IRM 25.6.5.7.2 (03-01-2006) Statutory Notice of Deficiency (90 Day Letter) 1. A statutory notice of deficiency may be issued by Examination, Collection, Deferred Adverse Tax Consequence (DATC/ASTA) and the Document Matching functions. Except for certain limited exceptions, a statutory notice of deficiency must be issued to assess and collect an income tax, estate tax, gift [...]

Congress has established that IRS agents may be held liable for specified forms of misconduct. An agent who, inter alia, “is guilty of any extortion or willful oppression under color of law,” or “knowingly demands other or greater sums than are authorized by law,” will be discharged from office and exposed to criminal penalties. 26 [...]