The Examination Plan – Form 4764
(IRM 4.46.3.5)
The examination plan is a written document containing agreements with the taxpayer, information for Service personnel, work assignments, audit procedures, time estimates, and special instructions. This plan is prepared using Form 4764, 4764A and 4764B or facsimiles thereof. The examination plan should only be as sophisticated and detailed as needed for the examination to be performed.
The examination plan generally consists of three sections. Part I is the Taxpayer Information Section (Examination Arrangements) and is an overall plan of the examination. Part II is the Service Management (Examination Program) Section and is essentially the team manager’s instructions to team members and contains information of a general management nature. Part III is the Examination Procedures Section, which contains each team member’s assignments and plan for the procedures to be used in accomplishing the assignment. Form 4764B is generally used to identify examination procedures to be used in the examination of each particular account of item.
The examination plan is a working tool and may be changed during the examination. The examination plan will be shared and discussed with the taxpayer. Modifications to the plan should also be discussed with the taxpayer.
In some examinations, a team manager can elect to use a streamlined examination plan. This is a condensed version of the formal examination plan and is still prepared using certain pages of Form 4764. The streamlined plan includes information such as Service personnel assigned to the examination, a Communications Agreement, list of taxpayer personnel contacts, Examination Schedule, and a preliminary listing of areas/issues to be examined on Form 4764A. The exact information included is dependent upon the specific facts and circumstances of each examination. The examination plan will be shared and discussed with the taxpayer.
To view an example of a formal examination plan, Form 4764, Examination Plan (pdf)
