Can a Bridge year be opened for examination

Yes, a Bridge year can be opened for examination under certain limited circumstances.

During the Bridge phase, the IRS generally does not accept disclosures, conduct reviews, or provide assurances. However, there are specific situations where a Bridge year may be opened for examination. These situations include:

• Evidence of fraud, malfeasance, collusion, concealment, or misrepresentation of a material fact.
• Any new material issue not previously reviewed.
• Any material changes to a previously reviewed issue.
• Any material issue that was reserved for or reported on Schedule UTP during the Bridge year.
• Any material Campaign issue.
• Any clear arithmetic error or material error based on an established service position.
• Any claim for refund that exceeds the Joint Committee on Taxation threshold.
• Any other circumstances where a failure to open an examination would not be in the interest of tax administration.

Therefore, while the intent is not to open a Bridge year for examination, these exceptions allow for the possibility under specific conditions.

Sources:
IRM Part 4. Examining Process. Chapter 10. Examination of Returns. Section 2. Pre-Contact Responsibilities
IRM Part 4. Examining Process. Chapter 70. TE/GE Examinations. Section 12. Planning the Examinations
IRM Part 4. Examining Process. Chapter 75. Exempt Organizations Examination Procedures. Section 12. Required Filing Checks and Package Audit Procedures
IRM Part 4. Examining Process. Chapter 71. Employee Plans Examination of Returns. Section 1. Overview of Form 5500 Examination Procedures