The deficiency includes additional amounts, additions to tax, and interest. If the assessment or collection of a deficiency will be jeopardized by delay, the deficiency is immediately assessed. The deficiency may include additional amounts, additions to tax, and interest. The deficiency may be computed for a short period or the entire year. Exam will limit its investigation to a determination that collection of the currently proposed deficiency will be endangered if regular assessment and collection procedures are followed.
Appeals is responsible for making the final determination of the tax liability.
If Collection receives information on cases under active consideration by another division, the Chief, Collection should report such information by memorandum to the affected division. If CI receives information on cases under active consideration by another division, the Chief, CI should report such information by memorandum to the affected division. The taxpayer's financial solvency is, or appears to be, imperiled. After the referral of a case to CI or during a joint investigation, it shall be the continued responsibility of Exam and Cl to make periodic reviews of the facts and circumstances involved in the case to assure that the government's interests are adequately protected. The purpose of criminal tax investigations is to enforce the tax laws and to encourage voluntary compliance.