PCS was created to monitor and control pass-through entity investors. Pass-through entities can have many partners and many levels of tiering. Tiering occurs when an investor in a pass-through entity is also a pass-through entity. This complexity can make it difficult to keep track of statutes and monitor all the investors.

PCS control is a policy that was established in response to the partnership provisions of the Tax Equity and Fiscal Responsibility Act (TEFRA) of 1982. It has been expanded to cover other pass-through entities that fall outside of TEFRA.

The Director, SB/SE, Headquarters, Examination Field and Campus Policy (SE:S:E:HQ:EFCP) is responsible for:

The SB/SE Program Manager, Examination Field and Campus Policy, Campus Exam & Field Support (SE:S:E:HQ:EFCP:CEFS) is responsible for:

Field Territory Managers, Field Area Directors, Director over LB&I Ogden and Director, Examination - Brookhaven, are responsible for ensuring that:

Area office Examination Managers and campus Field Support Operations managers are responsible for:

The campus PCS Coordinator works with:

The campus PCS Coordinator is charged with:

Following are specific campus PCS Coordinator responsibilities:

Program Reports: PCS generates a variety of reports used to monitor the inventory and related statutes. These reports are explained in detail in IRM 4.29.4.

Program Effectiveness: PCS is used to help identify the effectiveness of the CPF program. PCS shows the number of investors linked within a pass-through structure. Failing to link partner returns timely can result in barred statutes or the need to follow burdensome procedures such as manual assessments or untimely notice procedures.

PCS is a Integrated Data Retrieval System (IDRS) based system. Access to command codes are restricted based upon need. For example, generally only the PCS Coordinator is allowed to delete records from the system.

There are several terms unique to PCS. Examples of these words:

See IRM Exhibit 4.29.1-1 for a list of acronyms.

The following IRM cross references may be helpful to PCS coordinators:

The following three reports are national directories:

Reports 22-1 and 22-2 are produced monthly on Control-D. Report 22-3 is a printed report.

Report 22-1, produced monthly, lists key case records in Taxpayer Identification Number (TIN) order with linked investor records in TIN order grouped by PBC.

The report reflects open key case records and closed key case records which have at least one open linked investor record. Open key cases are in a status code below 80. Closed key cases are in a status code 80 or above.

Following the TIN sequence listing, an alpha listing of key cases is provided. This allows research by DBA name if the key case TIN is not available.

The report is a research tool providing a history of the key case and linked investors.

All microfiche must be retained for 30 years. The CD-ROMs must also be kept for thirty years, but recopied every five to seven years. Special procedures must be followed when disposing of microfiche. Please contact the Headquarters TEFRA analyst or the Records Officer prior to disposing of those records.

Beginning in January 2016 this report is printed and stored on Control-D. CDs are no longer produced.

Report 22-2, produced monthly, lists key cases with linked investor records in promoter number TIN sequence. It is used for research; it provides a history of key cases and investors within a promotion.

The report reflects open key case records and closed key case records which have at least one open linked investor record. Open key cases are in a status code below 80; closed key cases are in a status code 80 or above.

All microfiche must be retained for 30 years. The CD-ROMs must also be kept for thirty years, but recopied every five to seven years. Special procedures must be followed when disposing of microfiche. Please contact the Headquarters TEFRA analyst or the Records Officer prior to disposing of those records.

Report 22-3 lists key case records with all linked investors. Field reports reflect ILSC key cases and their linked investors. CPF reports reflect TEFRA key cases within the campus's jurisdiction and their linked investors.

The report includes investor records in a TC424 status. They are indicated by an asterisk to the left of the investor sequence number. One asterisk indicates the record has been in a TC424 status for one month. Two asterisks indicate two months or more.

The report is generated weekly if at least one investor is a skeletal record. The AIMS 424 Reject Register should be worked with this report. The reject code, listed in IRM 4.4, AIMS/Processing Handbook, identifies the reason for the reject. Research the record, correct the reject condition, and establish the investor in full display.

This report is used to identify investors with incorrect CPF PBCs. For example, there should be no cases in PBC 295 appearing on Ogden's report, or PBC 398 cases on the Brookhaven report. When cases like this are seen, the CTF Indicator needs to be corrected.

The following five reports are database maintenance reports:

During centralized processing at MCC, PCS data is input in the database in date and time order of input. An input can be accepted during real-time but rejected during centralized processing if the accessed record is no longer on the Partnership Investor Control File (PICF).

Report 1-1 notifies the key case field office or CPF of inputs rejected during centralized processing. A literal reject message appears on the report. Literal reject messages are shown in Exhibit 4.29.4-2, Error Register Reject Literals. The command code originally input, as well as pertinent key case and investor information, is included on the error register.

This error register should be analyzed when received by the PCS Coordinator to ensure that corrected inputs are made. No action is needed for CC TSCLS rejects.

Retain the report until the next report is received

Report 7-3, Deleted Investors, lists investor records dropped from PCS when the only key case linkage has been deleted. The key case linkage is identified on the report to assist contacting the key case field office or CPF.

The report gives the reason the investor record dropped from the PCS:

The report lists all linkage records that were present when the investor record dropped.

The investor record and key case record are displayed in the following format:

Investor records dropped from the PCS are printed on Report 7-3 only once. They do not repeat on subsequent weekly reports. AIMS records are not affected when the record drops from the PCS.

The investor field function or CPF must determine whether to re-control the case on the PCS, close the case on AIMS, or leave the case controlled on AIMS, but not on the PCS.

Retain this report for three months.

The PCS generates four reports that show information about the PCS cases with pending statute of limitation dates. The PCS only provides statute reports with regard to TEFRA one-year assessment statute dates. Fields and CPFs must also utilize AIMS Tables 4.1 and 4.0 to ensure statute dates are protected on all assigned cases.

Report 2-2 provides a count of records with a one-year assessment statute date on the investor record. Criteria for items excluded from the report are provided below.

Report 4-4 lists all records on the PCS with a one-year assessment statute date on the investor record.

Report 5-5 provides a list of key cases within an CPF’s jurisdiction that are in status 90 and have linked investors without a one-year assessment statute date.

Report 2-2 is a count of TEFRA investor records with a pending one-year assessment statute date.

Report 2-2 reflects pending one-year assessment statute records by month for the current month and the following 14 months. Each area in the CPF’s jurisdiction is displayed with a breakdown between records in status code 34 and records in a status code other than 34.

The report does not include investor records that have "11111111" entered in the one-year assessment statute date field.

The CPF should use the report to determine volume of pending one-year date cases requiring action and for required staffing.

Report 4-4 lists all CPF investor records that have a TEFRA one-year assessment statute date present on a linkage record. Key case information for linkage records with a one-year date present is displayed to the right of the investor record information.

The CPFs must ensure reports are written and tax, penalty, and interest are processed prior to the expiration of the one-year assessment statute date.

Investor records with an entry of A, B, C, M, R, or S in the package received indicator field are listed on separate report pages. See IRM Exhibit 4.29.3-3, Report Package Received Indicator Codes, for the meaning of these codes. Records with MFT code 34 are also listed on separate report pages. All other IMF investors are listed separately from all other BMF investors.

Investor records added to Report 4-4 within the prior three PCS cycles are identified by the literal "NEW" to the extreme right of the report. Records identified as "NEW" are listed at the beginning of each separate sort for the report.

The "NEW" investor records are listed in one-year assessment date order followed by all other investor records in one-year assessment statute date order. If an investor has multiple linkages with a one-year date present, the investor and all linkages with a one-year date will be listed on the report by the earliest one-year date.

An entry of "Y" in the Report Package Received Indicator field signifies that the investor report writing package was received. Follow-up action must be taken to secure packages that have not been received.

TEFRA investor records, with the TEFRA assessment already processed, appear on this report with a "11111111" one-year assessment statute date. The one-year assessment statute date field MUST NOT be deleted when the TEFRA assessment is made. If it is deleted the investor record reappears on this report as a new investor requiring action, when a mass change update takes place after the assessment is made.

When the TEFRA assessment is made, the one year assessment statute date must be updated to "11111111" .

If there is an unagreed penalty or affected item issue, the one-year assessment statute date must be updated to the six digit numeric date followed by “P” (YYYYMMDDP) with CC TSCHG. The one-year date for the penalty or affected item issue will be updated to "11111111" when the penalty or affected item is assessed.

One-year assessment statute dates that have been updated to "11111111" for investors linked to a tier with multiple key case linkages, will be removed from the linkage record with an entry of "T" in item 05 of CC TSCHG.

Report 5-5 lists key cases that are in status 90 that have linked investors without a one-year assessment date.

The key case CPF will use this report in conjunction with Report 21-3, TEFRA Key Case Action Report, for the Campus CPF, to ensure timely receipt of incoming packages.

The key case CPF must input one-year assessment statute dates on each linked investor when there is sufficient information in the key case administrative file to determine the correct date.

The key case CPF must coordinate with the key case field office when there is insufficient information:

Retain this report for two years. It will be reviewed by the National Headquarters Office when the CPF is on the visitation schedule. In general, no local jurisdiction investor, other than an investor in Appeals or the courts, should cause a local key case to appear on this report.

Report 5-5(N) lists ILSC key cases that are in status 90 that have linked investors without a report package received indicator date.

The key case CPF must input the report package received indicator code on each linked investor when a report is received.

The key case CPF must coordinate with the key case field office when a package cannot be located:

Retain this report for two years. It will be reviewed by the National Headquarters Office when the CPF is on the visitation schedule.

Report 5-5 lists Appeals key cases that are in status 90 that have linked investors without a one-year assessment date.

The key case CPF will use this report in conjunction with Report 21-3, TEFRA Key Case Action Report, for the Campus CPF, to ensure timely receipt of incoming packages.

The key case CPF must input one-year assessment statute dates on each linked investor when there is sufficient information in the key case administrative file to determine the correct date.

The key case CPF must coordinate with the key case Appeals office when there is insufficient information:

Retain this report for two years. It will be reviewed by the National Headquarters Office when the CPF is on the visitation schedule. In general, no local jurisdiction investor, other than an investor in Appeals or the courts, should cause a local key case to appear on this report.

The following reports are action reports:

All action reports should be retained for three months.

Report 21-3 lists TEFRA key cases, by Primary Business code within the campuses jurisdiction, when the TEFRA key case record enters status code 27, 28, 29, or 80 and above for the first time. This gives the CPF an alert that key case adjustments have been finalized and will be moving into the notice phase.

The date the FPAA was issued to the TMP is displayed to determine the date by which all investor FPAAs must be issued. Investor FPAAs must be issued within 60 days of the date the FPAA was mailed to the TMP.

The key case administrative file will be reviewed to determine if the necessary documentation was received from the field office, or if follow up is needed.

Verify that all investors had a proper closing action as follows:

Retain this report for three months.

Report 21-3(N) lists ILSC key cases, by Primary Business code within the campuses jurisdiction, when the ILSC key case record enters status code 27, 28, 29, or 80 and above for the first time. This gives the CPF an alert that key case adjustments have been finalized and will be moving into the notice phase.

The key case administrative file will be reviewed to determine if the necessary documentation was received from the field office, or if follow up is needed.

Retain this report for three months.

All key cases whose TEFRA indicator was changed using CC TSCHG or CC MSCHG during the previous three weeks are listed with their linked investors.

Key case and investor campuses use this report to ensure that returns are properly controlled and that administrative files accurately reflect return status.

Key case CPFs should verify that the change to the key case TEFRA indicator is correct.

Retain this report for three months.

This report identifies returns in status 34, employee group code 58XX, to which an ILSC linkage has been added within the last three weeks.

Returns listed on this report should be forwarded to ILSC suspense.

An asterisk (*) identifies the new ILSC linkage which was added.

Retain this report for three months.

This report is a listing, for the key case CPF, of investors that match AIMS weekly updates for bankruptcy, Criminal Investigation, Disaster Related, Combat Zone, and potentially dangerous taxpayer (PDT) transactions.

The report should be associated with the key case administrative file and appropriate action taken:

The investor CPF receives the AIMS Weekly Update Report with these messages.

Retain this report for three months.

The report will list the key cases that have transferred into the CPF during the given week. The report will list cases transferred in from the field, Appeals or another campus. This listing will afford the CPF notice that a key case has been transferred to them.

The report list tiers with an "X" tier indicator. A decision was made by the CPF not to link the partners of these tiers because a material adjustment is unlikely.

This report lists tier partnerships that have not been perfected. An unperfected tier is one that does not have a tier indicator of "#" or "X" . The CPF should work this report timely to ensure that all tiers partners are linked, or determine that the tier should be a 'no-load'. These unperfected partnerships must be perfected on the system to maintain adequate control of inventory.

The bypassed records count is a count of records whose LN-PN-TEFRA-CD is not a space (i.e., a TEFRA case) or if the PBC-PTR field is not equal to 700.

The valid records count are those records whose PBC-PTR field doesn’t equal 700 (any invalid PBC), and if (the TEFRA-ASSMT-RPT-DATE is greater than or equal to the PREVIOUS-DAY) or (the TEFRA-ASSMT-RPT-DATE is less than or equal to the CURRENT-DAY).

The error count is those records whose PBC and service center code are not a valid combination.

The bypassed records count includes those records whose LN-1-YR-ASSMT-DATE has either spaces or zeroes as values. It also includes those records whose ASSESSMENT-DATE is more than 998 days in the past.

The valid records count are those records whose BOD-PBC doesn’t contain certain values (398, 301-309, 315-317 or 298) and the APPL-BOD and PN-CTF-IND are "O" . Records whose PBC contains other values (295, 201-207, 212-214) and the APPL-BOD and PN-CTF-IND are "B" .

The error count is those records whose PN-CTF-IND is not either "B" or "O" (Brookhaven or Ogden).

The bypassed records count include those records whose LN-PN-TEFRA-CD is not "T" (i.e., an ILSC case). Also included in the count are those records whose pass-through record key (PS-KEY) is not the same as the previous record’s PS-KEY. Those records which do not meet the criteria for a valid record (see below) are also added to the bypassed count.

The valid records count are those records whose PBC-PTR field doesn’t equal 700 (any invalid PBC), and if (the TEFRA-ASSMT-RPT-DATE is greater than or equal to the PREVIOUS-DAY) or (the TEFRA-ASSMT-RPT-DATE is less than or equal to the CURRENT-DAY).

The error count includes those records whose PBC are not found in a table and the PS record’s key is not the same as the previous PS record.

The bypassed count are those records which do not meet the valid record criteria (see below).

The valid records count are those records where (the TEFRA-ASSMT-RPT-DATE is greater than or equal to the PREVIOUS-DAY) or (the TEFRA-ASSMT-RPT-DATE is less than or equal to the CURRENT-DAY).

The error count includes those records whose PBC are not found in a table.

The bypassed records count are those records which do not meet the valid record criteria below.

The valid records counts include ILSC cases (the LN-PN-TEFRA-CD not equal to "T" ). Also included are those records whose PBC-PTR field doesn’t equal 700 (any invalid PBC), and if (the TEFRA-ASSMT-RPT-DATE is greater than or equal to the PREVIOUS-DAY) or (the TEFRA-ASSMT-RPT-DATE is less than or equal to the CURRENT-DAY).

The error count includes those records whose PBC are not found in a table.

The run control file lists those records whose TICKLER-PS-KEY is less than the PS-KEY.