Internal Revenue Manual (IRM) 5.4.10, General Case Processing, contains procedures, guidance, and information for campus collection operations tax examining technicians. The content includes procedures for: adjustments, credit transfers, payment tracers, IRC 6020(b) processing, Collection Due Process (CDP), Forms 53 (Currently Not Collectible) and the processing of Forms 900 Tax Collection Waivers.

According to the Code and Regulations, the IRS has the authority to abate tax or any liability with respect thereof (which would include penalties and interest). Code: The IRS’s general abatement authority is found in IRC 6404(a). It provides:

IRC 6320 and 26 CFR 301.6320-1, the right to appeal the filing of a Notice of Federal Tax Lien.

IRC 6330 and 26 CFR 301.6330-1, the right to appeal before or after levy action is taken, depending on the type of levy.

IRC 7122(e),the right to appeal the IRS’s rejection of an installment agreement request.

IRC 6159(e), the right to appeal proposed modification or actual modification, and to appeal proposed termination or actual termination of an installment agreement , and Treas. Reg. Section 301.6159-1(e)(5).

Taxpayer Bill of Rights, IRC 7803(a)(3).

The IRS Restructuring and Reform Act of 1998 (IRS RRA 98), Section 3705(a),provides identification requirements for all IRS employees working tax related matters.

IRM 1.2.1.6.2, Policy Statement 5-2, Collecting Principles, describes principles that guide collection.

IRC 6020(a), Preparation of return by Secretary. If any person shall fail to make a return required by this title or by regulations prescribed thereunder, but shall consent to disclose all information necessary for the preparation thereof, then, and in that case, the Secretary may prepare such return, which, being signed by such person, may be received by the Secretary as the return of such person. (b) Execution of return by Secretary (1) Authority of Secretary to execute return If any person fails to make any return required by any internal revenue law or regulation made thereunder at the time prescribed therefor, or makes, willfully or otherwise, a false or fraudulent return, the Secretary shall make such return from their own knowledge and from such information as they can obtain through testimony or otherwise.

The Director, Collection Policy, is the executive responsible for the policies and procedures in this IRM.

The Operations Manager is responsible for managing campus collection activities including telephone, correspondence and systemic transactions, following the procedures in this IRM. They oversee department, team and employee responses to revenue officer requests, inquiries and responses concerning balances due.

The Department Manager is responsible for overseeing team and employee responses to revenue officer requests for processing and inquiries, along with responses concerning systemic transactions, following the procedures in this IRM. They oversee team and employee actions to resolve balance due accounts owed by taxpayers.

The Team Manager is responsible for overseeing employee responses to revenue officer requests for processing and inquires, along with responses concerning systemic transactions, following the procedures in this IRM. They oversee employee actions to resolve balance due accounts owed by taxpayers.

Employees who process balance due responses are responsible for responding to revenue officer requests for processing and inquiries, along with responses concerning systemic transactions, following the procedures in this IRM.

Program Reports: The following daily and weekly reports are generated by management, and can assist with evaluating the performance of the balance due program:

Program Effectiveness: The program results are housed on the Collection Program and Campus Reports SharePoint site in the Monthly Monitoring Report (MMR). The MMR captures NQRS results to show monthly and cumulative stats. Evaluative (EQRS) and national (NQRS) Quality reviews and consistency reviews are routinely conducted, along with Headquarters reviews to ensure case actions are timely and in accordance with the procedures in this IRM.

Managers are required to follow program management procedures and controls addressed in:

Managers conduct workload reviews to ensure compliance with this IRM.

The department and operations managers perform operational reviews annually to evaluate program delivery, conformance to administrative requirements and ensure compliance with this IRM.

Headquarters Collection, Collection Policy, Campus Policy and Collection Campus Operations conduct program reviews as necessary to verify compliance with IRM requirements, address TIGTA/GAO findings, and address any trends that appear.

ENTITY is the Workload Management System (WMS) used by Collection managers to extract and organize information about case activity and casework quality from ICS.

Employees must ensure that revenue officer requests for Adjustments, Credit Transfers and payment tracers are submitted in accordance with IRM 5.1.15, Abatements, Reconsiderations and Adjustments.

Employees must ensure that revenue officer requests for Mandatory 53 Follow-up actions, are submitted in accordance with IRM 5.16.1.6, Mandatory Follow-Up.

Employees must ensure that revenue officer requests for 6020(b) processing, are in accordance with IRM 5.1.11.7.7, IRC 6020(b) Authority.

Integrated Data Retrieval System (IDRS) programming ensures that all revenue officer requests for terminal input are consistent with current account balances and status indicators.

The table below is a list of common abbreviations, definitions and acronyms used throughout this IRM:

Here is a listing of some helpful IRM resources:

All misrouted cases received from Field Collection with original documents should be returned to the originator. Send an email with a CC to the originator’s manager informing the originator that the case is not CCP criteria if the case is received through the email boxes or if the case is received with no original documents. Below is a list of adjustments that CCP is not authorized to process and how to identify them.

Combined Annual Wage Reporting (CAWR) adjustments can be identified as listed below:

Federal Unemployment Tax Act (FUTA) tax assessment can be identified by an additional tax with TC 290 on either MFT 10 (Form 940) or MFT 30 (Schedule H, Form 1040) with numbers 50 or 51 in digits 9 and 10 of the DLN. CCP cannot process an adjustment requesting the abatement of the additional tax. See IRM 5.1.15.8, Federal Unemployment Tax Act (FUTA) Tax Adjustments.

Audit Reconsideration adjustments can be identified on TXMOD by Transaction Code (TC ) 420, (audit) followed by a TC 300 with an amount. See IRM 5.1.15.4.1, Audit Reconsiderations.

Automated /Substitute For Return (A/SFR) adjustments can be identified by the following:

Tax Exempt/Government Entities (TE/GE), of which some of the most common TE/GE forms are listed in the table below:

Trust Fund Recovery Penalty (TFRP) adjustments can be identified by MFT 55 with TC 240 and Penalty Reference Numbers (PRN) 618, 699 or 697. A TC 538 on MFT 01/03/09/11/12 tax modules also indicates TFRP assessment. See IRM 5.7.7.5, Abatements and Adjustments of a TFRP.

Excise Tax adjustments, See IRM 5.4.10.3.2 and IRM 4.24.1, Excise Tax - Introduction to Excise Taxes.

Estate Tax Return adjustments includes Form 706 returns and are processed under MFT 52 or 53 on IDRS. See IRM 5.5.3, Working Decedent Cases.

Identity Theft adjustments and related transaction are not processed by CCP. Refer to IRM 5.1.15.13, Identity Theft.

CCP receives two types of requests that meet rejection criteria:

An incomplete request is one that cannot be processed without securing missing/incomplete information. (See 5 below for more information about incomplete requests).

An invalid request is one that cannot be processed due to the nature of the request. CCP cannot take the action that is being requested. Unlike incomplete requests, these requests cannot be processed by securing additional information.

For invalid requests:

The Integrated Collection System (ICS) should be reviewed for missing or incomplete explanations. If the information cannot be obtained from ICS, contact the originator for the missing data. Write a brief history in ICS explaining reason for access.

Tax examiner internal forwarding procedures:

Lead tax examiner daily suspense file review procedures:

Insert signature.

Insert DO NOT RESPOND TO THIS EMAIL.

Inform assigned tax examiner that the Reject Action has been completed.

Research adjustment, payment tracer and credit transfer requests meeting CCP criteria on IDRS using Command Code (CC) SUMRY/TXMOD prior to input:

Always open and close a control on the module or ENMOD using command code ACTON when adjusting accounts. Leave a history of the action taken

When processing a request that cannot be closed immediately, change the status "A" to status "S" using ACTON. See IRM 2.3.12.2, Case Control Using Command Code ACTON.

Review IDRS to determine if the adjustment will result in a refund or credit where the Refund Statute Expiration Date (RSED) has expired. See IRM 25.6.1.5, Basic Guide for Processing Cases with Statute of Limitations Issues.

When transferring payments or overpayments as a result of an adjustment, the RSED must be taken into consideration. If the RSED has expired the money cannot be transferred to another module. The money must be moved to Excess Collection.

If the Assessment Statute Expiration Date (ASED) has expired, do not process the assessment. When a legal tax assessment is not made timely within the prescribed period for assessment (Assessment Statute Expiration Date) (ASED), it is considered a "Barred Assessment." See IRM 25.6.1.13, Barred Assessments/Barred Statute Cases and IRM 21.5.3.4.1, Tax Increase or Credit Decrease Processing.

An abatement may be made before or after the ASED; however, the tax cannot be reassessed if it is determined that the tax decrease was erroneous after the ASED has expired. An erroneous abatement is an abatement of tax that is later determined to have been made in error. See IRM 25.6.1.10.2, Erroneous Abatement.

Thoroughly review IRM 25.6.1.5, Basic Guide for Processing Cases with Statute of Limitations Issues, before processing an adjustment if the RSED or ASED has less than six months remaining.

If the RSED has expired on the payments or credits, reject the case back to the originator following the CCP Rejection Procedures. See IRM 5.4.10.2.2 above.

Form 3870 can also be received to process a return made under IRC 6020(b) when a disregarded entity LLC fails to file employment tax returns for tax periods ended before January 1, 2009, and the liable single member owner (SMO) has previously filed an employment tax return for the same tax period for another business. Process the return made under IRC 6020(b) on Form 3870, Request for Adjustment, as a supplemental tax assessment. Ensure that an additional assessment is not prohibited by an ASED. See IRM 5.4.10.6.2 below and IRM 5.1.11.7.7.4 , Preparing Returns for Assessment, and IRM 5.1.15.6.1, Limited Liability Company (LLC) IRC 6020(b) Adjustments.

Process abatement requests on LLCs following normal procedures.

CCP will receive requests to abate Personal Liability Assessments for Excise Taxes on a Form 3870 along with a revised Form 9494, Request For Assessment of Personal Liability For Excise Tax, page 3, from Advisory revenue officers, which should be forwarded as Source Documents.

Advisors must also forward a memorandum of authority to request reversal of a prior adjustment made on the assessment which must be approved by the group manager.

The Form 3870 will request abatement of either TC 150 or TC 290 on MFT 03. If the Form indicates MFT 45, the request must be sent to the Non-Master File Unit.

Forward request to CCP-FORT.

RCA provides a decision support system accessible via Accounts Management Services (AMS) to make penalty abatement determinations using a series of questions that lead the user to a consistent conclusion while ensuring the appropriate factors are addressed. When necessary, RCA systemically generates a letter after the abatement is completed by CCP. See IRM 5.1.15.16.1, Reasonable Cause Assistant (RCA), for a list of letters.

Revenue officers (ROs)are required to use RCA when the taxpayer requests relief of certain penalties due to reasonable cause. RCA should be used for the following penalties:

CCP will accept Form 3870 requests for reasonable cause abatements on the following types of cases:

If Form 3870 is received requesting abatements for the penalties listed in (2) above for reasons other than those listed in (3), contact the RO using the narrative below: "On (MM-DD-YYYY) a Form 3870 was submitted requesting to have a penalty abatement input on (TIN/MFT/TAX PERIOD). This request needs to be submitted through the Reasonable Cause Assistant (RCA) system. RCA use is required for IMF FTF and FTP and BMF FTD penalties per IRM 20.1.1.3.6, Reasonable Cause Assistant (RCA) and IRM 5.1.15.16.1, Reasonable Cause Assistant (RCA). Since your request was not submitted using the RCA system your request is being closed. In order to have this request processed it will be necessary to resubmit using RCA through AMS. For more information you can refer to catalog number 557142. If you have any problems, questions or concerns please send them to *SBSE.RCA.HELP@irs.gov."

Adjustment requests received in CCP involving the following issues MUST be referred to the appropriate area;

Route adjustments to reverse offsets on Debtor Master File (DMF) and Treasury Offset Program (TOP) Offsets to the FORT.

The instructions in (2) below are specific to CCP processing of IRC 6020(b) adjustments submitted by Field Collection (FC) revenue officers. The following instructions will result in the ASED field being populated on TXMOD when a return is secured by FC in conjunction with a IRC 6020(b) assessment.

Process the adjustment to 6020(b) assessments as follows:

When a disregarded entity Limited Liability Company (LLC) fails to file employment tax returns for tax periods ending before January 1, 2009, prepare an IRC 6020(b) return. Although the single member owner (SMO) may file employment tax returns for these tax periods in the name and EIN of the SMO or the name and EIN of the LLC, the IRC 6020(b) return must be prepared in the name and EIN of the liable party, the SMO. If the SMO has previously filed an employment tax return for another business under the SMO EIN for the same tax period, then the return prepared under IRC 6020(b) should not be submitted to Submission Processing as a secured return. The return prepared under IRC 6020(b) will be processed on Form 3870 as a supplemental tax assessment. Review ASED before processing the additional assessment.

The revenue officer will submit Form 3870 to CCP using the name and EIN of the SMO with the following statement in the Reason for Adjustment section of the form: "This liability resulted from the operation of (Name and EIN of LLC), for which (Name of Single Member Owner) was liable as the employer, it should be added to the original assessment as a supplemental assessment."

Notate the name and EIN of the LLC in the IDRS history on the module.

Follow normal procedures to process an abatement request on an LLC/SMO.

Form 53 sent to CCP for manual input of the TC 530 CC XX will be received from Field Collection on various forms, such as, Form 53, Currently not Collectible; Form 3177, Notice of Action for Entry on Master File; and Form 4844, Request for Terminal Action. The information required includes the tax period(s) MFT and the closing code. The Form 53 should be annotated "Assessed" .

Parts 2 and 3 of Form 53 completed on ICS will be transmitted to CCP via a systemically generated email after approval of the CNC by the group manager. TC 530 cc XX will systemically upload from ICS to IDRS command code TXMOD, within 1-3 days of the group manager’s approval. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡.

Paper Form 53 requests require manager approval by the immediate manager of the revenue officer. Return unapproved requests to the revenue officer. See IRM 5.16.1.5, Managerial Approval.

See IRM 5.16.1.2.5, Tolerance, for tolerance accounts being closed with TC 530 cc 09 and cc 19 that do not require managerial approval.

ICS systemically uploads TC 530 cc XX on TXMOD upon the group manager’s approval. Utilize the If/Then table below when processing parts 2 and/or 3 of Form 53. TXMODA research or input is not required during processing:

For all other Currently Not Collectible (CNC) requests (i.e. F4844, manual F53), ensure that TC 530 with the appropriate closing code is input on IDRS CC TXMODA, as requested on the applicable form. If requested, input TC 130 and update filing requirements.

Do not input TC 530 cc XX if TC 150 has not yet posted. Refer to IRM 5.4.10.7.3, Processing of Pre-Assessed Form 53.

When Form 2363, Master File Entity Change, is attached, input the new address and/or Area Office Location code using CC ENREQ

When the account is reported CNC, CCP must use one of the following values for Responsibility Unit Code (RUC) or Jurisdiction Code when using Command Code (CC) FRM77 input on CNC accounts.

The Form 53 request for input of a TC 530 on an un-assessed or pre-assessed module occurs when a taxpayer is determined to be CNC and tax period(s) have an assessment that has not posted to IDRS. CCP monitors the tax period(s) for the posting of the TC 150 and immediately inputs the TC 530 on IDRS using CC REQ77 to avoid collection activity against the taxpayer.

Form 53s sent to CCP for input of the TC 530 cc XX on un-assessed modules will be received from the FC on various forms, such as Form 53, Currently Not Collectible; Form 3177, Notice of Action for Entry on Master File; and Form 4844, Request for Terminal Action. The information required includes the tax period(s), MFT and the closing code. The Form 53 should be annotated "Pre-Assessed" .

Ensure that proper approvals have been secured prior to input of a CNC request. Return unapproved requests to the revenue officer. See IRM 5.16.1.5, Managerial Approval.

Revenue officers request mandatory follow-ups if there is evidence that the taxpayer's ability to pay will improve and either computer-generated reactivation is not available or the improvement will happen significantly sooner than systemic reactivation can occur. The RO creates a systemic Non-Field Other Investigation (NF- OI) "101-Mandatory 53" and the ICS case is systemically assigned to CCP for monitoring.

Cases not processed on ICS, should contain the specific follow-up actions and the date required in the Mandatory Follow-up Action section of Form 53 (or equivalent) in sufficient detail to ensure appropriate follow-up. Also, information in the case history should permit review of the follow-up action after part 4 of Form 53 is detached. As each follow-up action is completed, update part 4 to show the date of the next follow-up.

A mandatory follow-up should not be requested in the following instances:

Accounts may be reported CNC using cc 13 when an operating (in business) corporation, exempt organization, or limited partnership cannot pay its back taxes and enforcement cannot be taken because the business has no distrainable accounts receivable or other receipts or equity in assets. These cases are sometimes referred to as "In-Business 53s."

Closing code 13 may also be used for Limited Liability Corporation (LLC) cases (where the LLC is identified as the liable taxpayer), when an operating business cannot pay its back taxes and enforcement cannot be taken because the LLC has no distrainable income or equity in assets.

Refer to IRM 5.16.1.6, Mandatory Follow-Up , and IRM 5.16.1.2.7, In-Business Corporations, Exempt Organizations, Limited Partnerships, or Limited Liability Companies for additional information.

Input a TC 550 using REQ77.

Input "1" for the Trans-Register-Ind.

Input new requested CSED for the extension date.

Input correct CSED code in the CSED-CD area. No alpha code is needed for Civil Penalty/BMF.

Input predetermined Definer Code for the 550 Definer-CD.

In the Remarks area, type "The delegated representative’s name per Form 900 Waiver with IA" .

Date and initial back of Part 3 (input copy) of 900 Waiver and send for review.

After input of an extended CSED, a review must be performed to ensure:

After input, Part 1 of Form 900 (the original) will be kept in an accessible file in CCP for three years beyond the latest date to which CSEDs were extended. IRC 6511(a) provides the right to make claims for refunds within 2 years from when taxes are paid or 3 years from when the return was filed, whichever period expires later

Part 3 of the Form 900 will be attached to the related partial payment installment agreements (PPIA).