Common Terms used in IRS Appeals - John R. Dundon II, Enrolled Agent
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Common Terms used in IRS Appeals

Common Terms used in IRS Appeals

90-day letter

Term includes the 150-day letter.



A file consisting of one or more examined tax returns of a taxpayer, the report of examination, and all papers, correspondence, and other documents relative to the taxpayer’s liability for the year or years involved. An administrative file may also consist of collection related documents such as history, correspondence, financial information, and other documents related to collection action taken on the taxpayer and the relevant tax periods.


Refers to an Appeals Officer and includes Appeals Officers, Settlement Officers and Collection Resolution Specialists.


Refers to Appeals Processing Services, the unit responsible for processing cases in Appeals.


Refers to Appeals Team Case Leader.


Refers to Appeals Tax Specialist, a campus employee who works campus generated post assessment penalty cases.

Audit Statement

A settlement computation which gives effect to the decision of Appeals or Counsel showing proposed adjustments, computation of revised tax liability, and deficiency or overassessment. It concerns examination issues and accompanies Appeals case memos. Referred to as Settlement Computations in IRM Part 8.


Refers to Employee Plans and Exempt Organizations, functional units within the Tax Exempt and Government Entities (TE/GE) Operation Division.


Refers to the Internal Revenue Code of 1986.


Refers to the Internal Revenue Manual.

Nondocketed Case

– A protested case in which the taxpayer has not filed a petition with the United States Tax Court.

Notices of deficiency (90-day letters)

References include those issued by the Operating Divisions and Functional Divisions of the Internal Revenue Service.

Pre-90 Day Cases

Term includes the pre-150 day cases.

Preliminary Letter

30-day and 60-day letters.


The taxpayer’s statement of disagreement with the adjustments proposed by Compliance.

Reference Return

Return which is associated with a case solely for the purpose of providing information.

Service Policy

IRS policy as expressed in a policy statement approved by the Commissioner.