IRS Transmittal of United States Attorney's Recommendation, Special Agent's and Criminal Tax Counsel's Reports, and Exhibits from Grand Jury Investigation

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DOJ Justice Manual › Title 6: Tax › 6-4.000 - Criminal Tax Case Procedures › Justice Manual § 6-4.125

This text was captured on Aug 14, 2026. It is a snapshot, not a live feed, so check the official code before relying on it.

Text

When a grand jury investigation is complete and the United States Attorney’s Office concludes that the Government has gathered sufficient evidence to proceed with prosecution, the United States Attorney’s Office should request that the special agent assigned to the matter prepare a SAR. After the SAR is completed, the special agent should request that CT Counsel review the SAR and prepare a CEM. Then, the SAC must forward the SAR, with copies of the relevant exhibits, and the CEM to the Tax Division for review and authorization. At the same time, the United States Attorney’s Office or the SAC must forward to the Tax Division the United States Attorney's Office’s written recommendation regarding prosecution of a target(s) for tax violations.

See

JM 6-4.200

. Whenever possible, the Tax Division will complete its review of the prosecution recommendation within thirty (30) days of receiving the transmittal letter, reports, and exhibits.

See

JM 6-4.242

.

The IRS also must transmit a recommendation against prosecution resulting from a grand jury investigation to the Tax Division for evaluation. Alternatively, the IRS must advise the Tax Division that it has no recommendation.

See

IRM 9.5.14.12.2(3)

;

see also

JM 6-4.242

. The Tax Division will complete its evaluation of the matter and authorize declination or other actions within thirty (30) days of receiving the recommendation.

[updated June 2020] [cited in

JM 6-4.242

]

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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IRS Transmittal of United States Attorney's Recommendation, Special Agent's and Criminal Tax Counsel's Reports, and Exhibits from Grand Jury Investigation · Justice Manual § 6-4.125 | Frix