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Part 8. Appeals

Chapter 21. Appeals Statute Responsibility

Section 2. Appeals Processing Services (APS) Statute Responsibility

8.21.2  Appeals Processing Services (APS) Statute Responsibility

8.21.2.1  (02-02-2007)
General Guidelines for Appeals Processing Services (APS)

  1. APS employees include the following positions:

    1. Processing Team Manager (PTM)

    2. Tax Examining Technicians (TE)

    3. Any other Appeals employee doing processing work similar to the TE.

  2. IRM 8.21 is the primary source of reference used by APS employees when verifying, updating, and monitoring statute dates on Appeals' cases.

  3. APS is responsible for verifying and monitoring the statute dates on all tax periods or returns under its jurisdiction. APS has jurisdiction of the case under the following circumstances:

    1. Case is input into Appeals Centralized Database System (ACDS) as being in APS possession.

    2. Case file is date stamped "received" by APS but not yet input into ACDS.

    3. Case file is transmitted to another location but no acknowledgment is received from the intended recipient.

  4. To ensure that adequate statute control is maintained at all times while APS has jurisdiction of the case, take the following steps:

    1. Timely open incoming mail and verify statute dates on all new receipts, including cases transferred from another Appeals Office;

    2. Keep ACDS current by timely updating ACDS for statute extensions/consents. Also, input new receipts and close cases off ACDS as soon as possible.

    3. Issue Statutory Notices of Deficiency (SND) timely;

    4. Immediately assign cases/returns when an assessment is required. The assigned APS employee will validate the assessment statute date upon receipt;

    5. Verify that Compliance-initiated assessments and abatements have been completed at the time the case is created on ACDS;

    6. Generate and process follow-up lists, as provided in IRM 8.20.9;

    7. Generate CASES on Processing Employees Automated System (PEAs) Inventory statute reports as outlined in this document;

    8. Monitor Partnership Control System (PCS) reports generated from ACDS for cases that have Tax Equity and Fiscal Responsibility Act (TEFRA) linkages.

8.21.2.2  (02-02-2007)
Verifying the Statute of Limitations on New Receipts

  1. Immediately upon assignment, inspect all case files to verify the earliest statute date for each tax period and each type of tax contained in the file.

  2. Also verify that the statute dates reflected on the transmittal and/or AMDISA print are correct.

  3. Never assume that the statute date on the transmittal and/or AMDISA is correct. If the statute date on Audit Information Management System (AIMS) is incorrect, update it to the correct date by using command code AMSTUB (positions 15-22). See Exhibit 8.20.2-16

  4. If it is unclear which statute date applies, always use the earliest, most conservative date. Alert the PTM, Appeals Team Manager (ATM) and/or Appeals technical employee assigned the case to the discrepancy.

  5. Verification of the statute date should include a review of all original, copy, information, reference or substitute for return contained in the file.

  6. Consider assessment and/or collection statute dates when verifying statute of limitations on the following receipts:

    1. Docketed Cases

    2. Innocent Spouse Cases

    3. Collection Due Process (CDP), Offer in Compromise (OIC), Trust Fund Recovery Penalty (TFRP), Penalty Appeals (PENAP)

  7. Use the most recently executed consent (Form 872, 872-A, etc.) when determining the statute date.

8.21.2.2.1  (02-02-2007)
Examining Consent Forms 872, 872-A, etc.

  1. Analyze the most recent consent (Form 872, 872-A, etc.) to ensure that it is properly executed, contains the correct taxpayer information, and covers all years and types of tax included in the work unit.

    Note:

    Although APS employees are not responsible for determining the validity of prior consents as long as the current consent is valid, the validity of prior consents should be determined by the Appeals Officer assigned to the case.

  2. If the current consent is not valid, the APS employee will need to verify the validity of the next prior consent. If valid, the statute date reflected on that prior consent will be used as the statute control date.

  3. The above actions will be repeated until it can be determined that there is a valid statute on all the returns included in the work unit.

  4. If a valid statute date cannot be determined, immediately seek assistance from the PTM in determining what statute date to use.

  5. If it is determined that a valid statute exists but there are less than 180 days remaining on the statute, follow the procedures found in IRM 8.20.4.1.

8.21.2.2.2  (02-02-2007)
Consent Signed by Individual Named in the Power of Attorney (POA)

  1. If an individual named in the POA, Form 2848, signs the consent, verify that the POA is authorized to sign the consent for the tax period, type of tax and taxpayer shown in the consent.

    1. If the POA form does not cover all periods, types of tax, etc. of the case, a notation should be made in the notes section of the case summary card alerting the ATM of this fact.

8.21.2.2.3  (02-02-2007)
Verifying Compliance Assessments or Abatements

  1. If there is evidence that Compliance should have made an assessment or abatement, request a current transcript to verify that the action was taken and follow these steps:

    1. Highlight assessment or abatement on the transcript.

    2. Place the transcript in the case file.

    3. Take action to process the assessment or abatement using Form 5403 or 3870.

8.21.2.2.4  (02-02-2007)
Special Situations

  1. On innocent spouse cases, you must first determine whether or not the amount at issue has been assessed in order to determine the appropriate statute date/code to input on ACDS for the requesting and non-requesting spouse. Refer to IRM 25.15.12 for procedures on receipt and control of Innocent Spouse cases.

8.21.2.3  (02-02-2007)
Cases Not Accepted by Appeals

  1. There are several cases that Appeals will not accept.

  2. If an APS employee receives any of the following cases for carding in, notify the PTM and return the case to Compliance:

    1. Cases where the Assessment Statute Expiration Date (ASED) statutory period of limitations has expired on any tax year in the case.

      Note:

      Cases where the Collection Statute Expiration Date (CSED) statutory period of limitations has expired on a CDP/Equivalent Hearing (EH) case are accepted in Appeals.

    2. Cases with less than 180 days remaining on the assessment statute. This is applicable to Compliance/Examination type cases.

    3. OIC cases where the taxpayers appealed too late. Statute dates on untimely appeals are not suspended.

      Note:

      Most Collection cases can now be appealed per statutory provisions. Those provisions may suspend the statute dates

    4. Trust fund recovery cases where the taxpayer appealed beyond the 60 days, and the normal ASED has expired. However, Appeals will accept the case if the taxpayer appeals late but there is at least one year remaining before the ASED expires. Statute dates on untimely appeals are not suspended.

    5. Cases that are in 90-day status.

      Note:

      If a 90-day case has Form 8626 (Agreement to Rescind Notice of Deficiency) signed by both the taxpayer and/or representative, and the designated official of the Internal Revenue Service, the case is accepted as long as at least 180 days remain on the statute.

    6. Cases that involve Jeopardy or Termination Assessments, unless an SND has been issued. The exception to the above is cases received in Appeals for administrative review, pursuant to IRC 7429.

    7. Cases that have an unassessed agreement in the file.

8.21.2.4  (02-02-2007)
Actions When Statute Date is Uncertain

  1. Any new case received in APS where the correct statute date cannot be identified will be handled as a priority case and identified as a short statute case until the correct statute date is determined. Under no circumstances should the case be held more than two (2) workdays without action to resolve the statute date question.

  2. If the tax examiner is unable to determine the correct statute date, immediately contact an ATM or other designated technical employee located on-site. If there is no one who can provide on-site assistance, seek guidance from the PTM.

  3. If for any reason the correct statute date still cannot be identified, the PTM may authorize use of STATCODE "UNKNOWN" on ACDS. This will allow the tax examiner to complete the card-in process on ACDS and move the case to the appropriate ATM for assignment.

    1. If the PTM is not available, the Area Manager can authorize use of STATCODE "UNKNOWN" .

    2. Every effort should be made to determine the correct statute date. STATCODE "UNKNOWN" will only be used in very rare situations.

  4. Before sending the case with a STATCODE of "UNKNOWN" to the ATM, it should be placed in a red folder and marked with an expedite tag to alert the receiver that the statute date is uncertain at this time.

  5. LACTION/LTODATE will show"to ATM" and the date the case was sent to the ATM for assignment. If possible, hand-carry the case to the ATM or designated technical employee.

  6. APS will utilize Form 3210 for all case movement out of APS. Jurisdiction shifts from APS upon confirmation of receipt (acknowledged 3210) by the ATM.

8.21.2.5  (02-02-2007)
Updating Statutes on ACDS and AIMS

  1. Statute date/code must be timely updated on ACDS and AIMS. Timely update is defined as one (1) workday from the date of notification or receipt of documentation.

  2. The following is a list of circumstances that affect the statute date, and will require an update to the statute date or code on ACDS and AIMS. See Exhibit 8.21.2–1 for ACDS Statute Codes.

    1. Signed consent forms extend the date to a particular date (i.e., Forms 872, etc.). When updating ACDS, enter the extended date in MM/DD/YYYY format (i.e., 12/31/2007).

    2. Other signed consent forms extend the assessment period indefinitely (i.e., Forms 872-A, 872-O, and 872-R). When updating ACDS, use the appropriate statute code A, O, R, etc.

    3. Signed notice of termination of special consent (i.e., Forms 872-T, 872-N, 872-Q, etc.). Enter a date of 90 days from when your office received the notice OR 90 days from mailing a signed termination to the taxpayer if issued by the Service.

    4. Petition filed with Tax Court. Eliminate the statute date and enter the statute code DOCKT.

    5. Petition filed with Bankruptcy Court. Enter the statute code BKRUP; however, the original statute date must also remain. In this instance, you also must also update the Feature Code with BK.

    6. Defaulted notice of deficiency. Enter a date of 150 days (210 for foreign country residents) from what the normal or extended statute date was before the statutory notice was issued. (Consent Forms 872-A, 872-O, 872-R, are cancelled on the date the statutory notice was issued.) See IRM 8.21.2.5.1, Adding Tack-On Time to Statutes.

    7. Agreement during the 90-day period after a notice of deficiency. Enter a date 60 days from the date the agreement is received in Appeals or the original statute date, whichever is later. See IRM 8.21.5.1 for procedures on tack-on time.

    8. Decision entered on a petitioned Tax Court case. Enter a date 150 days from what the normal or extended statute date was before the statutory notice was issued OR 150 days from the decision entered date, whichever is later. Eliminate the statute code DOCKT. If less than 60 days remain on the statute, compute the statute date using tack-on procedures. If you use a tack-on statute date, also input statute code TACKON. See IRM 8.21.2.5.1, for procedures on tack-on time.

    9. Decision entered on docketed substitute for return (SFR). Compute the statute date: Decision Entered Date + 3 years + 150 days = the newly computed statute date. For example: entered date = March 1, 2004 + three years = March 1, 2007 + 150 days = July 29, 2007. The newly computed statute date is July 29, 2007.

    10. Stay lifted on assessment by Bankruptcy Court. Enter at least 60 days from the date the stay was lifted. (This determination should be made by the Bankruptcy Coordinator or appeals officer.)

    11. Written request to update the statute date is received from the ATM or Appeals technical employee.

8.21.2.5.1  (02-02-2007)
Adding Tack-On Time to Statutes

  1. Appeals will not use "Tack-On" time unless there is less than 60 days remaining on the statute.

  2. "Tack-On" time is the number of days remaining on the statute date which is impacted by the issuance of a notice of deficiency or a tax court decision or order of dismissal being entered.

  3. "Tack-on" time for defaulted notices of deficiency is computed as follows: Issue date PLUS number of days from issue date to the normal or extended statute date before the notice of deficiency was issued.

  4. If the tack-on statute date is used at ANY time, the statute code FINAL must be entered for every return impacted. You should use the standalone program TackonACDS.EXE to compute the tack-on statute date. Contact your local Systems Administrator to request this be added to your computer.

  5. Tack-On Time—Agreed Notice of Deficiency

    • The tack-on statute date (90-Day Agreed statute) on an agreed notice of deficiency is the number of days that the statute was suspend plus 60 days.

  6. Tack-On Time— Defaulted Notice of Deficiency

    • Defaulted Notice of Deficiency - The tack-on statute date (90–Day Agreed Statute) on an agreed notice of deficiency is the number of days that the statute was suspended plus 60 days.

    • NOTE: Exception to the above — If a notice of deficiency was issued on a case extended by an executed Form 872–A, the default statute date is computed by adding 90 days plus 60 days to the date the notice of deficiency was issued. The statute date is not suspended indefinitely.

  7. Tack-On Time—Docketed Cases with Decisions Entered -

    • The tack-on statute date (Decision Entered Statute) on a docketed case with an entered decision is computed by adding 90 days (for the decision to become final) plus 60 days (for assessment) plus the suspension period (the period from the date of the notice of deficiency to the normal or extended statute date).

8.21.2.6  (02-02-2007)
Transmitting Files to Other Offices

  1. APS is responsible for monitoring the statute date on any case sent outside the local Appeals office until an acknowledgement is received from the recipient office.

    1. When transmitting unassigned non-docketed cases to Counsel for any reason, list all statute dates on the transmittal memorandum to Counsel.

  2. Annotate the earliest statute date on the front of the administrative file (Form 3198 or similar form) and on the transmittal.

  3. Since APS is responsible for monitoring the statute of limitations until the acknowledgement receipt is received, a follow-up should be made by phone or secure email if the acknowledgement is not received within 10 work days.

    Note:

    Acceptance of the ACDS inbox transfers by the receiving office transfers statute responsibility to that office.

  4. If the acknowledgement is not received within 20 work-days, contact the PTM for involvement.

  5. Transferring cases with assessment periods expiring within 60 days, should be avoided. Cases with imminent statute dates should only be shipped under the direction of the APS Area Manager.

  6. When secure emailing or faxing a case, include the Taxpayer's name (TPNAME, Taxpayer Identification Number (TIN), tax periods and statute dates.

  7. The receiving APS office will review all statute dates on the returns received to ensure the correct dates are shown on ACDS and AIMS.

8.21.2.7  (02-02-2007)
Receipt of Amended Return with Tax Due

  1. If a taxpayer files an amended return with an amount due on a tax year under consideration in Appeals, follow the procedures in IRM 8.20.6.9.1 for processing the amended return and updating master file and ACDS.

  2. To ensure that the statute is protected, the amended return will not be sent to Compliance until a partial assessment is made.

    1. If the amended return was sent to Appeals from the Campus, check IDRS to see if a partial assessment was made.

    2. If the amended return was sent directly to Appeals, take steps to process a partial assessment.

  3. When the case is sent to Compliance for review, the transmittal should clearly indicate that Appeals is retaining jurisdiction of the return.

  4. The Tax Reform Act of 1984 allows for an administrative extension for assessing statute year amended returns for Income Tax returns ( IRC Section 6501(c)(7)). If an amended return showing an increase in tax is received and the IRS Received Date is within 60 calendar days of the ASED, the assessment of tax on the amended return must be made within 60 days of the amended received date.

    1. This extension does not apply to Estate and Gift taxes, Employment taxes, and Excise taxes.

  5. An amended return does not automatically extend the ASED unless a condition exists to extend the assessment period. For a complete list of the conditions that extend the assessment period refer to IRM 25.6.5.6. Special Assessment Periods - Related to Return or Item on Return.

  6. Special procedures apply when an amended return is received on a taxpayer under criminal investigation. Specifically, the following issues exists:

    If Then
    TC 914, 916 (Z freeze), or TC 810 code Z (E freeze) is posted to a tax module, and the case file does not include Fraud Detection Center (FDC) (formerly the Criminal Investigation Branch) approval for assessment, Refer the case to FDC.
    TC 918 (Z freeze) is posted to the entity module, and the case file does not include FDC approval for assessment, Refer the case to the FDC control function for processing instructions.

8.21.2.8  (02-02-2007)
Receipt of Consent Termination (Form 872-N or 872-Q)

  1. Receipt of a Form 872-T, 872-N or 872-Q signed by, or on behalf of, the taxpayer, automatically decreases the statute date to 90 days from the receipt date of the form. Immediate attention must be given when any of these forms are received.

  2. The actions taken will depend on whether the case is open or closed. This section details the procedures to follow when these forms are received on both open and closed cases.

8.21.2.8.1  (02-02-2007)
Consent Termination on Cases Open in Appeals

  1. When a Form 872-T, 872-N or 872-Q signed by, or on behalf of the taxpayer, is received; ACDS and AIMS should be immediately updated to reflect the new statute date. This will cause the case to appear on the Statute Expiration Report so that it can be monitored.

  2. Immediate action should be taken to give the termination form to the technical employee assigned the case.

    1. If the employee is on-site, hand-deliver the form.

    2. If off-site, immediately fax the form. Email the technical employee to notify that the form is being faxed. Mail the original soon after.

  3. If the case is in the process of being closed as an agreed case, promptly process an assessment. Complete the case closing afterwards.

8.21.2.8.2  (02-02-2007)
Consent Termination on Cases Closed in Appeals

  1. When a Form 872-T, 872-N or 872-Q is received on a case that has already closed in Appeals, immediately check IDRS to determine if the tax year is open in another function.

  2. If it is, contact that function by phone or email to alert them of receipt of the form. A copy should be faxed immediately and the original form mailed to the other function using Form 3210.

  3. Ensure that the other function receives the acknowledgement.

  4. If the tax year is not currently open in another function, the PTM will forward the original form to the proper Campus for association with the return (refile or original DLN).

8.21.2.9  (02-02-2007)
Statutory Notice Procedures

  1. This section covers the statute procedures APS employees will follow when issuing an SND.

8.21.2.9.1  (02-02-2007)
Undeliverables and Unclaimed Notices

  1. If a Notice of Deficiency or Determination Letter is returned undelivered or unclaimed, follow the procedures in IRM 8.20.6.6.1.2.

  2. Prompt attention must be given when this occurs since the assessment period is still running.

8.21.2.9.2  (02-02-2007)
Agreement Received during 90(150)-day Notice Period

  1. If the taxpayer agrees to the deficiency in the statutory notice during the 90(150)-day period, process the assessment when the executed agreement form is received.

  2. Compute the new statute date following these steps:

    1. New Statute = 60 days + agreement received date or original statute date, whichever is later.

    2. If the statute was previously open under 872-A, add 60 days to the date agreement was received.

    3. Update STATDATE on ACDS with the new statute date.

    4. Update AIMS with the new statute date. See IRM 8.20.6.17.

  3. If these cases continue to appear on the statutory notice list, there may be a false sense of security created because the default date may indicate additional time available before closing action should be completed. However, the action taken above to update the statute date will cause the case to also appear on the statute list. If you choose to keep the case from appearing on the statutory notice list, you may assign a dummy docket number (i.e., 999-9 or remove the SNTYPE code.)

  4. Promptly notify the Appeals technical employee when an agreement is received during the 90/150-suspense period after an SND is issued. See IRM 8.20.6.6.1.3.

  5. TEFRA notices Final Partnership Administrative Adjustment (FPAA) and Final S Corporation Administrative Adjustment (FSAA) are treated similarly to SNDs as noted in IRM 8.17.4.17.

8.21.2.9.3  (02-02-2007)
Defaulted Notice Case

  1. Timely forward defaulted Statutory Notice cases for assessment. See IRM 8.20.7.25.1 for additional details.

  2. In some cases, petitions are not filed until the 90th/150th day. Because this occurs, APS will generally wait 15-30 days before defaulting the Statutory Notices to avoid premature assessments.

  3. However, Form 872-A cases should be defaulted within 10 days to allow ample time to make the assessment.

8.21.2.9.4  (02-02-2007)
Notice Issued on an 872-A Case

  1. Caution must be exercised when issuing an SND on a case that has the assessment period held open with a Form 872-A.

  2. At the time the notice is issued, either staple a pink Expedite tag or other Special Handling form to the front of the file to alert that a Form 872-A is holding the assessment period open.

  3. If the taxpayer submits an executed agreement form during the 90-day period on a Form 872-A case, take the following actions within five workdays:

    1. Request that the Appeals technical employee assigned to the case determine if Appeals accepts the agreement.

    2. Update the statute date on ACDS and AIMS to the agreement date + 60 days.

    3. Prepare the case for closing.

    4. Submit the case for assessment.

8.21.2.10  (02-02-2007)
Petitioned Cases

  1. Review all petitions received to determine whether all taxpayers and all tax periods are set forth as shown in the SND regardless of whether the Notice was issued by Compliance or Appeals.

  2. The actual petition must be checked against the Statutory Notice. The "List of Cases Docketed by the United States Tax Court" (whether in hardcopy or electronic form, see IRM 8.20.5.5.1) should not be relied upon for this information.

  3. If there is any question about whether the petition covers everything (all taxpayers and all tax periods) shown in the notice, contact Counsel for an opinion. However to protect the Government’s interest, assess the deficiency relating to the questionable taxpayer or period, and withhold collection. See IRM 8.20.6.2.2(2) for use of holding codes.

    Note:

    The transmittal to Counsel should note the details of the partial assessment.

  4. If the taxpayer does not petition one or more years of a multi-year notice, the statute date will need to be updated on AIMS. It may be necessary to establish a new workunit on ACDS for the non-petitioned tax years to control the correct statute dates. See IRM 8.20.7.25.3

8.21.2.11  (02-02-2007)
Receipt of Cases for Closing

  1. APS is responsible for review of all cases received for closing. The review should include verifying the correct statute date, and ensuring ACDS is promptly updated with the correct statute date.

    1. IRM 8.20.6.7.7 and IRM 8.20.7.12 are to be followed when processing tried, dismissed or settled docketed cases.

  2. Cases received in APS for closing will be date stamped and assigned as soon as received. The date stamp on the case will be the date entered into PEAS.

8.21.2.11.1  (02-02-2007)
Statute Verification on Case Closings

  1. When a case is assigned for closing, inspect the file to determine the correct statute date for each tax period and each type of tax in the case. Use the most current extension (Form 872, 872A, etc.) attached to the return.

  2. Consult with the PTM if there is uncertainty about the correct statute date.

  3. Cases not controlled on AIMS, such as Interim Action Request, and cases not controlled with an ASED statute date, such as Innocent Spouse cases, will also be reviewed for assessment statute determination.

  4. Closely inspect the file to ensure that all documents requiring assessment (partial agreements, taxable amended returns, etc.) have been properly processed.

8.21.2.11.2  (02-02-2007)
Processing Closings on Short Statute Cases

  1. A case received with less than 60 days remaining on the assessment statute requires preparation of a manual assessment package including Form 2859, Request for Quick or Prompt Assessment, for submission to the Customer or Processing Service Center Campus. Adhere to the following timeframes:

    1. Cases with statute dates expiring in 10 business days or less must be faxed to the Customer or Processing Service Center Campus.

    2. Cases with statute dates expiring in 11-59 days can either be sent by mail/courier, or faxed depending upon requirements/agreements with the local campus for each office.

  2. Follow-up action will be taken if no verification has been received prior to the 23c date.

  3. Responsibility for monitoring the statute remains with APS until verification is received. When received, actions should be taken to ensure that the correct taxpayer, tax period, and tax amount were assessed before filing the verification.

  4. Cases received with an assessment period expiring the same day will be processed using the After Hours Assessment procedures, if received beyond the cutoff time for the campus that services the office with the case. Responsibility for monitoring the statute date remains with APS until verification is received.

  5. Prior to any known absence from the office, notify the PTM of short statute cases needing action. Once notified, the PTM is responsible for follow-up actions on the case during the employee’s absence.

8.21.2.11.3  (02-02-2007)
Cases That Reject at Closing

  1. When a case sent for closing is missing or contains incorrect information, contact the technical employee for clarification. It is important to remember that the jurisdiction of the case is with APS.

  2. If a case is rejected and the tax periods have not been assessed/abated, do not change the statute date information. By leaving the original statute date, it ensures the case will continue to be monitored on ACDS.

  3. Follow procedures in IRM 8.20.7.2 for updating the statute date and statute code on ACDS for any rejected returns.

  4. If the case is to be returned to the Appeals technical employee, the APS employee will note the earliest statute date on the front of the case file and ensure that the correct statute date is reflected on ACDS. APS will use Form 3210 to return the case to the technical employee. Jurisdiction shifts to the technical employee upon receipt of an acknowledged Form 3210. If the assessment period will expire in less than 60 days, the ATM should be advised by e-mail that the case is being transferred to the technical employee.

8.21.2.11.4  (02-02-2007)
Unpostable Closings

  1. Copies of all REQ54 adjustments will be placed in a " monitor folder" . IDRS monitoring for unpostables will be done weekly to ensure any unpostables are caught and corrected before a statute problem occurs.

8.21.2.12  (02-02-2007)
Individual Statute Reports

  1. On a weekly basis, each APS employee will generate their individual statute report, and annotate the status and actions taken or expected to be taken on the report.

  2. This report will be returned to the PTM for review of the notes and verification that the proper actions are being taken.

  3. The individual statute reports for each APS employee will be attached behind the monthly report for the entire group.

Exhibit 8.21.2-1  (02-01-2007)
ACDS Statute Codes

Code Description Source Document
6501E 25% Omission Exam Report
872–A 872–A Form 872–A
872–F 872–F Form 872–F
872–O 872–O Form 872–O
872–R 872–R Form 872–R
ABATE Abatement of Previous Assessment Form 3870
ABINT Abatement of Interest Form 843
ASESD Assessment Made Transcript of Account
BKRUP Bankruptcy Various documents (including lien)
CBYYYYMM Carryback + year i.e. CB200312 Exam Report, claim forms, etc.
CLAIM Claim Amended return, Form 843, etc.
COLL Collection is controlling the Statute  
CSED Collection Statute Expiration Date IDRS research
DOCKT Docketed Docket list, petition, etc.
EXAM Exam is controlling the Statute Approved Early Referral Request
FINAL Tack-On time statute Only used when less than 60 days remains on the statute for SND and Tax Court decisions
FRAUD Fraud Exam Report, Doc. 6411
N/A Not Applicable  
NPS Non-Petitioning Spouse Used on the Joint Return Key Case
RFRTN Reference Return  
SUB Substitute for Return Administrative file contents, IDRS research, etc.
SUSP CSED Suspended Collection Due Process administrative file contents, Innocent Spouse administrative file contents, etc.
TBOR2 T/P Bill of Rights Trust Fund Recovery Penalty administrative file
TFINV TEFRA Investor  

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