Emphasis on Unrelated Business Income Tax Enforcement Should Be Enhanced.

The Commissioner, TE/GE Division, should update the Classification and Case Assignment's Classification Desk Guide to require experienced senior EO classifiers to review claims involving an NOL prior to accepting the claim as filed and document the review in the case file.

The Commissioner, TE/GE Division, should implement safeguards to ensure the accuracy of the Reporting Compliance Case Management System Closing Record to avoid material errors that affect information reports based on these inputs, which are relied upon by internal and external stakeholders.

The Commissioner, TE/GE Division, should replace the respective IRM sections that provide instructions on the Form 5599 with the revised Reporting Compliance Case Management System Closing Record and clarify any differences in how examiners should complete this process for appealed examinations.