The taxpayer in the Compliance Assurance Process (CAP) Program must disclose any Federal or State Agency investigation that could limit the IRS's access to corporate books and records or could result in a material tax item. This requirement ensures that the IRS is fully informed of any potential issues that might affect the taxpayer's compliance and the accuracy of their tax filings.
Sources:
Rev. Proc. 2022-9
IRM Part 9. Criminal Investigation. Chapter 5. Investigative Process. Section 11. Other Investigations
PMTA 01233
