Large Dollar Refunds Are Not Always Examined and Sent to the Joint Committee on Taxation

The Commissioners, Large Business and International and Small Business/Self-Employed Divisions, should assess the compliance risk of the large-dollar original return refund claims that exceed I.R.C. Section 6405 dollar criteria that are not required to be examined and are not subject to the JCT review process due to Treasury Regulation Section 301.6402-4(a), relative to other tax returns, and allocate examination resources accordingly.

The Commissioners, Large Business and International and Small Business/Self-Employed Divisions, should take additional corrective actions on the carryback and amended return cases that were not examined or sent to the JCT for review as legally required to ensure that they are sent to the JCT.

The Commissioner, Large Business and International Division, should assign oversight responsibilities to a specific group or function for the overall JCT process to ensure that cases are sent to the JCT when required and procedures (such as placing the correct project code on the exam) are being followed.

The Commissioners, Small Business/Self-Employed and Large Business and International Divisions, should take corrective actions on all cases that were legally required to go to the JCT for review but did not to ensure that they are sent to the JCT for review.