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25.15.7  Compliance Campus Functions

25.15.7.1  (09-01-2006)
Overview

  1. Processing of Requests for Relief from Joint and Several Liability is centralized at the Cincinnati IRS Campus known as the Cincinnati Centralized Innocent Spouse Operation (CCISO) of the Andover IRS Campus. In this section they will be referred to as CCISO.

25.15.7.2  (03-21-2008)
General Procedures

  1. This section includes instructions for Compliance Campus and Field functions. The functions are Innocent Spouse, Exam Correspondence, Automated Underreporter, Taxpayer Advocate Service (TAS), Field Collection, Field Examination, Appeals, and Customer Service Representatives.

  2. General procedures for all functions can be in found in IRM 25.15.1 and IRM 25.15.2.

  3. Technical procedures about IRC 6015 can be found in IRM 25.15.3.

  4. Technical procedures about IRC 66(c) can be found in IRM 25.15.5.

  5. Field Examination procedures can be found in IRM 25.15.6.

  6. Compliance Campus Functions procedures can be found in this IRM.

  7. Field Collection procedures can be found in IRM 25.15.8.

  8. Processing procedures can be found in IRM 25.15.9 .

  9. Cincinnati Innocent Spouse Case Review (CISCR) procedures can be found in IRM 21.10. Field Exam Review procedures can be found in IRM 25.10.

  10. TAS procedures can be found in IRM 25.15.11.

  11. Appeals procedures can be found in IRM 25.15.12 .

  12. Innocent Spouse Tracking System (ISTS) procedures can be found in IRM 25.15.14.

  13. Mirroring Modules procedures can be found in IRM 25.15.15.

  14. Telephone procedures can be found in IRM 25.15.16 .

  15. Reconsideration procedures can be found in IRM 25.15.17

25.15.7.2.1  (03-21-2008)
Addressing Letters to the Taxpayer

  1. When the taxpayer’s last name has changed from the name on the originally filed return for which relief is being requested, address the letter to the name as it appeared on the return, and enter AKA (also known as) and the current name.

    Note:

    An indication the taxpayer's last name has changed would be if the taxpayer's signature shows a new last name.

    Caution:

    Be sure you do not disclose the new name to the nonrequesting spouse (NRS).

  2. Verify the address on the letter with the address on the Form 8857. If the address is different, determine which address is more current, the one on IDRS Command Code ENMOD, INOLE, or Form 8857. If the Form 8857 address is more current, input an address change for the RS.

    Note:

    During the mirroring process some of the RS's addresses are updating to the NRS's address on the joint return. Therefore it is imperative to verify the address before sending the letter.

    Caution:

    Do not input an address change for the NRS based on Form 8857 unless the NRS provides a new address.

  3. When the taxpayer is deceased and you do not know if there is an estate, address the letter to the estate of the taxpayer. On the first name line input "Estate of ...." No second name line is required.

25.15.7.2.2  (09-01-2006)
Receipt of Innocent Spouse Claim from Revenue Officer

  1. If Form 3449, Referral Report, is received, provide updates every 30 days to the revenue officer. If no Form 3449 is received but there is an indication that the revenue officer wants to be kept apprised, provide update every 30 days.

25.15.7.3  (03-21-2008)
Identifying Automated Underreporter or Correspondence Examination (SCEB) Cases

  1. AUR cases are identified by:

    1. TC 922 with processing codes (PC) on TXMOD. The PC listed last beneath TC 922 indicates the current status of the case. Refer to the AUR processing codes in Document 6209, IRS Processing Codes and Information for the definitions of the PC.

    2. Additional assessments will be indicated by a TC 290.

      Note:

      AUR cases will not be mirrored or sent to the Processing Team unless there is also an underpayment issue that requires processing.

  2. SCEB cases are identified by:

    • TC 420 on TXMOD. Check Integrated Data Retrieval System IDRS Command Code (CC) AMDISA to determine the status of the case. Refer to the AIMS Status Codes in Document 6209 for the definition of each code

    • Additional assessments will be identified by a TC 300

25.15.7.4  (03-21-2008)
AUR or SCEB Cases - Overview

  1. Taxpayers must be notified of their rights when IRS proposes an additional assessment. Publication 1 , enclosed with most correspondence related to proposed tax increases, informs taxpayers of their right to file a Request for Relief from Joint and Several Liability. Requests for relief are made on Form 8857, Innocent Spouse Relief. Also, a requesting spouse (RS) may submit a written statement containing the same information required on Form 8857, and it must be signed under penalties of perjury. Publication 971 explains this relief in detail.

  2. If an innocent spouse claim is received on an open AUR/SCEB case, the Compliance Campus and CCISO will coordinate:

    1. AUR/SCEB is responsible for all issues except innocent spouse. AUR/SCEB will also be responsible for coordinating final case processing including issuance of a Statutory Notice of Deficiency (SND), account processing and appropriate Innocent Spouse Tracking System (ISTS) inputs, See IRM 25.15.7.4.1.

    2. CCISO is responsible for making the innocent spouse determination, notifying the NRS, sending determination letter(s), and providing AUR/SCEB with instructions on case closing (i.e. forward case to Appeals, language for Notice, etc.).

  3. Procedures differ depending on whether a "90 day letter" (SND) has been issued and whether the RS or NRS has requested an Appeals conference.

  4. Each Compliance Campus has an Innocent Spouse Coordinator available to assist with innocent spouse questions. A listing of these coordinators can be found on the innocent spouse website. See LEM 25.15.1.6 for the website address.

25.15.7.4.1  (03-21-2008)
Form 8857 Received by Compliance Campus

  1. Upon receipt of the Innocent Spouse claim, AUR/SCEB will:

    1. Date stamp the Form 8857 with AUR/SCEB received date.

    2. Acknowledge receipt of the claim using IDRS Letter 2645C. Use the CCISO innocent spouse AUR/SCEB coordinator as the contact.

    3. Control on ISTS using IDRS command code ISTSR. See IRM 25.15.14.2 for information on ISTS.

      What to Enter on ISTS:
      Stage 01 with the earliest IRS received date stamped on Form 8857 or the metered date stamp on the envelope; whichever is the earliest. If no IRS received date on Form 8857 or to determine if the claim was timely filed, go to the envelope to see if there is a postmark date. If there is, enter the date on the envelope. This indicates receipt of the Innocent Spouse claim. See IRM 3.10.72.9, Campus Mail and Work Control , for rules on received date.
      Stage 02 - TOAREA 296. This indicates the Innocent Spouse claim has been sent to CCISO.

      Note:

      Upon receipt of the transferred case, CCISO will follow normal ISTS inputs.

    4. Fax Form 8857 and any correspondence regarding Form 8857 within 10 business days to CCISO at (859) 669-5256, Attn: Innocent Spouse AUR/SCEB Coordinator.

      Note:

      If too large to fax, mail within 10 business days.

  2. The CCISO Innocent Spouse Coordinator will be available to help if necessary.

  3. CCISO will:

    1. Date stamp the faxed copy of Form 8857.

    2. Acknowledge receipt of the faxed claim via secure e-mail to the appropriate IRC § 6015 coordinator.

    3. Screen and consider the claim.

25.15.7.4.2  (03-21-2008)
AUR/SCEB 30 Day Period (CP2000 or Letter 565 Issued).

  1. If an innocent spouse claim is received during the 30 day period or before a Statutory Notice of Deficiency (SND) is issued, the following general procedures will be followed:

    AUR SCEB CCISO
    Suspend case by inputting the appropriate action to stop the automated system from generating SND until notified of the final innocent spouse determination. Do not issue SND until notified of the final innocent spouse determination. Follow normal procedures for claims including First Read and notification to the NRS.
    Work AUR issues if additional correspondence is received from the taxpayer. Work audit issue if additional correspondence is received from the taxpayer.  
    Notify CCISO of any changes to the proposed deficiencies previously shared with CCISO. Notify CCISO of any changes to the proposed deficiencies previously shared with CCISO. Notify AUR/SCEB of any delay in making determination past 90 days.
    Research IDRS Command Code ISTSRA to determine the latest stage of Form 8857. If stage number is 01 through 04, initiate PC 75/letter. Contact CCISO to advise them you are issuing the SND. If stage number is 05 or higher, contact CCISO to determine if the SND should be issued. Research IDRS Command Code ISTSRA to determine the latest stage of Form 8857. If stage number is 01 through 04, continue processing. Contact CCISO to advise them you are issuing the SND. If stage number is 05 or higher, contact CCISO to determine if the SND should be issued. If the time to appeal an innocent spouse determination has not expired, advise AUR that a preliminary determination has been issued, and they must wait 45 days from that date before issuing SND.

  2. If AUR/SCEB determines there is no deficiency and the case is a "no change," follow the " no change" procedures. See IRM 25.15.7.4.4.

  3. If the taxpayer signs the proposed deficiency and the SND was not issued, treat as an underpayment.

25.15.7.4.2.1  (03-21-2008)
Innocent Spouse Determination Made Before Issuance of SND

  1. Determination to deny claim in full before issuance of SND — AUR/SCEB and CCISO will take the following actions:

    AUR/SCEB CCISO
    Take no action until notified by CCISO of the preliminary determination and the time to appeal has expired (45 days from the ISTS Stage 11 Stage Date). Issue preliminary determination. See IRM 25.15.7.11.9.
      Send a secure e-mail, using the read receipt function, to AUR/SCEB primary and back-up contact. Advise them of:
    • The determination is denied in full

    • Both taxpayers' names and taxpayer identification number (TIN)

    • Tax Year

    • Financial Technicians name and phone number


    If RS requests an Appeals conference regarding the Innocent Spouse claim denial:
      Send a secure e-mail, using the read receipt function, to AUR/SCEB primary and back-up contact to send their case to Covington Appeals Office. Notate file.
      Leave folder on case. Send innocent spouse file to Covington Appeals office. See IRM 25.15.7.11.11.2.. Include in the file a copy of the e-mail sent to the AUR/SCEB notifying them, to send their case to Covington. Notate on Form 3210, "Appealed AUR Case, associate with AUR Case" . Place the e-mail print to AUR on the top inside of the folder. Attach Form 1725, Routing Slip, notate at the top " Pre-Assessment " in red.
    Forward case to Covington Appeals office using existing procedures.  
    If NRS requests an Appeals conference regarding the Innocent Spouse claim denial:
    Take no action until notified by CCISO of the preliminary determination and the time to appeal has expired (45 days from the ISTS Stage 11 Stage Date). Inform NRS there are no appeal rights on the Innocent Spouse issue since the claim was denied in full.
    If neither spouse requests an Appeals conference regarding the Innocent Spouse claim denial:
    Do not issue SND until 45 days from the ISTS Stage 11 Stage Date has passed.
    • Issue final determination letter to RS. See IRM 25.15.3.9.2

    • Issue final notice to NRS. See IRM 25.15.3.9.3(3).

    • Update ISTS to Stage 12. See IRM 25.15.14.4.

    • Update IDRS control. Suspend for 110 days

    If SND defaults, process adjustments to the taxpayers’ MFT 30.  

    Note:

    Do not use Form 870–IS paragraph p in Letter 3661C on AUR cases.

  2. Determination to partially allow claim before issuance of SND — AUR/SCEB and CCISO will take the following actions:

    AUR/SCEB CCISO
    Take no action until notified by CCISO of the preliminary determination and the time to appeal has expired (45 days from the ISTS Stage 11 Stage Date). Issue preliminary determination. See IRM 25.15.7.11.9.
      Send a secure e-mail, using the read receipt function, to AUR/SCEB primary and back-up contact. Advise them of:
    • The determination is partially allowed

    • Both taxpayers' names and TIN

    • Tax year

    • Form 3465, with processing instructions for partials

    • Financial Technician's name and phone number

    If RS or NRS request an Appeals conference regarding the Innocent Spouse claim determination:

    Note:

    Do not send to Appeals until time to appeal has expired for both taxpayers.

      Notify AUR/SCEB via secure e-mail to AUR/SCEB and back-up contact, using the read receipt function, to send their case to the Covington Appeals office. Notate file.
      Send innocent spouse file to Covington Appeals office. See IRM 25.15.7.11.11.2.. Include in the file a copy of the e-mail sent to AUR/SCEB notifying them, to send their case to Covington. Notate on Form 3210, "Appealed AUR Case, Associate with AUR" . Place the e-mail print to AUR on the top inside of the folder. Leave folder on the case. Attach Form 1725, Routing Slip, notate at the top "Pre-Assessment" in red.
    Forward case to Covington Appeals office using existing procedures.  
    If NRS requests an Appeals conference thru AUR/SCEB regarding the tax issue:

    Note:

    Do not send to Appeals until time to appeal has expired for both taxpayers.

    Notify CCISO via secure e-mail to send their case to the Appeals office where the NRS lives. To find the appropriate office, use the website - http://appeals.web.irs.gov/cpte/caserouting.htm. Notate file. Forward case to Appeals office designated by AUR/SCEB using existing procedures.
      Update ISTS to Appeals. See IRM 25.15.7.11.11.2.
    If neither spouse requests an Appeals conference:
    Do not issue SND until 45 days from the ISTS Stage 11 Stage Date has passed.
    • Issue final determination letter to RS. See IRM 25.15.3.9.2.

    • Issue final notice to NRS. See IRM 25.15.3.9.3(3).

    • Update ISTS to Stage 12. See IRM 25.15.14.4.

    • Update IDRS control. Suspend for 110 days

    If SND defaults, process adjustments to the taxpayers MFT 30 and 31 accounts based on CCISO’s instructions.  

    Note:

    Do not use Form 870–IS paragraph p in Letter 3661C on AUR cases.

  3. Determination to fully allow claim made before issuance of SND— AUR/SCEB and CCISO will take the following actions:

    AUR/SCEB CCISO
    Take no action until notified by CCISO of the preliminary determination and the time to appeal has expired (45 days from the ISTS Stage 11 Stage Date). Issue preliminary determination. See IRM 25.15.7.11.9.
      Send a secure e-mail, using the read receipt function, to AUR/SCEB primary and back-up contact. Advise them of:
    • The determination is allowed in full

    • Both taxpayers' names and TIN

    • Form 3465, with processing instructions

    • Financial Technician's name and phone number

     
     
    If NRS requests an Appeals conference thru AUR/SCEB regarding the tax issue:  
    Notify CCISO via secure e-mail to send their case to the Appeals office where the NRS lives. To find the appropriate office use the website - http://appeals.web.irs.gov/cpte/caserouting.htm. Notate file. Forward case to Appeals office designated by AUR/SCEB using existing procedures.  
      Update ISTS to Appeals. See IRM 25.15.7.11.11.2..  
    If NRS requests an Appeals conference thru CCISO regarding the Innocent Spouse claim determination  
      Notify AUR/SCEB via secure e-mail, using read receipt function, to AUR/SCEB primary and back-up contact person to send their case to the Covington Appeals office. Notate file.  
      Leave folder on case. Send the innocent spouse file to Covington Appeals office. See IRM 25.15.7.11.11.2. Include in the file a copy of the e-mail sent to AUR/SCEB notifying them to send their case to Covington. Notate on Form 3210, "Appealed AUR case Associate with AUR Case" . Place the e-mail printout to AUR on the top inside of the folder. Attach Form 1725, Routing Slip, notate at the top " Pre-Assessment " in red.  
    Forward case to the Covington Appeals office using existing procedures.    
    If the NRS does not appeal:  
    Issue manual SND to the NRS only. Do not issue SND until 45 days from the ISTS Stage 11 Stage Date has passed. Issue final determination letter to RS. See IRM 25.15.3.9.2 . Issue final notice to NRS. See IRM 25.15.3.9.3 (3). Update ISTS to Stage 12. See IRM 25.15.14.4 . Update IDRS control. Suspend for 110 days.  
    If SND defaults, process deficiency assessment to NRS’s MFT 31 account based on CCISO’s instructions.    

  4. Imminent Expiration of Assessment Statute of Limitations (ASED) — If CCISO does not issue a preliminary determination letter within 6 months of the ASED, AUR/SCEB may proceed with issuance of the SND after notifying CCISO. CCISO will continue processing the innocent spouse claim and follow procedures in this manual.

25.15.7.4.3  (03-21-2008)
SND Issued — 90-Day Process

  1. An innocent spouse claim may be filed after the SND is issued.

  2. AUR/SCEB is responsible for monitoring the assessment statute expiration date (ASED) and making an assessment if the SND defaults.

  3. If the SND defaults before the innocent spouse issue is resolved, AUR/SCEB will follow normal procedures for assessing the tax. CCISO will then make account corrections as needed after the final determination is made.

  4. AUR/SCEB and CCISO will generally follow their normal procedures in addition to coordinating the following actions:

    AUR/SCEB CCISO
    Provide CCISO with the following: Send a letter to the RS informing them of the need to protect their petition rights for the AUR/SCEB deficiency and their right to raise the innocent spouse issue in their petition. Document the case file.
    Date the SND was issued,
    Copy of the tax computation,
    Copy of the information returns in AUR cases.
    Await further instructions from CCISO.  
    Notify CCISO if there is a reduction in the deficiency. Proceed with claim determination and issuance of preliminary and final determination letters.
      Notify AUR/SCEB of the claim determination.
    For petitioned cases on AUR/SCEB issues.
    Forward case to Appeals and notify CCISO of appropriate Appeals office to send their case if either spouse petitions. Determine the status of the claim and advise Appeals office of any delays in making the innocent spouse determinations. The determination will be made expeditiously after appropriate suspense period has expired.
    For petitioned Innocent Spouse issues.
      Forward case to Appeals and notify AUR/SCEB of appropriate Appeals office to send their case if innocent spouse determination is appealed or petitioned. See IRM 25.15.7.11.11.2.
    Forward case to Appeals office designated by CCISO using existing procedures. Notify AUR/SCEB where to forward the case.
    On defaulted AUR/SCEB SND where the Innocent Spouse Determination is Not Made and ASED is within 45 days
    Notify CCISO that assessment will be made and proceed. Make any necessary corrections to assessment after determination is made.
      Update ISTS as appropriate.
    On defaulted SNDs, where the Final Innocent Spouse Determination is made with more than 45 days remaining on the ASED
    Follow CCISO instructions when assessing deficiency on allowed or partially allowed claims. Send a secure e-mail with Form 3465 and allocation worksheet (as necessary) to AUR/SCEB.
      Update ISTS.
      Monitor final account processing.

25.15.7.4.4  (09-01-2006)
AUR/SCEB No Change Case

  1. If AUR/SCEB determines that the case is going to be closed as a no change (no deficiency), they will:

    1. Notify the CCISO AUR/SCEB Coordinator of the no change determination.

    2. Close case using normal procedures.

    3. CCISO will then take the necessary actions to address the innocent spouse claim.

      Note:

      Processing Code 29 indicates that AUR was not able to secure the return and are not pursuing the proposed deficiency. Close the case as PAND See IRM 25.15.7.8.4.

25.15.7.5  (03-21-2008)
First Read at CCISO Overview

  1. The responsibility of the First Read Tax Examiner is to identify:

    • Non-qualified claims,

    • Perfect the claims,

    • Disallow claims, if appropriate after reviewing IDRS,

    • Build claims;

    • Account problems, and

    • Rework/Reconsideration cases.

  2. Each year must be addressed and input on ISTS as appropriate.

25.15.7.5.1  (03-21-2008)
Claims Received in CCISO

  1. When a claim is received:

    1. Date stamp Form 8857 or substitute document on a daily basis.

    2. Check IDRS command code SUMRY or ISTSR for open innocent spouse controls and associate any new correspondence/claim with the existing claim.

    3. Copy Form 2848 (Power of Attorney and Declaration of Representation) attached to a claim and place in clerk’s basket. IRM 21.3.7, Processing Third Party Authorizations onto the Centralized Authorization File, for additional information. Clerks will fax the Form 2848 to the Centralized Authorization File (CAF) team per www.irs.gov/instructions/i2848/ch01.html. Keep the original in the case file.

    4. Screen for processable and unprocessable claims.

    5. Pull cases with requests for Appeals conference and route to the examiner coordinating the Appeals file.

    6. Ensure ISTS is input for each year relief is requested.

    7. Input TC 971 AC 065 following instructions in IRM 25.15.2.4.2.

    8. Ensure TC 130 has posted to the correct account per IRM 25.15.2.4.3.

    9. ESTAB for the administrative file, see See IRM 25.15.7.7.(8).

    10. Research for a TC 570 on the current year account. See IRM 25.15.7.7.

    11. Conduct IDRS Research. See IRM 25.15.7.5.2.4.

  2. Taxpayers must be contacted within 30 days after receipt of the innocent spouse relief request, per Action 61, see IRM 21.3.3.4.2.2.

  3. If the taxpayer raises other issues, copy the correspondence and route to the appropriate area for resolution. Notate on the routing slip you are processing the innocent spouse claim. Document the case file that the correspondence was forwarded to the appropriate area.

  4. If the claim information is insufficient to make a determination, contact the taxpayer by telephone or Letter 3659C to obtain the additional information. Advise the taxpayer to respond within 30 days or a determination will be made based on the information available. Suspend the case for 45 days.

    Note:

    Before disclosing any tax information, you must be sure you are speaking with the taxpayer or authorized representative. See the Taxpayer Authentication guidelines in IRM 21.1.3 , Operational Guidelines Overview. Also, before leaving any messages on a taxpayer’s answering machine, review IRM 11.3.2.6.1, Leaving Information on Answering Machine/Voicemail. Fax procedures contained in IRM 11.3.1.10 must be reviewed prior to faxing confidential information to the taxpayer.

  5. Before reaching a determination, the examiner shall fully analyze all information available. This includes contacting the NRS, see IRM 25.15.3.3.

  6. Original documents should be copied and the copies maintained in the case file. Return the originals to the RS. Use Form 3699, Return of Documents to Taxpayer or appropriate letter.

25.15.7.5.2  (03-21-2008)
Screening Procedures

  1. Claims will be screened in IRS received date priority. Claims will be screened for:

    • Disallowed/Non-qualified;

    • Built;

    • Referred, or

    • Other

  2. Other categories include items listed below:

    • Injured spouse, See IRM 25.15.7.8.14.

    • Additional information needed

    • Forgery, See IRM 25.15.7.6.5.

    • Invalid joint election, See IRM 25.15.7.6.6.

    • Account Problem (Place in appropriate folder and forward case to the Financial Specialist), See IRM 25.15.7.6.8.

    • IRS Employee Cases (Place in appropriate folder, forward to appropriate team), See IRM 25.15.7.6.3.

    • Congressional Cases (Place in appropriate folder and notify appropriate individuals), See IRM 25.15.7.6.4.

    • Collection Due Process (Place in appropriate folder), See IRM 25.15.7.6.12.

    • Taxpayer Advocate Case, forward to the Innocent Spouse TAS Liaison.

    • Reworks/Reconsiderations, See IRM 25.15.7.11.10. . Place a tag marked "Rework" , update ISTS to Stage 10 and route the case to the appropriate team

  3. Identify all years shown on Form 8857 or specified in the RS’s correspondence. All years must be addressed.

  4. Check for RS’s signature. A photocopied signature is acceptable. An authorized Power of Attorney (POA) signature (per CFINK or Form 2848) on Form 8857 is considered a valid signature.

    Exception:

    A fax signature is acceptable if in response to post filing/non-filing inquiries and interactions by IRS. The history file must be documented with the date of contact and a notation is made that the taxpayer wishes to send the document/form/letter by fax. A fax signature is acceptable when a taxpayer submits a Form 8857 based on our advice that they may qualify for relief in another year.

  5. If the RS gives an incorrect TIN for the NRS and you can determine the RS’s intent, continue screening the claim.

    Example:

    If the NRS’s TIN does not belong to the taxpayer she filed with for the year listed and module is balance due, build the case using the correct NRS’s TIN.

  6. Read the RS's correspondence to determine all years to consider. See IRM 25.15.7.11.11..

  7. Identify and address all other issues.

    Example:

    A taxpayer attaches a divorce decree for a tax year in which you are disallowing a claim. Issue Letter 3661C advising the taxpayer that the divorce decree does not change their responsibility to pay any liability owed. The divorce decree is a civil matter, and it has no impact on their taxes as far as IRS is concerned. If the former spouse has not paid as directed in the divorce decree, the RS should seek restitution from the former spouse in the court that issued the divorce decree or in other appropriate proceedings against the former spouse.

25.15.7.5.2.1  (03-21-2008)
No Valid Signature

  1. Continue processing the request to determine if the request would be a non-qualified/disallowed first read closure, e.g., no joint filed return.

  2. Prepare Letter 3658C , circle received dates on Form 8857 and all correspondence in red. Return the form and correspondence to the RS. In addition, if the year would be non-qualified/disallowed include a sentence in Letter 3658C, "this year would not qualify because..." .

  3. Complete an ISTSR Input Record to Stage 29 with Activity Description "UNPR" and Stage 30 with Activity Description "NOACCTP" .

    Note:

    Do not input TC 971 AC 065

    .

25.15.7.5.2.2  (03-21-2008)
Second Request