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

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/JM_S6-4.125

## Section

- **Citation:** Justice Manual § 6-4.125
- **Heading:** IRS Transmittal of United States Attorney's Recommendation, Special Agent's and Criminal Tax Counsel's Reports, and Exhibits from Grand Jury Investigation
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** DOJ Justice Manual / Title 6: Tax / 6-4.000 - Criminal Tax Case Procedures / Justice Manual § 6-4.125

## 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
]

## Nearby sections

- [Justice Manual § 6-4.010 Federal Criminal Tax Enforcement](https://www.frixlaw.com/law-library/statutes/JM_S6-4.010.md)
- [Justice Manual § 6-4.011 Criminal Tax Manual and Other Tax Division Publications](https://www.frixlaw.com/law-library/statutes/JM_S6-4.011.md)
- [Justice Manual § 6-4.110 IRS Administrative Investigations](https://www.frixlaw.com/law-library/statutes/JM_S6-4.110.md)
- [Justice Manual § 6-4.120 Grand Jury Investigations—Generally](https://www.frixlaw.com/law-library/statutes/JM_S6-4.120.md)
- [Justice Manual § 6-4.121 IRS Requests to Authorize Grand Jury Investigations](https://www.frixlaw.com/law-library/statutes/JM_S6-4.121.md)
- [Justice Manual § 6-4.122 United States Attorney's Grand Jury Investigations and Prosecutions](https://www.frixlaw.com/law-library/statutes/JM_S6-4.122.md)
- [Justice Manual § 6-4.123 Joint United States Attorney—IRS Request to Expand Tax Grand Jury Investigation](https://www.frixlaw.com/law-library/statutes/JM_S6-4.123.md)
- [Justice Manual § 6-4.125 IRS Transmittal of United States Attorney's Recommendation, Special Agent's and Criminal Tax Counsel's Reports, and Exhibits from Grand Jury Investigation](https://www.frixlaw.com/law-library/statutes/JM_S6-4.125.md)
- [Justice Manual § 6-4.126 Restriction on Disclosure of Grand Jury Matters to IRS for Civil Use](https://www.frixlaw.com/law-library/statutes/JM_S6-4.126.md)
- [Justice Manual § 6-4.130 Search Warrants](https://www.frixlaw.com/law-library/statutes/JM_S6-4.130.md)
- [Justice Manual § 6-4.200 Tax Division Jurisdiction and Procedures](https://www.frixlaw.com/law-library/statutes/JM_S6-4.200.md)
- [Justice Manual § 6-4.209 Stolen Identity Refund Charges](https://www.frixlaw.com/law-library/statutes/JM_S6-4.209.md)
- [Justice Manual § 6-4.210 Tax-Related Mail, Wire, or Bank Fraud, RICO, or Money Laundering Charges](https://www.frixlaw.com/law-library/statutes/JM_S6-4.210.md)
- [Justice Manual § 6-4.211 Standards of Review](https://www.frixlaw.com/law-library/statutes/JM_S6-4.211.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/JM_S6-4.125. Check the current official text before relying on it. Not legal advice.