishing and providing guidance to meet program objectives,

2. Ensuring the consistency of the Estate and Gift Job Aid and training materials with the IRM and other guidelines,

3. Recommending updates to the quality attributes and process measures,

4. Maintaining instructional guides, forms, letters and the EPD system as needed,

5. Host embedded quality summit to discuss quality trends with affected stakeholders, as needed.

(1) Territory Manager responsibilities include:

1. Conducting analysis of the territory's NQRS and EQRS results and identifying opportunities for improvement, and

2. Conducting quality improvement initiatives to impact NQRS and EQRS results.

(2) Field group manager responsibilities include:

1. Conducting quality reviews on case work and inputting the results into the EQRS system,

2. Assisting Territory Managers in conducting analysis of the territory's NQRS and EQRS results and identifying opportunities for improvement, and

3. Conducting quality improvement initiatives to impact NQRS and EQRS results.

(1) Document 12499, Estate and Gift Tax Embedded Quality Job Aid, includes complete instructions, definitions, and examples of how cases should be evaluated by management and quality reviewers.