In 2005, the IRS posted information online that a transcript notation with the code “421” could be used to determine when the IRS had concluded its review of a filed estate tax return, in place of obtaining a closing letter. This indicated that closing letters would no longer be automatically issued but could be requested. Now, this information has be formalized into a Notice, essentially to notify the probate courts that they can rely on IRS estate tax transcripts bearing the “421” transaction code. The Revenue Procedure also mandates that the IRS can still reopen the review under specified circumstances.
See Charles Rubin, IRS Formalizes Transcripts as Substitute for Estate Tax Closing Letters, Rubin on Tax, January 18, 2017.
Special thanks to Joel Dobris (Professor of Law, UC Davis School of Law) for bringing this article to my attention.
