Simultaneous Examination of the Estate, Income and Other Internal Revenue Tax Liabilities of a Decedent and Those of His Estate

November 29, 1983 REVENUE MEMORANDUM ORDER NO. 40-83 SUBJECT : Simultaneous Examination of the Estate, Income and Other Internal Revenue Tax Liabilities of a Decedent and Those of His Estate TO : All Internal Revenue Officers and Others Concerned 1. The estate tax return of a decedent and all his unverified income tax returns five years prior to his death shall be simultaneously investigated by one examiner or a group of examiners. Only one letter of authority to investigate shall be issued but separate reports of investigation of the estate tax and income tax, including other internal revenue tax liabilities, if any, shall be submitted by the examiner(s) who conducted joint and/or simultaneous investigation. 2. The separate reports shall be consolidated into one docket for audit-review and approval and shall embody the following documents - (a) The estate tax return filed for the estate of the decedent. (b) The income tax return of the decedent for prior years and for the period from January 1 to the date of death. casia (c) The formal report in forms prescribed therefor, including working papers, analysis and computation sheets, etc. 3. If, under the existing Revenue Memorandum Orders or issuances, the investigation of the estate tax liability of a decedent comes under the jurisdiction of the Financing, Real Estate and Transfer Taxes Division (FRETT), the income tax return of the decedent from January 1st up to the date of death as well as all his unverified income tax returns for five years prior to his death shall be requisitioned by the Chief of the FRETT and the same shall be forwarded to the said Division by the regional offices concerned. If the investigation of the estate tax liabilities come under the jurisdiction of the regional office, both the estate tax return and all the unverified income tax return of the decedent, as well as his final income tax return for the period from January 1 up to the date of his death shall be assigned to one (or two examiners, if necessary) for simultaneous audit and investigation. acd 4. This Revenue Memorandum Order shall be applicable to estate tax returns which will be filed beginning 1984. RUBEN B. ANCHETA Acting Commissioner