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small case request for an Appeals Office conference Publication 5
states that a taxpayer must send a letter in which it identifies
the IRS’s proposed changes that the taxpayer disagrees with and
the reasons for disagreement.
Finally, Internal Revenue Manual (IRM) part 8.6.1.1.4(1)
(Dec. 13, 1999), Written Protests and “Small Case Requests” in
Unagreed Cases, states: “Appeals will consider matters under its
small case request procedures if the total amount for any tax
period is not more than $25,000.” The small case request
requirements under the IRM are virtually identical to those
stated in Publication 5. Unlike a written request for a small
case, a written protest is “required to obtain Appeals
consideration if the total amount for any tax period is more than
$25,000.” IRM pt. 8.6.l.1.4(2) (Dec. 13, 1999). A written
protest must include, among other things, “the facts supporting
the taxpayer’s position on any disagreed issue, and the law or
authority, if any, on which the taxpayer relies.” IRM pt.
8.6.1.1.4(2) (Dec. 13, 1999).
In this case, for each tax period at issue the proposed
change was less than $25,000. Having reviewed petitioner’s
letter dated October 24, 2002, we find that it complied with the
small case request requirements set forth in the 30-day letter,
Publication 5, and the IRM. Respondent did not grant
petitioner’s request but instead directed petitioner, in a letter
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