The Campus E&G operation processes items related to domestic and international estate and gift tax returns. This includes responding to telephone inquiries, processing amended returns, extensions to file and pay, and installment elections; maintaining annual installments and extensions, computing interest, classifying returns, preparing and sending closing letters upon request.

The site is a blended operation that provides service in the form of account maintenance activities, payment and filing activities, and reporting compliance activities. The IRM addresses all activities performed by the site with cross reference to other IRMs when appropriate.

The information in this section is based upon the following authorities (not all inclusive):

The Director, Examination - Field and Campus Policy, reports to the Director, Headquarters Examination, and is responsible for the delivery of policy and guidance that impacts the field and campus examination process.

Campus Exam and Field Support, which is under the Director, Examination - Field and Campus Policy, is the group responsible for providing Servicewide policy guidance on compliance processes that relate to campus examination operations and support Field Exam and Specialty programs in SB/SE and Large Business & International (LB&I).

The following table lists commonly used acronyms and their definitions used throughout this IRM.

E&G Operation employees are required to use the Integrated Automation Technologies (IAT) tools, shown in the tables below, whenever possible. The use of some of the tools is mandatory. The IAT tools simplify processing by assisting the user with IDRS research and input. The tools reduce the chance of errors and improve productivity. They are desktop productivity enhancing tools.

If an IAT tool is not available or an employee has a problem with the IAT Tool Manager, the case should be processed manually. Employees should report any issues with IAT to management.

IAT tool users can visit the IAT website to sign up as a subscriber to the IAT newsletter. The iNews details all ongoing IAT activity with tool retirements and rollouts.

The following IAT tools are mandatory to be used:

The following IAT tools are optional and available for processing E&G cases. This list is not all inclusive:

The clerical function is responsible for sorting, processing and controlling all incoming mail.

Mail is received twice a day (morning and afternoon).

Date Stamp all receipts.

Sort the mail by form:

Route any mail that does not belong to Campus E&G to the appropriate location using the Servicewide Electronic Research Program (SERP) Mail Routing Guides. See SERP Mail Routing Guide

All work is assigned by the clerical staff to TE’s and TTT’s through the direction of Campus E&G management.

The table below shows the sorting of the mail:

Sort the following replies by IDRS Number:

Control on Integrated Data Retrieval System (IDRS) using appropriate literals. The table below shows the work Activity, Description, Organizational Function Program (OFP) and the IDRS Control Category:

Estate amended returns are processed by examiners at the Cincinnati Campus.

Amended Form 706 or Form 706-NA can be received as an unnumbered (no DLN) return with correspondence or as a numbered return, posting as a TC 976, causing a CP 193 or CP 293, Duplicate Filing Condition. This creates an "-A" freeze. See IRM 21.7.9.4, Duplicate Filing Condition Procedures for additional instruction.

When processing an amended return, verify the following:

When processing amended returns, you need to research by checking the following:

Use the applicable Item Reference Numbers (IRNs) when adjusting an estate return. The following table shows valid IRNs for Form 706:

IDRS allows up to $999,999,999.99 per adjustment. BMF processing only allows one adjustment to post per cycle. If an adjustment to the account is needed for more than the allowed amount, it is necessary to input an OSGetServices ticket to the BMF transaction posting team requesting for all adjustments to post within the same cycle. Open a OSGetServices ticket by:

Form 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts, is used by the trustee/designated filer of a qualified domestic trust to determine and report tax on certain distributions, the value of property on the date of the surviving spouse’s death and the corpus portion of certain annuity payments. E&G assists NMF when secondary or duplicate returns are received by providing specific instructions on appropriate actions to NMF. TTT’s review the account and document making one of the following recommendations:

To associate or process as a new return, provide instructions to NMF on action to take using Form 3210, Document Transmittal.

To amend an existing account, prepare one of the following forms:

If an extension request is received on the Form 706-QDT, make the determination regarding the extension, notate whether it is approved and send to NMF for processing.

Form 709 – International Gift Tax Return:Form 709, Part 1, Line 5 and Line 7 determine legal residence (domicile) and citizenship of taxpayer. A taxpayer is international if the residence (domicile) and citizenship shown on Lines 5 and 7 in Part 1 of Form 709 is not United States, USA, etc. International taxpayers filing Form 709 should be referred to a TTT due to the unique differences from the domestic returns. For example:

The referral package should include a MFTRA U print for the donor and spouse, if the information is available. Notate on the referral document if the donor and/or spouse are nonresident aliens. Process the amended return per instructions received from the TTT.

International Returns - Additional Information: Treaty listings are found at the following site: https://www.irs.gov/businesses/small-businesses-self-employed/estate-gift-tax-treaties-international. Form 8833 is the form used to claim treaty benefits. A statement attached to the return providing the same information is acceptable. If missing, check the original return for the form or request from the estate.

If the amended return is filed to correct a math error, follow IRM 21.5.4, General Math Error Procedures. These amended returns should not be referred to a TTT or ETA.

TTTs are responsible for processing amended Form 709 returns that are filed to report late Generation-Skipping Termination (GST) exemption allocation and supplemental returns filed pursuant to Rev. Proc. 2004-46.

The threshold requirement for relief pursuant to Rev. Proc. 2004-46 is that on or before December 31, 2000, the taxpayer made or was deemed to have made a transfer by gift to a trust from which a GST may be made. The allocation must:

Additional information should be requested if necessary to perfect the return and/or verify compliance. A determination will be made as to whether the requirements for granting relief to make a GST exemption allocation have been satisfied.

The Taxpayer will be notified if the requirements for granting relief to make the GST exemption have been satisfied and will notify the taxpayer of the result of the determination.

If necessary, complete a technical referral to Campus ETA to verify whether the amended return qualifies for the 2004-46 late GST allocation. See IRM 4.25.2.9.4.2, Technical Referrals for more information.

Any other questionable amended gift tax returns involving GST exemption allocation issues other than those addressed above (i.e. late elections out of the automatic allocation rules, incomplete information on the return, post 2000 gifts, 2010 GST issues, etc.) should be addressed at the discretion of the TTT as follows:

In the event of the death of an estate executor and/or the appointment of a new executor, secure verification that the new executor was appointed by the estate. This involves securing the appropriate documentation such as Will, Letter of Testamentary, Court Appointment or other appropriate documentation, such as a Form 56, Notice Concerning Fiduciary Relationship.

When it becomes known that a new executor has been appointed for an estate, the Tax Examiner (TE) will research using IDRS CC CFINK to determine if a new Form 2848 is on file. CFINK will show a new signature date and what information the POA is entitled to for a specific estate. If there is a new Form 2848, the information may be disclosed to the POA on file.

If there is evidence that the executor appointed by the estate is deceased and/or a new executor is appointed, and there is no new Form 2848 on file (CFINK), the TE must contact the new executor via correspondence or phone call. The TE will advise the new executor that a new Form 2848 must be filed regardless of whether the same POA will be representing the estate. No release of information will be made to the POA until a new Form 2848 is received and approved by the IRS.

During processing, a line item on the return may be changed resulting in a balance due notice due to IRS error. See IRM 21.5.3.4.16.1, Account Adjustments, Administrative Errors. This can happen with both domestic and international returns. The individual responsible for the estate normally contends that the tax is not owed. To resolve this issue:

Suppress balance due IDRS Notices with Command Code (CC) STAUP. See IRM 21.5.2.4.8.2, Suppressing Balance Due Notices, to determine the number of delay cycles necessary.

The same estate can have two separate accounts when there should only be one account. This frequently occurs with international accounts. The estate is given a Taxpayer Identification Number (TIN) beginning with a "9" to reflect an international temporary identification number. A return can be filed before the number is received resulting in two accounts. There can also be two returns for the same estate posted under different numbers. Research using IDRS CC NAMES, NAMEE and NAMEI. If two numbers have been assigned to the same decedent, provide the estate with the correct number to use. Follow the procedures regarding merging accounts in IRM 21.7.10.4.3, Determining if Accounts Can/Should Be Merged.

The estate can receive a balance due notice if a payment is not shown on the account. The payment may be misapplied or was incorrectly moved off the account. Check the following for the payment:

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A Form 5706, Case History Sheet, is required on all penalty abatement cases. It must document the reason the estate feels the penalties should be removed, the TE's determination and the adjustment.

If the penalty abatement determination by the TE results in an abatement of ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡, refer to TTT, and if ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ refer to ETA. All other requests are worked by the TE.

Reasonable cause should be considered for both domestic and international returns when a request to remove penalties is received. See IRM 20.1.1.3, Criteria for Relief from Penalties.

If processing a penalty abatement request for an international return, consider the following:

Check IDRS to see if the account is assigned to Collection or if there is a TC 421. If the account is assigned to Collection, coordinate with Collection regarding the abatement request.

Penalty abatement requests on accounts in open examinations require WSD scanning. If open to Field:

If the return is in EGC 1078:

If return is in EGCs 1000, 1001, 1895, 1898 or 1899 Awaiting Classification:

The purpose of Form 4810, Request for Prompt Assessment Under IR Code Section 6501(d), is for a taxpayer to request prompt assessment of gift tax or other kinds of tax (not estate tax). Requests for prompt assessment of gift tax may also be requested by a taxpayer using their own format if they list all the same information required on Form 4810 in their correspondence.

Form 4810 is a time sensitive document.

Assign all Form 4810 to a TTT in a red statute folder.

Requests that should be denied immediately:

Forms in the Form 706 series ineligible for IRC 6501(d) prompt assessment:

Review Requests: A valid Form 4810 includes the following:

If request is incomplete or invalid for any reason, the TTT will advise the requestor accordingly using Letter 621-C, Prompt Assessment Request: Acknowledgement/Reply/Additional Information Requested, with the appropriate paragraph.

If Form 4810 lists a Form 706 return, deny as stated in IRM 4.25.2.5.6(5), unless the request pertains to GST tax. If GST tax is involved, forward to ETA for review and action determination prior to updating the Assessment Statute Expiration Date (ASED). Campus wants to avoid ASED confusion between the Form 706 estate tax return ASED and prompt assessment request for GST tax. Do not send the Form 4810 request to the National Gatekeeper if all gifts are a combination of:

After verifying the listed Forms 709 have been filed, request all E&G returns listed on the forms and any additional Form 709 returns not listed regardless of open statute. (This pertains to Deceased Spousal Unused Exclusion (DSUE) and to determinations for classification and verification of accuracy of current filings.)

There is a one-day turnaround from receiving Form 4810 to requesting returns.

Expedite return request due to short statute.

After requesting the required tax returns for tax periods listed on Form 4810, input:

Within 2 days of receipt of the gift tax returns listed on Form 4810, review the gift tax returns and follow the table below:

If any requested gift tax returns not listed on Form 4810 are not received at the same time as tax returns listed on Form 4810, follow the table below:

If the National Gatekeeper sends the Form 4810 back to Campus E&G stating the Form 4810 will not be sent to the field, consider it accepted as filed. Associate the Form 4810 with the Form 709 and send to C-Site to be re-filed.

When IDRS indicates Form 706 for the taxpayer is under examination in the field, notify the Campus E&G Department Manager immediately of the Form 4810 receipt. The Department Manager will notify the National Gatekeeper for assignment and routing to Field ETA.

Form 5495, Request for Discharge from Personal Liability Under IRC 2204 or IRC 6905, should be assigned to a TTT to make the determination if the request for discharge from personal liability should be granted.

If the Service does not issue a notification of determination of estate tax timely based on the received date of the request, the fiduciary or executor is automatically discharged from personal liability (applying only to them in their personal capacity and their personal assets).

The following table provides instructions for Form 5495:

For certain estate tax returns (Form 706 and Form 706-NA) filed after July 2015, Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent, along with a copy of any required Schedule A, is used to report values of property passing to beneficiaries from an estate.

Only estates required to file Form 706 or Form 706-NA are required under IRC 6018(a) and (b) to file Form 8971 and only certain property is required to be reported.

Form 8971 is not required when:

The executor must file the Form 8971 with the IRS on or before the earlier of:

Failure to file a valid Form 8971 by the due date will result in penalties under IRC 6721. Only one penalty will apply for all failures relating to a single filing of a single Form 8971 and the Schedules A required to be filed along with it. The amount of the penalty depends on when the valid Form 8971 with the required Schedule A is filed.

Form 8971 is filed at the Cincinnati Campus, Stop 824G. Campus E&G is responsible for the initial processing of Form 8971 as described in this IRM section.

On receipt of Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent, check the Form 706 account to determine if the TC 150 has posted.

Document all actions on Form 5706, Case History Sheet, or similar document. Use the IF/THEN Table below to determine what should be done with Form 8971, based on if TC 150 has posted or not posted:

The process of creating a potential penalty case file for a valid Form 8971 not timely filed (as previously described in IRM 4.25.2.5.8(9)(10-08-2020)), has been suspended.

A protective claim may be filed at any time before the RSED expiration to preserve the estate's right to claim a refund by reason of claims or expenses that are not paid or do not otherwise meet the requirements of deductibility. A protective claim does not have to state a particular dollar amount or demand an immediate refund. However, to be valid, a protective claim must:

Processing Schedule PC, Protective Claim for Refund: A protective claim can be filed with the return or submitted after the return is filed. A protective claim is normally filed on the Schedule PC and attached to the original return. Submission Processing will copy the schedule and route to Campus E&G. Protective claims can be filed on an amended estate tax return. All protective claims must be processed so the account reflects that a claim was filed.

Effective October 28, 2021, Treasury Decision 9957 established a user fee of $67 for persons requesting the issuance of Letter 627, Estate Tax Closing Letter. The requestor must utilize Pay.gov (at www.pay.gov) to pay the user fee and request the estate tax closing letter, however the closing letter will be issued only to the address(es) of record. A closing letter cannot be issued until TC 421 is posted and the account is full paid. The status on AIMS must be closed before a closing letter can be issued.

Phone Requests: The phone assistor should advise the caller to submit the request for closing letter and pay the user fee through Pay.gov. No estate tax closing letters will be issued over the phone.

If the caller requests a transcript, advise the caller to submit Form 4506-T, Request for Transcript of Tax Form. The form and its instructions can be obtained on IRS.gov. Most requests are processed within 10 business days.

Authorized representatives may request transcripts through the e-Services Transcript Delivery System (TDS), found on IRS.gov. If the caller states they are unable to secure the transcript via TDS, advise the caller to submit Form 4506-T, Request for Transcript of Tax Form. They may also contact the e-help desk at 866-255-0654 for further assistance.

Closing letters only apply to Form 706 and Form 706-NA. If a closing letter request is made on a Form 706-A, 706(QDT) or Schedule R-1, a NMF transcript should be issued in lieu of a closing letter.

Campus E&G will generate the Pay.gov Collections Report weekly to identify estates that have paid the user fee and need an estate tax closing letter issued. In addition, an automated payment confirmation is emailed from Pay.gov to the designated E&G mailbox, SBSE.EEF.Closing.Letter.User.Fee, once the requestor pays the user fee. See IRM 4.25.2.5.10.1, Processing and Monitoring Pay.gov ETCL Requests

Utilize the payment confirmation email to locate the Estate’s TIN. Update the applicable weekly Pay.gov Collection Report Excel spreadsheet with the applicable information.

TIN’s listed on Campus Closing Letter Fee spreadsheet indicate a user fee was paid. Follow the IF/THEN chart to determine if a closing letter should be issued:

If the tax period reflects a prior tax change (29X or 30X), the request should be assigned to a TE or TTT for closing letter research and issuance.

Correspondence Requests received before 10/28/2021:

Correspondence Requests received on or after 10/28/2021: The request should be denied by issuing Letter 6477, Notice of Denial, Estate Tax Closing Letter, using the appropriate selectable paragraph. Valid closing letter requests will be addressed through Pay.gov reports and the email confirmations received through the designated E&G mailbox, as cited above.

All closing letters should be issued from the IMS closing letter database. Place letters in the designated area for PAS sampling. Once PAS completes the pull of letters for review, the remaining letters are mailed by clerical.

Refund Requests: Refund requests are emailed directly from the requestor to the designated E&G mailbox, SBSE.EEF.Closing.Letter.User.Fee@irs.gov. Refund requests received through the mailbox are considered correspondence. The request must contain the following:

If the request does not contain the above required information, issue Letter 6478, Notice of Denial, Estate Tax Closing Letter User Fee Refund Request, using paragraph F.

Refund Approval: If the refund request is initially determined to be warranted by the employee reviewing the request, approval for refund requires managerial and HQ Policy approval. Research conducted and supporting documentation regarding the refund request should be provided to the manager. If the manager agrees, HQ Policy will review for concurrence. Refunds will be issued only in limited cases. See “What if I want to request a refund?” on IRS.gov’s FAQ on ETCL for additional information.

Refund Denial: If the refund request is denied, issue Letter 6478, Notice of Denial, Estate Tax Closing Letter User Fee Refund Request, using the appropriate paragraph.

Ensure the Campus Closing Letter Fee excel spreadsheet is updated to reflect the refund request status.

All closing letters should be issued from the IMS closing letter database. Place letters in the "Quality Review" basket. When the Program Analysis System (PAS) completes the pull of letters for review, the clerk gives the remaining letters to the examiners to mail.

Follow normal procedures for Closing Letters for requests from Nonresident Citizens and Nonresident not citizens of the United States. Follow the procedures in this section for Transfer Certificate Requests.

General information for Form 706 and Form 709.

Closing Letter Requests.

Status of Form 706.

Balance Due notices.

General information on GST.

Form 706 and Form 709 transcript requests.

Status of international transfer certificate.

Form 4422, Application for Certificate Discharging Property Subject to Estate Tax Lien, requesting address to mail the form.

Other types of calls not listed here.

Greet the caller.

Target the caller’s question.

Provide assistance. Provide accurate and complete assistance and/or appropriately refer the taxpayer to another source, if required.

Use appropriate hold procedures.

Close the conversation. Verify the taxpayer's understanding and conclude the contact courteously.

Use IAT Disclosure Tool when possible. For additional information on IAT Tools see IRM 4.25.2.2.1 , Integrated Automation Technologies (IAT) Tools.

For calls about Forms 706-NA, IRM 4.25.2.7.5, International Calls.

The table below provides taxpayer and representative authentication for Form 706:

The table below provides taxpayer authentication for Form 709:

To ensure quality service, E&G employees can provide the name and extension number of the E&G campus employee assigned to the taxpayer’s case when transferring the customer to the correct extension.

Calls unrelated to E&G should be transferred to the appropriate phone number. Provide the phone number to the taxpayer prior to transferring a call.

The table below provides a listing for transfer numbers to be provided to the taxpayer prior to transferring the call:

E&G has a phone voice mail system (VMS) dedicated to international phone calls. The number is 859-320-3456 and used by international callers who can’t use the 800 number. Check the international mailbox and voicemail daily and respond within three business days. The same domestic call disclosure rules apply to international calls. Incoming international calls may present a communication or language problem. The caller may be an interpreter or a TTY representative, calling on behalf of the executor. Follow IRM 11.3.3.3.1, Use of Interpreters in Tax Administration. There may be people in the work area that can communicate in Spanish if needed, check with your manager. It may be helpful if you speak slowly, use short sentences, and ask the caller if the instructions are understood and have them repeat the instructions back.

Incoming phone calls can be received over the Finesse phone system or the unit phone. Some callers from Canada cannot call the U.S. toll free line. When possible, give the non-toll free number on outgoing correspondence as well as the toll-free number.

If the caller claims they have submitted some type of document but does not know the SSN or Internal Revenue Service Number (IRSN), request them to spell the decedent’s first and last name, where decedent was domiciled and where the executor resides. Research using IDRS CC NAMES and NAMEE, ** in the country and it will bring up all foreign addresses under that name. NAMEI, 000 can be used as the zip code if foreign country. If a number is found, proceed with disclosure and assist the caller. Issue a letter to advise the estate of the correct number to use.

If a SSN or IRSN number is not found, check the listing for transfer certificates found on the E&G common drive at: S:SBSE:CP:FSO:Dept 1, Common Area, Forms Letters and Work Sheet, International, Transfer Certificates. The listing is in ALPHA order and will indicate if a SSN/IRSN was provided. Access to this common drive is limited to specified campus employees.

If no information is located, use the probe and response technique to establish the best course of action needed to help them. The assistor may need to request the information be faxed or resubmitted.

Outgoing phone calls can be made on one line in each team. Check with your manager to confirm the correct line to use. Prior to making a call, the website http://www.countrycallingcodes.com/ can be used to confirm the international prefix and country code for the location being called. Be considerate of the time difference when calling another country.

International Electronic Facsimile (E-FAX): E&G has an e-fax number for POA and executors located in the United States to use, 855-201-8011. The e-fax number for POA and executors located outside of the United States is 304-707-9970.

When an Estate Tax Return is filed, it is processed and posted to the Business Master File (BMF). During the process, the return is marked with certain identifiable codes called a Payment Indicator Code (PIC). When these indicator codes are identified in the system, CP 191, computer generated notices are issued to the campus. The codes and indicator explanations are in the following table:

The following sections provide guidelines for processing IRC 6081, Extension of Time for Filing Returns, IRC 6161, Extension of Time for Paying Tax, and IRC 6163, Extension of Time for Payment of Estate Tax on Value of Reversionary or Remainder Interest in Property.

An estate will be allowed an automatic 6-month extension of time to file the estate tax return within the Form 706 series, if Form 4768, Application for Extension of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes, is filed on or before the due date of the applicable return.

Basics:

A request for an automatic extension of time to file will be disapproved if any of the following conditions are met:

The following sections provide guidelines for processing IRC 6166 installments.

If the estate requests voluntary early terminationat any time, either via telephone or correspondence, send pattern letter, Waiver of Right to Administrative and Judicial Review of Termination of IRC 6166 Election, in IRM Exhibit 4.25.2-3. This letter requires managerial review, approval and signature. Establish a 30-day follow-up date to monitor for the taxpayer response. Document the database that the request for early termination was made, the letter was sent to the executor for signature and the follow up date. Should the next billing date arrive before receipt of the letter, continue normal billing procedures.

The date of termination is the IRS received date of the signed Waiver of Right to Administrative and Judicial Review of Termination of IRC 6166 Election.

Upon receipt of the signed Waiver of Right to Administrative and Judicial Review of Termination of IRC 6166 Election, take the following actions:

Monitor the account for the adjustments to post and Status 21. Prepare and issue Letter 6335-F, Notice of IRC 6166 Denial or Termination. Letter 6335-F shall be dated and mailed certified mail, return receipt requested, on the 23c date. Do not check any boxes, attach a copy of the letter signed by the executor requesting early termination. Send the Letter 6335-F to the executor and the current POA on file.

Send Advisory ETL group a copy of the letter agreement to voluntary early termination along with a copy of the Letter 6335-F.

When the account goes to Status 21, accelerate the account to Status 26 using command code ASGNB with assignment code 6466. Close case. Associate all the correspondence related to the termination of the IRC 6166 election to the Form 706.

If the estate decides not to voluntarily terminate the 6166 election, or if no response is received within 30 days, leave the account in status 14 and continue normal billing procedures.

) For various E&G campus termination issues, reference the following termination IF/THEN Table.

Submit copies of 6335-F letters issued and related Forms 4768 to Advisory on any early termination. This documentation is needed to pursue collection on the account.

IRC 6166 cases are closed upon full payment, 14 years annual installment expiration and/or extension or default of the installment agreement.

Closed IRC 6166 files should be associated with the refile or controlling DLN on the Form 706 account using Form 10023-B. Before associating with the file, any documents not needed to maintain the IRC 6166 file such as CPs, IDRS TXMOD, BMFOL etc. prints should be removed. Folders should also be removed. The closed IRC 6166 files no longer need to be held one year before sending to Files. Associate as the IRC 6166 is closed.

Documents to be kept and associated with Form 706:

Lien packages are prepared for IRC 6166 and IRC 2032A.

Accepted Form 706 returns with either an IRC 2032A and/or IRC 6166 election are forwarded to E&G campus after classification. Elections for IRC 2032A are made in Part 3 of Form 706 page 2.

The following guidelines are for preparing Lien Packages for Advisory ETL group.

Verify the following:

Calculate recapture tax amount as follows: the total in Column C plus the Total Gross Estate less exclusion amount less the original amount of total transfer tax.

Prepare Form 6111, Notice of Special-Use Valuation Election, (IRC 2032A).

Prepare Memo to Advisory ETL group and attach the following documents:

Additional Information:

Final Actions:

International Accounts with Balance Owed: Closing letters cannot be issued to international accounts that have a balance due. The accounts must be monitored until the account is full paid. Once the account is paid, Letter 4944 along with the appropriate transfer certificates are issued. See IRM 4.25.2.5.11, Transfer Certificate Requests, for more information.

The balance owed can be from the original tax assessment or an audit assessment. All audited returns are forwarded to Centralized Case Processing (CCP) for closure. AIMS status 51/90 indicates the return is/was in CCP. Generally, CCP will forward international returns (Form 706 /Form 706-NA) to stop 824G for closing letter/transfer certificate action after they have completed their actions.

The examiner should verify if the account is full paid or has a balance due.

Full Paid Accounts:

Balance Due Accounts:

Monitoring Balance Due International Accounts: The International TTT will monitor 6F report quarterly for zero balance. If the account has a TC 608 indicating Collections has written off the balance due to pending or expired CSED:

If zero balance is due to a payment and there is no TC 420:

The processing of Form 706 by submission processing automatically generates a TC 420 on the account once the TC 150 posts. The generated TC 420 causes the system to generate the following:

Returns are established in EGC 1000. When the return posts and the TC 420 generates, the following activity codes are generated based on the size of the estate. Current activity codes are:

Activity codes 419, 431 and 433 are classified by the field Estate Tax Legal Specialists. Activity code 412, 413, 418, 424, 430 and 432 are classified in WSD. All international returns are classified by campus ETA.

SOI provides a list of returns selected for review to WSD and that is used to update AIMS to status 05 within 3 business days from receipt of list.

Form 706 estate tax returns are classified based on activity code as indicated in IRM 4.25.2.9.1(3), General Information. For additional information on classification see IRM 4.25.3, Planning, Classification, and Selection.

Some returns need additional work before classification can be completed. This includes:

Anything Classification related will come through *SBSE EEF E&G Campus Classification. Cases needing perfection are sent to Gateway Stop 824G and completed by TTTs. Stock valuations requested from the Field or Campus are completed by campus clerical support unless the volume is high and technicians at Gateway need to assist.

The following sections provide guidance for closing accepted as filed estate tax returns.

The following sections provide guidance for informant referrals and the turnaround response time for technical referrals.

Clerical: Sort documents using the following criteria:

Examiners: For cases meeting the criteria set in items a and c above, use the screening procedures below before referring to WSD.

Screening of Form 706-GS(D-1) when no return filed or a mismatch is identified:

Generation-Skipping Transfer Tax Rate: GST tax is calculated at the maximum rate for federal estate tax for the year of the Generation-Skipping transfer. See IRM 3.12.106.4.3.1(3), Maximum Tax Rates Table.

Forms that reflect≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡, send to Form 706-GS(D-1) Coordinator for tracking since taxpayers can have more than one form filed on their behalf. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

Forms that reflect ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡, assemble a case file with transcript and return:

Forms 706-GS(D-1) reflecting other than cash in column b: If a blank Form 706-GS(D-1) is received, send Letter 5666, F706-GS(D-1) Missing Information, to preparer.

If Return Filed:

If No return filed:

The following sections provide guidance for Form 3870 and resolving unpostables.