- 3.42.10.9 e-file Application Process
- 3.42.10.10 Fingerprint Cards Review and Processing
- 3.42.10.11 Maintaining e-file Application Letters in TPDS
- 3.42.10.12 Generating e-file Letters From TPDS
- 3.42.10.13 Password Security Process
- 3.42.10.14 Reporting Agent PIN
- 3.42.10.15 Validating Not for Profit Business Activities
- 3.42.10.16 Valid EFIN File
- 3.42.10.17 ETIN TYPES: Test to Production
- 3.42.10.18 EFIN and ETIN Clean-up
- 3.42.10.19 Compromised EFIN
- 3.42.10.20 Updating the TPDS for Previously Accepted Applicants
- 3.42.10.21 Undeliverable ERO Correspondence
- 3.42.10.22 Deceased Providers
- 3.42.10.23 Suitability
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The daily ASAP extract (RIS23D) is run to produce the ASAP report.
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The system sets the firm and personal suitability status to "In Process" .
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The ASAP results are uploaded to TPDS.
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A Hit (a suitability issue is identified on a TIN) creates a worklist item for the group.
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The worklist item is assigned to an assistor for review.
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A "Reapply" application is required for an applicant that has been denied participation (failed suitability), suspended for suitability issues, suspended for non-compliance issues, suspended per field monitoring or whose EFIN has been inactivated (and subsequently dropped) for undeliverable mail or inactivity for two consecutive tax seasons.
Note:
A "Deleted" application is not considered a "Reapply Application" . If the provider option "reporting agent" was selected on the application, the system also generates a reporting agent PIN letter.
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Suspension period and eligibility date is determined by the Level of Infraction (1 yr, 2 yrs, expulsion), but beginning October 1, 2012, firms and individuals may reapply as soon as they resolve their suitability issue. See IRM 3.42.10.23.11. Applicants may reapply when:.
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If the suspension period has been completed.
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The suspension was prior or equal to November 01, 2011, the eligibility date is not xx/xx/2099 and the Provider Status is not ”Non-Compliant for Field Monitoring” the applicant may reapply. Even if the Principal and Responsible Official is the same person, you must “apply” the eligibility date on both pages of the application. All such eligibility dates were reset to September 30, 2012, on that date.
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When the suitability issue has been resolved prior to the eligibility date, the applicant will need to contact the e-help Desk to have the eligibility date updated for the Firm and any Principal or Responsible Official who does not have an Active or Provisional PTIN.
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If the individual has an Active or Provisional PTIN, the eligibility date is not xx/xx/ 2099 and the Provider Status of associated application is not" Non-Compliant for Field Monitoring" , the eligibility date is updated systemically allowing the applicant to reapply without having to contact the e-help Desk.
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If the firm suitability equals "fail" and the firm’s TIN does not equal the SSN of the individual, the system will not allow the individual with an Active or Provisional PTIN to reapply. The individual will have to contact the e-help Desk.
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If the firm suitability equals "fail" and the firm’s TIN equals the SSN of the individual, the system with update the eligibility date for both the firm and personal suitability allowing the applicant to reapply without having to contact the e-help Desk.
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If the business organizational structure, EIN or SSN has changed, the application will be "new" but will be treated as a "Reapply" and all suspension periods must be met.
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When the Firm, Principal or Responsible Official has resolved the suitability issue(s) prior to completing their suspension period, the applicant may reapply. The eligibility date(s) may need to be updated before the applicant can reapply.
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Research TPDS, Historical Comments, Summary Page, Comments, EFIN Status and Eligibility Date, to determine if the applicant is eligible to reapply.
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Research IDRS and determine if the applicant is compliant.
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Update the eligibility date(s) to the current date.
Note:
If the firm had failed, update the eligibility date of the firm with the current date and select "apply" . Also update the eligibility date of each Principal and Responsible Official to the current date if applicable and select "apply" .
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Once "Reapply" application is submitted:
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The application status will update to "Submitted Reapply"
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The application will be systemically processed for suitability and treated as a new application. See IRM 3.42.10.9.3
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Any Principal or Responsible Official who previously failed suitability must provide new fingerprint cards or enter professional status information.
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If a Provider option is added, the system sets the e-file application status to "Submitted Revised" .
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If a Principal or Responsible Official is added, the system checks for suitability issues.
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If suitability is needed and there are pending documents, the systems sets the e-file application status to "Submitted Pending Documents" .
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If documents are not required or the suitability results are available, the system sets the e-file application status to "Submitted Revised" .
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If the e-file application passed suitability, the system generates the acceptance letter, which includes the EFIN (and the ETIN if applicable), and changes all provider statuses to "accepted" .
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If the provider option" transmitter" was chosen on the application, the system also generates a password letter, which includes the EMS login ID and password.
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If the provider option "Reporting Agent" was selected on the application, the system also generates a reporting agent PIN letter which includes a 5 digit PIN.
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The system sets e-file application status to "Complete" .
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The system deletes any remaining worklist items for the firm but worklist items for personal suitability would remain.
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Worklist items are generated for activities necessary to complete an application.
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Worklist items are:
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APP_SUBMIT_N_REV_IRS- is generated when an EUP user moves the e-file application into "Submitted in Review" status. This worklist item is deleted when the e-file application is moved to "Completed" status.
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APP_ASAP_HIT_IRS- is generated when the IRS receives a Hit on an individual. After all suitability research is completed and all necessary actions taken, the worklist item must be manually removed and the application status set to completed when fail is determined. This worklist is generated by ASAP Report Upload program when the IRS receives a Hit on an individual. After all suitability research is completed and all necessary actions taken, the worklist item must be manually removed and the application status set to completed.
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APP_SUIT_LATE_IRS - is generated by the system when the personal suitability status is set to “In Process” for 15 days. After all suitability research is completed and all necessary actions taken the worklist item must be manually removed and the application status set to completed when fail is determined.
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APP_ORGASAP_HIT_IRS- is generated when the IRS receives a Hit on the firm entity on an e-file application and is generated by the ASAP Report Upload program when there is a Hit on the firm. After all suitability research is completed and all necessary actions taken, the worklist item is removed when the application status moves to "Completed."
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APP_ORG_SUIT_LATE_IRS- is generated by the system when the firm's suitability status is set to "In Process" for 15 days. This worklist item is removed when the e-file application status moves to "Completed" .
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APP_FPC_LATE_ IRS - is generated after a FPC is sent to the Federal Bureau of Investigation (FBI), and the results have not been returned within 30 days. It must be manually removed from the worklist.
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APP_UN_FPC_LATE- is generated when a FPC returns from the FBI as unprocessable and another FPC has not been received from the applicant within 30 days. Worklist item must be manually removed.
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ASSIGN_OLF_EFIN_IRS - generated when Online Provider is selected. Assistor will evaluate whether a specific EFIN should be assigned and whether data provided is complete. Manual assignment of EFIN is required. Worklist item must be manually removed.
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MF_TRANS_FIRM_IRS- is generated by the system when the ASAPHITS extract indicates a Hit on the firm. The system will add a row and set suitability to recheck. Research and take necessary actions or set suitability to pass.
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MF_TRANS_IND_IRS- is generated by the system when the ASAPHITS extract indicates a Hit on the individual, and also when a PTIN status is updated to Suspended, Revoked, or Deceased. The system will add a row and set suitability to recheck except for Deceased PTIN Status. Research and take necessary actions or set suitability to pass, except for Suspended and Revoked PTIN Status cases which will be closed with no action until further notice.
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APP_PHY_ZIP_NVLD- is generated when the zip code submitted by a RUP user for the physical address does not match a zip code on the EFIN assignment table. Refer to IRM 3.42.10.9.2.
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APP_VALD_NFP_IRS- is generated when a not for profit program is selected with the exception of IRS Sponsored Business activities. Validation and manual assignment of EFIN is required.
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APP_SUIT_SDN_IRS is generated when a Specially Designated Nationals (SDN) name appears on an e-file application.
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APP_LETTER_REVIEW – is generated when a letter is created for review, edit and printing. Worklist must be manually removed.
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Assistors perform the necessary work for an item appearing on their worklist. When reassigning a worklist item, notate in the comment section the reason for reassigning the worklist.
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When the necessary work is completed, the assistor selects the check box to the left of the worklist item selecting the Marked Work Link. The item is then removed from the worklist item.
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When forwarding worklist to Lead, notate at the top: Date of completion. Additionally notate action taken for each item: Passed, Reassigned to, Sent for Management Review.
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It is the responsibility of Andover e-help Desk to review the application and any certification to ensure the information is available and current.
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Date of Birth (DOB) must be entered and show that the person listed is at least 18 years old.
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Each person on the application must select whether they are a U.S. citizen or a legal resident alien.
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License, proof of good standing or bonding certificate to ensure it is current.
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Enrolled Agent number is valid.
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All necessary information is available for an officer of a publicly owned corporation and on company letterhead.
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If a CPA license is not sent, check for a valid license at The American Institute of Certified Public Accountants, access via EPSS Portal Quick Links. If the license is found, input the state where licensed, professional validation status of failed, passed or pending, professional validation date "today’s date" , status as of effective date, select active or inactive and the license number with expiration date as a comment Professional Credentials page.
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If the applicant states that they are an attorney and do not provide support, a check of the State Bar Association can be done to confirm his/her license. If it cannot be located via the web site, request the applicant provide a copy. Input the information on TPDS.
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Enrolled Agents are systemically validated against the Enrolled Practitioner System (EPS). The TPDS system may automatically generate the Enrolled Agent's number when the name and SSN is input. If TPDS does not validate the EA number, and a copy of the EA card is not included with the application, validate the Enrolled Agent by calling the EA hot line at 313-234-1280.
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Applicants must include fingerprint cards for all Principals, and Responsible Officials listed on the e-file applications unless they are exempt from submitting the FPCs. If they are exempt and claim professional status, evidence of the professional status must be validated as stated in IRM 3.42.10.9.10.
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Review FPCs to ensure that the following is included on the card
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Name;
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Date of birth;
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Citizenship;
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Sex;
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Social Security Number;
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Signature of the person fingerprinted;
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Signature of the official taking fingerprints.
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With the exception of a signature, any information missing from the FPC can be obtained by telephone call or correspondence to the applicant, or by copying the information from the online application.
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TPDS provide an alert to submit all FPC from e-file application for FBI processing.
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If an amputation or deformity makes it impossible to obtain the fingerprint, the official responsible for taking fingerprints should have made a notation in the individual finger block on the FPC.
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If fingerprint is not readable, check for attachment of explanation such as Elderly and/or Age Makes it Impossible to Obtain a Clear Print. The official responsible for taking the fingerprints should have made a notation in the individual finger block on the fingerprint card.
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FPCs without signatures will be returned and not entered into TPDS. Send Letter 3643 ( Exhibit 3.42.10-54).
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FPCs may be destroyed 3 years after they are scanned and the electronic back up copy will be available if necessary.
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On a daily basis, scan all FPCs for FBI check into the Automated Electronic Fingerprinting (AEF) and submit them to the FBI electronically in accordance with the AEF User Manual.
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TPDS displays six statuses for FPCs:
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"Not-on-File" - no FPC was received from the applicant.
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"Not-Pulled" - the FPC was received from the applicant, but not pulled for FBI check.
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" In-Process" - the FPC was received and sent to the FBI for processing, but has not yet been returned.
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"Data" - findings with history are received back from the FBI.
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"No Data" - findings with no history are received back from the FBI.
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"Unprocessable" - FBI was unable to process the fingerprint that was submitted.
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Procedures after FBI results have been received.
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Manually update TPDS to show the FBI findings by using the drop-down box located in the Fingerprint Tab section f.
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Clerical will forward the FBI findings with the NASDC Referral sheet to NASDC.
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If the FBI is unable to process the FPC and no second fingerprint card is available, generate Letter 3643 (Exhibit 3.42.10-54.) requesting a new FPC. If the applicant does not provide a new FPC within thirty days from the date of the letter, place the applicant’s Provider Options in "dropped" status.
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If the FBI returns the FPC showing data, the clerical staff will forward the information to the RPO).
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Acceptable evidence of a currently active professional status:
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A CPA must show qualifications to practice as a CPA in any state, commonwealth, possession, territory, or the District of Columbia and must not currently be under suspension or disbarment from practice.
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An Enrolled Agent may submit a copy of a currently active enrollment card issued by the IRS or provide their Enrolled Agent number.
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A banking official must submit a copy of their bonding certificate and proof of fingerprinting within the last two years.
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An officer of a publicly owned corporation must submit evidence on corporate letterhead which carries their name as an officer, the stock symbol, the exchange where listed, and the name under which the stock is traded for the individuals listed as Principal and/or Responsible Official.
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An attorney must show good standing in the bar of the highest court in any state, commonwealth, possession, territory, or the District of Columbia, and also show they are not currently under suspension or disbarment from practice before the IRS or the bar.
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If a certificate is not normally issued, a letter indicating good standing from the bar or regulatory agency will be sufficient.
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The credentials for attorney, CPA and EA can be destroyed after they have been input into TPDS. Credentials received for banking official and officer of a publicly owned corporation should be maintained for three years after the application has been dropped.
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Before generating a letter, it must be defined in the appropriate control tables. These control tables are used to define the content of the letter, as well as the database or user enterable variables to be included in the letter. The control tables for letter definition may be found by selecting "Go" , "Application" , "Maintenance" and "Letters" in TPDS.
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Define the paragraphs that will be later selected for use within a letter. A separate paragraph must be defined for certain elements within each letter. For example, if the letter contains a date line, associate a paragraph of type "Date Line" with the letter. Each paragraph that is defined will have sequence number, paragraph type, description and paragraph text. The sequence number identifies each paragraph, while the paragraph type determines where the text will be placed on the letter. The description describes the paragraph content and provides any special instructions to the end user. The paragraph text is the actual text to be displayed in the letter.
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Paragraphs can be static or dynamic. A static paragraph is one that is hard coded and will always be the same from letter to letter. A dynamic paragraph is one that uses both data base and system variables that will be substituted in the letter at run time. Valid paragraph types include: date line, enclosures, recipient address, reference line, return address, signature line and body.
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Letters can contain two types of variables: user-defined variables, and database variables. User-defined variables are defined by the user at run time. Database variables are supplied by a field in the database. Only certain fields may be used as database variables.
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If the letter paragraphs, tokens, definitions and variables are creating problems within the control tables, and a specific letter requires correction, use the e-file Letter Change Request form ( Exhibit 3.42.10-6.) to request the revision of a current letter or create a new letter.
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In section I, enter the name of the originator and the date and time of the request. The control number will be filled in by the letter maintenance analyst.
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In section II, check the appropriate box to identify if the letter request is to revise a current letter in TPDS or for a new letter. If a new letter request please provide title and description of new letter.
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In section III, enter the letter number and check the appropriate reason for the requested change. Describe the requested changes. Managerial approval must be obtained before forwarding to the letter maintenance analyst.
Note:
Section IV is to only be completed by the letter maintenance analyst. This area identifies when the corrections or changes were completed and if additional information or follow-up action is needed before the changes can be made.
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The letter definition component allows the user to define the letter. A letter is composed of the following:
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Letter name (name of the letter)
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Description (letter purpose)
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Revision Number (prints at bottom of the letter and is optional)
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Revision Date (prints at bottom of the letter and is optional)
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Paragraph Number (unique number associated with the paragraph to be attached to the letter)
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Paragraph Description (is view only and populated based on the paragraph number selected)
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Details (allows user to view the details associated with the paragraph)
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Paragraph type (is view only and populated based on the paragraph number selected)
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Order of Appearance (reflects the order in which the paragraphs will appear on the page)
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Paragraph Required (not used at this time)
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Paragraph Edit (this flag should be turned on if the paragraph can be edited by the user)
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To generate an e-file letter, select esrv-appl-efile, e-services, e-file, Search e-file Application. Search by any of the criteria and select the appropriate application. Letters can be generated from many pages within the component. The following example uses the Principal page:
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Select the name of the letter from the drop down box. The letter page will display and list the paragraphs of the letter that require user action: selection of optional paragraphs, entering of user supplied variables and user input of appropriate text for edit paragraphs.
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Spell check the verbiage by selecting the book on left below the open text box. Edit if necessary and select Save.
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The user should select "Printable Format" to prevent the IRS header and e-services Privacy Policy from printing.
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Worklist will be created APP_Letter_Review for all letters saved.
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Leads will review letters using the worklist in the efile_Admin_Leads workgroup.
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Edits and/or comments can be notated.
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Complete letters should be mark Final Version.
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Reassign or select the printer friendly to view.
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Letter is displayed for review and select Print Letter link to print.
Note:
Letters cannot be modified once marked final.
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To search for a created letter, select esrv-appl-efile, eservices, efile, process, new print notice.
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Select from the drop down Notice ID, Doing Business As, User ID. Enter information.
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Select the applicable result, entry opens for view, editable unless marked final version.
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The system will generate the security password letter 2461 (Exhibit 3.42.10-22.). The letter will contain the initial password for logging into the Electronic Management System (EMS).
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Security letters containing new passwords will only be issued to newly accepted Transmitters. The EMS Password Maintenance Process will provide all other passwords.
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Refer to Publication 1346, Electronic Return File Specifications and Record Layouts for Individual Income Tax Returns under Data Communications for the Password Maintenance Process.
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When an e-file applicant or IRS employee attempts to add the Reporting Agent Provider option to the e-file application, the system will validate that the EIN entered on the application has at least one Form 8655, Reporting Agent Authorization, posted to the Reporting Agent File (RAF).
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If the EIN is found, the Provider option will be set to "applied" .
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If the EIN is not found, the reporting agent Provider option will not be able to be selected and the following error message will appear:
A valid Form 8655, Reporting Agent Authorization, must be on file with the IRS prior to adding this Provider option. The Employer ID Number (EIN) on this application could not be found on our Reporting Agents File. Please contact our e-help Desk at 866-255-0654 if you need assistance.
Note:
The same error message will be displayed if the applicant is a sole-proprietor and enters an SSN for their TIN. The SSN will not be valid on the RAF.
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The results of the EIN validation can be checked manually using Command Code (CC) RFINK, definer R, and the EIN of the Reporting Agent.
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If an applicant selects the Reporting Agent Provider option on the e-file application, it is the applicant's responsibility to complete Form 8655, Reporting Agent Authorization. They must submit the Form 8655 and the Reporting Agent’s listing to the Ogden Submission Processing Center.
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If Andover e-help Desk receives a Form 8655, complete a Form 4442, Inquiry Referral, and fax it to 801 -620-4142, the Ogden Account Management Center (OAMC), requesting the Reporting Agent information be added to the RAF. Andover e-help Desk will not maintain a case history folder for the Form 8655 and the applicant’s Reporting Agent listing. For additional information on Reporting Agent Application and PIN Generation Process, refer to IRM 3.42.4.5.3, Business e-file Participant Criteria (3 through 6).
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When an applicant selects the Reporting Agent Provider option and the applicant becomes an accepted provider, Letter 3086, which includes a Personal Identification Number (PIN), will systemically generate and be sent to the Reporting Agent.
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Not for Profit business activities include Large Taxpayer, Employee Member Benefit, IRS Sponsored Taxpayer Assistance Centers (TAC), and IRS Sponsored Military Bases, Tax Counseling for the Elderly (TCE), Volunteer Income Tax Assistance (VITA) and State Government Agencies.
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The IRS Sponsored Not For Profit business activities are systemically validated through STARS/SPECTRUM.
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Not for Profit business activities default the application status to "Submitted New" and create work lists APP_VALD_NFP_IRS with the exception of IRS Sponsored business activities.
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The assistor validates all Not for Profit business activities on the worklists as described below.
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The assistor explains the actions taken in the Application Comments per IRM 3.42.10.7.20, Application Comments, and manually assigns an EFIN per IRM 3.42.10.9.1, Manual Assignment of EFIN.
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If the assistor can not validate a Not for Profit business activity, the assistor sends Not For Profit rejection letter 3.42.10.55 per IRM 3.42.10.12.
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TPDS systemically validates IRS Sponsored Not for Profit business activities by matching Site Identification Numbers (SIDNs) against the SPECTRM file which is downloaded daily to TPDS. SIDN has nine characters; the first character is the letter S followed by eight numeric digits; for example S12345678.
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When an IRS Sponsored Not for Profit business activity applicant completes the IRS e-file application via the RUP, the applicant must enter its SIDN.
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If the SIDN is valid, the application continues through systemic processing.
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If the SIDN is not valid, a pop-up message advises the applicant "Your SIDN is not valid. Contact your SPEC Area Analyst."
Note:
SIDN can also be viewed by selecting "Program(s) Applying For" then click on the blue hyper link "Edit" .
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If an IRS Sponsored Not for Profit business activity applicant should include the SIDN on the Doing Business As line .
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SPEC may request e-help to place a VITA or TCE EFIN in inactive status if the site refuses to comply with SPEC's Quality Site Requirements (QSR) or if the site is closed.
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SPEC faxes a Request for Deactivation check-sheet and a copy of the Partner Notification letter mailed to the VITA/TEC site to e-help manager at 877–477–0567.
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e-help then takes the appropriate actions to place the EFIN(s) in inactive status.
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The Employee Benefit Program business activity may or may not be a newly created volunteer organization or a volunteer organization with existing coalitions, partnerships, or other SPEC initiatives serving as a Not for Profit business entity.
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If the applicant selects the Not for Profit business activity of Employee Benefit Program.
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The assistor will check the filing requirements of the applicant on IDRS Command Code INOLES or ENMOD to confirm the filing of employment tax returns 94x.
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If the applicant is filing employment tax returns, the assistor continues processing the e-file application.
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If the applicant is not filing employment tax, the assistor will notate in comments per IRM 3.42.10.7.20, Application Comments and open an e-case referencing the tracking number of the application in EHSS. Elevate to ANA_ SPEC for validation and send as Open Referred to the ANA_SPEC.
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If ANA_SPEC validates the applicant has a relationship with an existing coalition, partnership or other SPEC initiative, comments will be included in the e-case and referred back to the ANSC Lead Group.
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If ANA_ SPEC cannot validate the Employee Benefit Program, the assistor closes the e-case, and sends Not For Profit rejection letter explaining that the e-file application cannot be processed because the IRS does not have a record that the applicant is an employer.
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For business activity Large Taxpayer, the assistor validates the activity by accessing IDRS Command Code INOLES with the EIN on the IRS e-file application and identifying the Business Operating Division Code (BOD: CD).
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If BOD: CD is equal to TE, the applicant is a Tax Exempt Organization.
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Use IDRS command code BMFOLO to research the organization to determine if the applicant qualifies as a Large Taxpayer Exempt Organization.
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Use the Filing Requirements Code at the bottom of the screen to determine the last filed Form 990, 990-EZ, 990-PF, or 1120POL.
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Determine if the filer qualifies as a large taxpayer by reviewing the Asset Code in the center of the screen. If the Asset Code is "8" or "9" , the applicant is a large exempt organization and eligible for Large Taxpayer Not For Profit business activity. The assistor will enter comments and continue processing the application to issue the EFIN and ETIN (Large Taxpayers are issued both ETIN and EFIN).
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If the Asset Code is other than "8" or "9" , the applicant is not considered a Large Taxpayer but may be eligible. The assistor opens an e-case "open referred" to the e-case to Analyst 990 (ANA-990), who will serve as the Level 2 TEGE analyst. Per IRM 3.42.10.7.20, Application Comments include the following information in the comments: the application tracking number, e-case "Open Referred" , and "Elevated to ANA-990 for decision" .
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If the assistor receives a message at the bottom of the BMFOLO screen that reads, "No Exempt Organization Information Is Available For this Account" , the assistor assigns the e-case to a Level 2 Analyst 990 (ANA-990) Application, and includes comments per IRM 3.42.10.7.20,Application Comments : the application tracking number, e-case "Open Referred" , "Elevated to Level 2 Analyst 990 (ANA-990) for decision" .
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If BOD: CD is not equal to LM and the Form type is other than 990, 990-EZ, 990-PF or 1120-POL, the assistor assigns the e-case to Level 2 LMSB Large Taxpayer Application, and includes the following comments per IRM 3.42.10.7.20,Application Comments: the application tracking number, e-case "Open Referred" , "Elevated to Level 2 LB&I-1120WAIVL2 for decision" .
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Level 2 LB&I Large Taxpayer Application or Level 2 TEGE support researches the taxpayer and determines if it qualifies as a valid Large Taxpayer. This will include contacting the Large Taxpayer, if necessary.
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If the applicant is a valid Large Taxpayer, the Level 2 LMSB-1120WAIVL2 or Level 2 TEGE refers the case back to the ANSC Lead Group. The assistor closes the e-case, includes comments, and continues to process the e-file application.
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If the applicant is not a valid Large Taxpayer, the Level 2 LMSB or Level 2 TEGE contacts the taxpayer to explain why the application is not accepted.
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Level 2 LMSB or Level 2 TEGE includes comments in the e-case explaining why the applicant does not qualify as a Large Taxpayer and refers the e-case back to the ANSC Lead Group.
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The assistor includes comments in the e-file application and sends Not For Profit rejection letter explaining why the application can not be processed.
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The IRS Taxpayer Assistance Center applicant must include TAC Office Designation Number (ODN) on the appropriate field on the IRS e-file application (comments field). An ODN should have eight (8) characters, seven (7) numbers followed by a letter, for example IRS TAC Gotham City, NY 1102123Z.
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The assistor validates the ODN by checking the ODN list on the Field Assistance Insider FA Insider. The ODN list has an index that describes how to identify operational and active TAC sites.
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If the assistor validates the ODN, the assistor enters comments, and assigns the EFIN to continue the processing of the e-file application.
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If the assistor can not validate the ODN on FA Insider, the assistor enters comments and sends Not For Profit rejection letter explaining the application is being returned because either:
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a valid ODN is required and they should contact the appropriate Field Assistance Area Analyst
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a valid SIDN is required and they should contact the appropriate SPEC Territory Office.
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IRS e-file application worklist item will be generated for an applicant selecting Provider Option "State Government Agency" .
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The assistor will access IDRS Command Code INOLES with the EIN of the State Agency on the IRS e-file application to determine the BOD: CD (Business Operating Division Code) and the Employment Code or the Client Code.
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Validity is determined by performing the following checks listed below:
If ... And ... Then ... If BOD:CD is equal to TE Employment Code is equal to "G" or "T" ; or, Client Code is equal to "F" or 2 The application is for a valid State Government Agency. Proceed to Step 4 If BOD:CD is NOT equal to TE Employment Code is equal to "G" or "T" ; or, Client Code is equal to "F" or 2 Assign to Level 2 based on form type: • 1040/1065/1120 (1120 Waiver) •990/990EZ/990PF (ANA-990) If BOD:CD is equal to TE Employment Code is blank; or is NOT equal to "G" or "T" ; or, Client Code is NOT equal to "F" or 2 Assign to Level 2 based on form type: •1040/1065/1120 (1120 Waiver) •990/990EZ/990PF (ANA-990) -
If the application is a valid, State Government Agency, the assistor will take the steps identified below to continue processing application
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Verify legal name is the State and the DBA Name contains the appropriate code. This is a manual inspection, as the EIN and Name have already been validated before the application was submitted. The DBA Name is made up of the State Abbreviation, ST, and additional codes. These additional codes identify how the State is participating in the MeF Fed/State Program. For example: MD Dept. of State: MDSTCB, where the C stands for Corporate and B stands for Both (linked and stand-alone) or MI Attorney General: MISTEF, where the E stands for Exempt and F stands for linked only.
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For Forms 1040 (MeF), 1065, and 1120, if the State Agency Name contains the name of the State’s taxing agency (i.e., Dept. of Revenue, Dept. of Tax Commission), and the DBA Name is in the correct format, then approve the application. Proceed to Step 5, or if the State Agency Name does not contain a taxing agency, and/or the DBA Name is not in the correct format, then assign the e-case to Level 2 1120 Waiver.
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The assistor will open an e-case in EHSS (be sure to include the applications tracking number in the e-case and refer the e-case ‘Open Referred’). The assistor will edit comment to read, ‘elevated to 1120 Waiver for decision.’ The 1120 Waiver analyst proceeds to step 6.
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For Forms 990, 990-EZ, and 990-PF, if the State Agency Name contains the name of the State’s Charitable Agency (i.e., Attorney General, Secretary of State), and the DBA Name is in the correct format, then approve the application. Proceed to Step 5.
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If the State Agency Name does not contain the charitable agency, and/or the DBA Name is not in the correct format, then assign e-case to Level 2 990 (ANA-990). The assistor will open an e-case in EHSS (be sure to include the applications tracking number in the e-case and refer the e-case ‘Open Referred’). The assistor will edit comment to read, ‘elevated to ANA-990 for decision.’ The ANA-990 analyst proceeds to Step 6.
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The assistor will continue processing the application to issue the EFIN and ETIN(s) , and move the Transmitter to accept. Then assign one ETIN for test and one ETIN for production. The assistor will manually generate an Acceptance letter and move the application to completed.
Note:
If the assistor does not manually generate the acceptance letter, only one EFIN and ETIN will be included.
Note:
After the application is complete, the State Responsible Official should add Delegated Users and Assign Authorities (i.e., MeF Enroller, etc.). The Responsible Official Receives all authorities by default.
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Level 2 1120 Waiver or Analyst 990 application support will research the state and determine if they qualify as a valid State Government Agency. This will include contacting the State Government Agency if necessary.
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Level 2 1120 Waiver or Analyst 990 application support will add comments to the e-case to instruct the assistor as to the disposition of the e-case.
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Level 2 1120 Waiver or Analyst 990 application support will refer the case back to the Andover Lead Group so that the e-file application can continue to be processed or the EUP worklist item can be closed.
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If the application is disapproved the Level 2 1120 or ANA-990 will contact the taxpayer to explain why their application is not being approved.
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Level 2 1120 Waiver or ANA-990 will update comments in the e-case to explain the reason for disapproval, and return to the Andover Lead Group.
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The assistor will edit comments in TPDS with the reason for the disapproval and reject the e-file application.
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-
When a Provider's Electronic Filing Identification number (EFIN) is inactive or dropped, it will not be stored on the valid EFIN file.
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The valid EFIN file prevents applicants that were denied participation in IRS e-file from sending electronic returns.
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The valid EFIN file is generated by the TPDS and provided to the computing center.
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ETIN types can be "test" or "production" . ETIN(s) generated through auto-pass will automatically be assigned a production ETIN with the exception of ETIN(s) for Provider option of Software Developer, who will receive a test ETIN. The Software Developer’s ETIN cannot be updated to production status. These statuses will be shown on the ETIN status page of the e-file application.
-
When assigning an ETIN manually, its use must be determined. If it will be used to transmit production returns, it should be assigned a production ETIN.
-
If an ETIN is in test status for a Transmitter, update it to a production ETIN.
-
Form types will also have a "Test’" and "Production" status for Transmitters and Software Developers. The form type must also be changed to correspond with the ETIN type once the assistor has verified that all necessary testing has been successfully completed.
-
Update the Form type from Test to Production on the Forms page of the e-file application. This can be done by clicking the edit link.
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If there are multiple ETIN(s) related to the same Provider option on the same application, updating the forms for that Provider option will apply to each of the related ETIN(s).
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-
Each year in May, analysis is conducted to identify all EROs and Transmitters that have been inactive over the preceding two filing seasons. The EFIN(s) and /or ETIN(s) of these inactive EROs and Transmitters are placed in "inactive" status and their Provider Options are dropped. Inactive Electronic Transmitters Identification numbers (ETIN(s)) of dropped Transmitters can be reissued immediately, if necessary.
-
The EFIN clean-up identifies and inactivates EFIN(s) of EROs who applied to participate in IRS e-file but have not submitted any returns during the preceding two filing seasons. The forms to be included are Form 1040, Form 1120, Form 1120-F, Form 1120-S, Form 1065, Form 1065-B, Form 2290, Form 8849 and Form 720.
-
EROs in "accepted" status and whose suitability status is in "Passed" are analyzed. If all of the following criteria are met then the EFIN status will be placed in "inactive" Status and later dropped.
-
They are an ERO only (no other associated Provider Option is ISP in accepted status).
-
They have not filed any Forms 1040 in the current or immediately preceding year.
-
The EFIN is in "Active" status.
-
They have indicated that they file Form 1040 only or Form 1040 and Electronic Transmittal Data (ETD).
The EFIN clean-up will not include any applicants who have indicated on their application that they would e-file Form 94x, Form 990, Form 1041, Form 1120 POL, Form 2290, Form 8849, or Form 720.
Note:
If an assistor receives a call from a Circular 230, Large Taxpayer, Low Income Tax Clinic (LITC), or State applicant and their EFIN was inactivated due to the EFIN clean-up only, reactivate their EFIN and add the Form 1041 to their application. This exception is for EFIN clean-up only.
-
-
The EFIN dropped date appears on the TPDS screen. It may vary from year to year but it will be the same for all EFIN(s) dropped in any given year as a result of the clean-up. A dropped EFIN may not be used by that ERO in any following year. A new EFIN must be issued for all new applications.
Note:
Dropped EFIN(s) are recycled and re-issued to new EROs 12 months after being placed in Dropped status.
-
ANSPC uses the most current ELF1541 report and the final ELF1541 report, from the prior year, to determine whether returns have been filed for each EFIN reviewed. Return Preparer Office (RPO) Analysts will instruct persons responsible for initiating the clean up of what they want.
-
The Letter 3250 (SC/CG), EFIN/ETIN Clean-up Letter, systemically generated and sent to the ERO advising that the firm has been placed in inactive status. To reactivate the EFIN the ERO must contact an e-help Desk Assistor. Once the EFIN is dropped through the EFIN Drop Program, it cannot be reactivated. The letter also provides instructions on how to reapply after the EFIN is dropped.
Note:
If the ERO is also a Transmitter (has a valid ETIN), a second analysis must be performed on their Transmitter e-file activity before the EFIN is dropped.
-
The ETIN clean-up identifies and deletes ETIN(s) where Transmitters who have applied to participate in IRS e-file, but show no form type set to "Production" status in the preceding two filing seasons.
Note:
If an assistor receives a call from a State applicant and their ETIN was dropped due to the ETIN clean-up only, assign them a new ETIN and add the Form 1041 to their application. This exception is for ETIN clean-up only.
-
An inactive Transmitter who is an active ERO will have their ETIN(s) dropped but not their EFIN.
-
Transmitters in accepted status whose suitability status is passed or recheck are analyzed.
Note:
Exception: Transmitters who filed a new application after June 1 of the current year are not included in the analysis.
-
The ETIN dropped date appears on the ETIN status screen. It may vary from year to year but it will be the same for all ETIN(s) dropped in any given year as a result of the clean-up.
-
The most current ELF1543 report and the final ELF1543 report, from the prior year, determine whether returns have been transmitted for each ETIN reviewed.
-
Letter 3250 (SC/CG) (Exhibit 3.42.10-35) is generated from TPDS when the firm is an inactive Transmitter and an inactive ERO. The following sentence is added to the end of the first paragraph: We will also deactivate any ETIN(s) that were issued to you under your EFIN.
-
-
There may be times when the IRS is notified or uncovers through internal sources that an EFIN has been compromised by either advertent or inadvertent actions. An EFIN can be considered compromised when it is being used by an unauthorized user who is not listed on the e-file application.
-
When an EFIN is found to be compromised:
-
Contact owner of EFIN and inform of possible compromised EFIN.
-
Place the compromised EFIN and any associated ETIN(s) in "inactive" status.
-
Inform the applicant of the new EFIN in either a letter or by telephone and inform them that the old EFIN is no longer valid.
-
Pull the folder and reconcile contents into the new folder that reflects the new EFIN.
-
If owner needs additional time for returns to be processed, allow time up to 1 week.
-
Enter appropriate comments on TPDS
-
-
Follow disclosure guidelines if information indicates that disclosure occurred due to the compromised EFIN.
-
In lieu of a revised e-file application, a documented e-case may be used. For disclosure purposes, the name, company name (if applicable), EFIN, ETIN, TIN (SSN or EIN), or PTIN must be verified in a e-case. The company address may be used for additional authentication (for example, if the company name the caller gives differs from our records). The individual revising or updating the e-file application, must be listed as a Principal, Responsible Official or Delegated User with the appropriate Authorities on the existing e-file Application.
-
If the entity information is being revised, update the e-file application information on TPDS. However, a new EIN is needed if the business structure has changed then a new application is needed.
-
If the applicant is changing the functions performed, direct them to the IRS web site for additional publications as necessary.
-
Assistors will not add or remove Principals, Responsible Officials, or Delegated Users, or submit an application based on a phone call, even if speaking to an authorized person. These changes require a signature of the authorized person.
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For any revisions/updates, the applicant should be made aware that the changes can be made online.
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Exception: Sometimes applications with EINs are filed with only one person on the application as a Principal and Responsible Official. If a call is received from an employee of the corporation stating that the person on the application is no longer associated with that EIN, do the following:
-
Ask the person who will be added on as a Principal and/or Responsible Official to fax, on company letterhead, a note stating who should be removed from the application and why, who should be added, their SSN, DOB, and certification that the structure of the company has not changed due to the person no longer working for the firm. Request that the original letter be mailed to the Andover e-help desk for inclusion in the EFIN file. The letter should be signed by a current officer of the firm.
Note:
Sole Proprietorships are not transferable. If a potential ERO has purchased an existing e-file business. They must apply for a new EFIN.
-
On receipt of the fax which contains all necessary information, input the person on the application and remove the original Principal and/or Responsible Official. Do not input the Terms of Agreement or suitability questions for the individual.
-
Contact the new Principal/Responsible Official, and request that he/she registers for e-services if they have not previously done so. The new Principal/RO should then complete the revision of the application and submit it.
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If there is a United States Postal Service (USPS) National Change of Address (NCOA) which indicates a new address on the correspondence, change the address on TPDS and indicate by comments that this is being done based on USPS NCOA. The NCOA is a recognized method of receiving updated taxpayer addresses per IRM 3.13.5.48, Updating Address Records. Reissue the correspondence.
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If the Provider is a Not for Profit, Volunteer Income Tax Assistance (VITA) Site or Tax Counseling for the Elderly (TCE), open e-case requesting correct year round address and Alternate contact information. Assign to SPEC_ANA L2 provider group. When the e-case is returned with the needed information, update the application accordingly. When (1) or (2) do not apply, call the applicant/Provider or listed contact name as provided on the e-file application:
-
If able to reach the Provider by telephone, update the TPDS with the new information and reissue correspondence. Exception: If the undeliverable mail is a password letter, elevate the e-case to EMS level 2 to have a new password issued.
-
If unable to reach ERO by telephone:
-
Place the EFIN and any associated ETIN(s) in “inactive” status. Do not place the EFIN in “dropped” status. Dropped EFIN(s) cannot be recovered.
-
Set the Undeliverable Mail Indicator to Yes on the TPDS. Add appropriate comments to the TPDS.
-
Document telephone call in the Application Comments page of the EFIN and in an EHSS e-case. Notate the letter number, letter date, and main issue of letter in both areas:
Note:
When undeliverable mail involves a national account an e-case should be sent to the lead to submit an e-mail to the National Account Management (NAM) program on a weekly basis containing the national accounts with undeliverable correspondence. Hold e-case open until you receive a response from the NAM. Refer to the National Accounts and National Account Managers.
-
-
If the ERO calls after the Undeliverable Mail Indicator is set, then:
-
Update the address and any other information on the TPDS;
-
Prepare documentation for e-case, if necessary;
-
Update the ERO record to the appropriate status on TPDS.
-
Update the undeliverable indicator to "No" .
-
Update the EFIN and any associated ETIN(s) to "active" .
-
Reissue of prior correspondence may be required.
Note:
If reissued prior correspondence was a suitability-related letter, update the appropriate TIN's suitability status to Recheck.
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-
When information is received that a Principal or Responsible Official is deceased put Personal Suitability of the deceased individual to "Incomplete" .
-
Research TPDS for associated EFIN(s), SSN(s) and EIN(s).
-
If the deceased individual is the only Principal on the application Drop all applicable EFIN(s) and ETIN(s), update all Provider Options to Dropped and enter the following comment "Principal deceased" .
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If the deceased individual is not the only Principal on the application or is only a Responsible Official request either by telephone contact or LOI that the Provider removes the deceased individual from the e-file application within 30 days. Place Firm Suitability in Recheck and enter comments "Firm to remove deceased" .
-
If Provider has not removed deceased individual within 30 days, Inactivate applicable EFIN(s) and related ETIN(s).
Note:
Inform the Provider that if the death resulted in a change in business structure it may need to obtain a new EIN and complete a new e-file Application.
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-
Refer any questions regarding unusual scenarios such as continuing operation or multiple firms to a RPO analyst.
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Suitability is the process used by the IRS to determine if the firms and individuals listed on e-file applications are appropriate (i.e. suitable) to distribute electronic filing products and services under IRS e-file. It is also used to determine if firms and individuals on Acceptance Agent applications are suitable to assist alien individuals and other foreign persons with obtaining TINs.
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The IRS sets suitability standards to screen and monitor applicants to ensure that they maintain a high degree of integrity and adhere to the highest professional and ethical standards.
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Suitability checks, which are performed at Andover Campus, may include an FBI criminal background check, credit history check, IRS tax compliance check and prior history check for compliance in IRS e-file.
-
The suitability codes are "Passed" , "Failed" , "Recheck" , "in-process" , "none required" and "incomplete" .
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Suitability checks are not conducted on the following:
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Software developers who function solely as software developer
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Providers who offer e-file solely as a benefit
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IRS sponsored Not for Profit organization,
-
Large Taxpayers
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Delegated users
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Contacts/ Alternate contacts
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Suitability checks for new applications should be completed within 45 calendar days of submission or receipt of the complete, correct application which includes all necessary documentation. If the suitability status remains “in process” for more than 45 days, the assistor must send Letter 2462, Receipt of Application, indicating that an additional 30 days is needed to process the application.
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See Publication 3112 and Rev. Proc. 2007-40 for suitability information.
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Applicants will not be accepted into IRS e-file until any applicable FBI fingerprint results are received and analyzed.
-
The applicant will be accepted into IRS e-file when the FPC is returned showing no criminal data and all other suitability checks have been completed and passed.
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When the FBI returns the FPC showing data, the designated assistor will forward the information to the Return Preparer Office (RPO) Analyst. The assistor will include any pertinent information with the case.
-
RPO analyst will evaluate the fingerprint reports for the following:
-
History of conviction or current indictments for financial crimes; e.g., tax crimes, money laundering, false claims, etc;
-
Dishonesty, e.g. bank fraud, mail fraud, securities fraud, etc;
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Breach of trust; e.g., embezzlement, violations of fiduciary trust, theft by misrepresentation, etc. (U.S. Title 18, 26, and 31).
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If convictions are found, the RPO analyst may recommend that the applicant/Provider be denied participation/sanctioned from IRS e-file as a result of conviction or indictment of crimes under revenue laws of the U. S. Title 18, 26, and 31 or of a state or other political subdivision.
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The RPO analyst will evaluate other items on the criminal record to determine if the nature of the items will adversely impact IRS e-file.
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The RPO analyst will consider the seriousness of the offense and duration of time since the offense when recommending that the applicant/Provider be denied participation/sanctioned.
-
The RPO analyst will recommend the specific sanction; one or two year suspension or expulsion.
-
When or if EPSS disagrees with the decision recommended by CI or Return Preparer Office (RPO) analyst, take the following actions:
-
Forward the case to manager for contact via telephone, e-mail etc. with CI or RPO analyst for further discussion or reversal of recommended decision.
-
-
If Manager/ CI or RPO analyst is not able to agree/resolve recommendation after additional discussions, contact the suitability program analyst before any action is taken. Analyst will advise when to prepare and send Letter 2462 SC/CG to applicant advising of extension of review. Update comments on EUP.
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The suitability analyst will be notified if no agreement is reached and forward the case for review by RPO Executive for "FINAL" decision on case.
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Upon completion of the review by the Executive, the suitability analyst will provide instructions to resolve the case in accordance with the decision rendered.
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Daily suitability is completed on new e-file applications prior to their acceptance into IRS e-file.
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The daily suitability process conducted on new applicants may include an FBI criminal background check, a credit history check, a tax compliance check and a history check for prior non-compliance in IRS e-file (research TPDS historical comments for outstanding compliance issues).
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Daily suitability is conducted on all taxpayer identification numbers (TINs) listed on the e-file Application for the firms and the Principals and Responsible Officials. Applicants with compliance issues will be denied participation in the program until all issues have been satisfactorily resolved. See IRM 3.42.10.23.11.2.
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Criteria: ASAP look back period: ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ -
For daily suitability, applicants that require a suitability check will have an EFIN generated or reactivated and will be added to the daily ASAP extract for processing in the PAT50 program against the master file data. Applicants will have their suitability status updated to In Process by the ASAP extract program. The file PAT5102 produced by the PAT50 program, is automatically loaded into TPDS on a daily basis. The program updates the ASAP results with a "Hit" or "No Hit" , and provides comments in the file when there are Hits. Andover leads will receive a worklist notification for the Hits, and assign them to an assistor for research and follow up.
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There are several worklist items related to suitability. To update either a group or an individual worklist, select "e-services" , "e-file" and "Process" . Select "Group worklist" to access the listing for the group or "Individual worklist" to access any individual listing. The system automatically places all new worklist Items in Andover's lead group. All work that has been assigned to a group from a user is in this group. This would typically occur when an assistor/lead needs to escalate the items to a manager. The worklist items related to suitability are:
-
APP_ASAP_HIT_IRS
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APP_SUIT_LATE_IRS
-
APP_ORGASAP_HIT_IRS
-
APP_ORG_SUIT_LATE_IRS
Note:
IRM 3.42.10.9.9, Worklists for a description of each worklist item related to suitability shown above.
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If an established Provider submits a new e-file application for an additional office and compliance issues arise that were not previously addressed with the firm(s)/ individual(s), the new office will not be allowed to participate until all compliance issues are resolved. The TPDS automatically monitors the relationship of Principals, Responsible Officials and firms with their suitability.
-
All correspondence MUST include all EFIN(s) and a statement that "if the decision is made to fail the new EFIN(s), it will affect all associated EFIN(s)" .
-
A Daily Worklist is generated when the IRS receives an issue from the ASAP on a Firm or Individual entity within an e-file application. ASAP results will post as a "Hit" and the issue will be annotated in the ASAP description.
-
Research via IDRS to determine if the EIN/SSN is in compliance.
-
Research to determine all associated EFIN’s for the EIN/SSN in question.
-
Research EFIN comments to see if the issue is already being worked.
-
-
Additional Steps for Daily Worklist
If Fingerprint Status is Then Not on File and professional Status is not passed Move suitability status from "In-Process" to "Incomplete" Not on File and Professional Status is passed Enter in application comments, "Working Entire Case" Not on File and comments indicate that FPC was received over a week ago Bring case to your Lead’s attention In-Process and the worklist item is current Work all other TIN(s) on the application that can be passed, Mark worklist as "Worked" In-Process and the worklist item is "Late Suitability" Reassign worklist to ANSC_Lead_TE Unprocessable Work all other TIN(s) on the application that can be passed, reassign worklist to ANSC_Lead_TE Data Work all other TIN(s) on the application that can be passed, 1. Check fingerprint tab description to ensure results were forwarded to ASDC, if not bring to your Lead’s attention for print and forwarding, reassign worklist to designated employee 2. Check fingerprint tab description, if a specific TE is indicated, reassign worklist item to the applicable assistor. 3. If no specific TE is indicated, reassign to designated employee, Annotate in comments "Reassigned" to (designated employee name) No Data or Not Pulled Enter in application comments "Working Entire Case"
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When fingerprint cards are processed electronically by Automated Electronic Fingerprints (AEF), and data is found, an official Rap Sheet is printed. Clerical will update the RPO Suitability Spreadsheet .
-
Clerks will match the SSN, name and date of birth on the Rap Sheet to the application. If they do not agree, the assistor will research IDRS (e.g. INOLE, NAME, etc.) to verify the applicant.
-
Clerks will use IDRS and cc IMFOL, research the SSN to find any Z or -T freeze codes. This information will be needed to complete the NASDC Referral.
-
Clerks will enter comments on the application comments page and the Fingerprint Cards tab: "Data Forwarded to RPO Suitability. Do Not Pass" and save.
-
Clerks will annotate the active EFIN and SSN on the upper right corner.
-
Repeat for all Rap Sheets with known active EFINs.
-
Clerks will complete the current version of Form 3210, Document Transmittal to include all referrals. Form 3210 will also contain the following information:
-
Subject: FPC (for fingerprint card)
-
To: RPO analyst Group 2
-
Date of message: current date
-
Routing Symbol: Stop 983 (EPSS e-help Desk Andover)
-
Releasing official: (signature and title).
-
-
In the Document Identification area, list the EFIN(s) that are being referred.
-
Clerical staff will maintain the Originator copy of Form 3210 for EPSS records.
-
Put all the sheets with the information and the Form 3210 Document Transmittal in an envelope and address it to RPO analyst Group 2; 401 W Peachtree St Mail Stop 337D Atlanta, GA 30308.
-
RPO Suitability will determine whether the applicant is subject to RPO Suitability criteria (Failed), or not subject to RPO analyst criteria, (Passed). If Failed, RPO Suitability will complete a referral sheet and include the proper terminology for the Fail Letter. RPO Suitability will return the Rap Sheet and Referral back to EPSS Andover.
-
Whether Pass or Fail, the assistor will complete the regular suitability checks on the SSN (and EIN, if applicable). Suitability will be worked as a daily worklist item, and follow procedures in Suitability Procedures After Initial Research (See IRM 3.42.10.23.8, Suitability Procedures for Daily Research), with the following adjustments:
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If RPO analyst recommends pass, and there are no other suitability issues, change all relevant TIN suitability statuses to Passed. Allow automated system to update all other status and issue the acceptance letter.
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If RPO analyst recommends fail, send Letter 2916 SC/CG Denied FBI Research and address all suitability issues. See Exhibit 3.42.10-28.
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If RPO analyst recommend pass, but there are suitability issues, follow suitability procedures and send to Management Review. Issue letter 3479-D.
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Below are the appeal procedures to be followed regarding fingerprint card data.
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Get folder with original Rap Sheet and paperwork.
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Attach a new Fraud Referral Sheet with EFIN, SSN, name of applicant, and Z/-T freeze (if applicable). IRM Exhibit 3.42.10.5 to the appeal and previous paperwork.
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Send to RPO analyst for reconsideration. If no personal information page was included in the first NASDC referral, include it now. If no Z/-T Freeze information was indicated in the first referral, and there is a Z/-T freeze, then the case will go to NASDC and not to RPO analyst.
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Document in TPDS comments, "appeal forwarded to RPO analyst" .
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RPO analyst will review the appeal, and decide whether to pass the applicant or uphold the previous Fail recommendation.
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When the response is received from RPO analyst, complete a First Appeal – Suitability Recommendation sheet (yellow).
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If pass, update TPDS and send pass Letter 2914D: D/OwnAft1S Daily Ltr (After 1st Appeal (Exhibit 3.42.10-25).
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If upholding the fail, send Letter 3062 (SC/CG): Resp to 1st Appeal/Request Denied (Exhibit 3.42.10-34).
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If necessary, send Letter 2913D (SC/CG) Officer & Corp Partner Failed Suit ( Exhibit 3.42.10-23).
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Get folder with original and 1st appeal paperwork.
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This does not go to RPO analyst. It goes to the Office of Appeals.
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Write up on Blue Recommendation Sheet.
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Make complete copy of all paper work and give case to designated Office of Appeals assistor.
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Wait for decision; the ERO will be unable to participate in IRS e-file until a decision is rendered by the Office of Appeals.
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After acceptance into IRS e-file, Providers are subject to periodic suitability check, which is the review of IRS records.
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The checks are performed to determine:
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if all business and personal tax returns are filed ,
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if all tax liabilities are paid or appropriately addressed (e.g., installment agreement) or
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if there are any fraud penalty assessments or
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if there is an open a IRS criminal investigation
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TPDS will provide extracts of taxpayer identification numbers (TINs) that have a suitability status of "Passed" and a Provider status of "Accepted" for more than 90 days. Extracts are run periodically for suitability review purposes.
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Periodic suitability reviews are performed on all TINs in Passed status that are associated with active EFIN(s).
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When ASAP criteria are identified, ASAP results must be manually entered prior to the TIN being manually updated to "recheck" .
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Inquiries such as telephone contact or Letter Of Inquiry (LOI) must be made to determine if the criteria identified in the ASAP report constitutes passing/failing the EFIN(s). All telephone contacts must be documented on the comments section of the e-file application and in the e-help Support System (EHSS).
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Daily suitability checks of all new applicants should be completed within 45 days of submission or receipt of the complete applications and all documentations.
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When the assistor determines the 45 day processing time for e-file applications will not be met, the assistor will send the applicant Letter 2462 (SC/CG) Delay in Processing and Acknowledgement Letter, acknowledging that we received their application and to allow an additional 15 days for processing. Exhibit 3.42.10-63.
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The ASAP program uses criteria from Master File (MF) to determine a Provider's compliance.
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ASAP is used for new/revised applications and periodic suitability review. It analyzes both IMF and BMF data to determine if applicants meet various suitability criteria. ASAP will analyze the valid, invalid and spousal SSN files (SSF).
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ASAP may identify issues that were previously addressed, or new issues may be identified through research that did not originally appear on the ASAP report.
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In either case, the assistor must address all issues with the Provider through either a telephone call or correspondence.
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Review the comments section of the e-file application to see if prior ASAP issues were identified. Historical data file folders must be reviewed for all ASAP reports with literals/Hits to ensure the issue was not previously addressed. If a file folder is not available, a new file folder must be created.
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Some cases contain unusual circumstances such as those involving the North Atlantic Scheme Development Center (NASDC). The appropriate field office or submission processing center function should be contacted to obtain further clarification on these issues. Cases should be referred to the NASDC via the designated assistor. Tax specialists and e-file monitoring coordinators should be contacted ONLY when a suitability issue may have been previously addressed by the respective function.
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An entity code on MF identifies individuals and businesses that participate as EROs, Transmitters, and Reporting Agents, etc. This entity code generates a worklist when specific transactions appear on a tax account that would impact suitability.
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An extract of all TINs subject to suitability in IRS e-file is used to mark the master file account on a biannual basis for IMF and an annual basis for BMF. The system turns this indicator on and off.
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Fraud penalties (TC 320) of any amount for any of the last 6 years.
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Intelligence Hold/Criminal Investigation (Z or -T Freeze).
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Deceased taxpayers, TC 540.
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TC 460 for other than current year or later and no TC 150 present.
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TC 480
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No return posted and MF status 02, 03, and 04 on any of the last 6 tax modules on record. Do Not Work any Valid Extensions.
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Potentially Dangerous Taxpayer (PDT), TC 971 with AC 271 or 272.
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Currently Not Collectable accounts (TC 530) with the following closing codes: 03, 09, 10, 12, 13, and 39.
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The worklists are generated for the specific tax modules affected for each applicant’s account when the suitability criteria are met and include the tax year, MFT code and the dollar amount when applicable.
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The worklists are worked in accordance with periodic suitability processing procedures.
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Worklists MF_TRANS_FIRM_IRS and MF_TRANS_IND_IRS are issue driven, printed on a weekly basis included in Workgroup ANSC_Leads and generated only once per issue. These worklist will be generated on a weekly basis as the information is received. Firm and/or personal suitability will systemically move to "Recheck". ASAP Results will post as a “Hit” and the issue will be notated in the description:
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Research via IDRS to determine if EIN/SSN is in compliance.
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Research EFIN comments to see if the issue has been included in a previous letter sent within the previous 45 days. If letter was issued within 45 days, add comment, "Recheck No Action-already worked" .
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Request EFIN folder if EIN/SSN is non-compliant.
Additional Steps for Worklists MF_TRANS_FIRM_IRS and MF_TRANS_IND_IRS:
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Research to determine all associated EFIN’s for the EIN/SSN in question.
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If the ERO is in compliance, enter ASAP results "No Hit" and TPDS comments "no hit from IMF (BMF) worklist" .
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Move suitability status to "pass"
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Notate in "ASAP Comments" which EFIN the Letter of Inquiry (LOI) was generated from.
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Manually update firm and/or Personal Suitability to ‘Re-check’ if LOI is to be issued.
Note:
If the Firm has suitability issues, only update the Firm suitability to recheck.
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If LOI is issued, up to two EFIN(s) may be listed on the Letter 3479(CG) (If there are more than two EFIN(s), the letter should be worded xxxxxx and all associated EFIN(s). When two gray boxes appear, select OK both times and the letter will print.
Note:
If Z or -T freeze is identified and it is a new issue or has not been addressed in the previous six months, forward the case to a designated assistor for elevation to North Atlantic Scheme Development Center (NASDC).
If a worklist generates for an issue (ex. balances due, missing return, fraud penalties assessed), and the taxpayer has not received any notice from the IRS, (indicated by status 21). And there are no other issues, do not send the LOI. However, if additional delinquent issues, are discovered by research, then address ALL ISSUES, (include modules with status 21) in the LOI.
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The research tools are:
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The Third Party Data Store
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IDRS, i.g., INOLE (valid and invalid), IMFOL, BMFOL, ENMOD, TXMOD, IRPTR, SUMRY, FFINQ, DDBOL
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Integrated Automation Technologies (IAT)
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Document 6209, ADP and IDRS Information, for explanation of sequence, status, transactions, and indicator codes
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Internal Revenue Manuals
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Research should include but is not limited to:
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Module balances
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Returns filed
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Reversal transaction codes
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Installment agreements
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Freeze codes
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Unpostables
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Offers in Compromise
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Assessment of Fraud penalty
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Bankruptcy
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Currently Not Collectible (CNC)
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Citizenship
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BMF research should also include:
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ENMOD/INOLE to verify the filing requirements for returns listed on ASAP.
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If new/additional issues are identified through ASAP/research, research IDRS. These issues must be addressed in the initial contact, e.g. LOI or telephone call.
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Notate in the description field and application comment page, Pass mini suit per Recheck list. If the "Hit" was previously resolved and no additional issue(s) have been identified, by ASAP during research add comments to indicate "transcript previously worked" .
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When a phone call is made to a Provider with suitability issue(s) and the individual no longer works for the company, request that they revise their application via the Registered User Portal (RUP).
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If the firm is replacing the individual, a FPC may also be necessary. If a FPC is necessary, please have them submit the FPC after revising the application online.
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If a revised application is not received within 30 days, a Letter of Inquiry (LOI) should be sent with a reference made to the telephone conversation.
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Reasonable Cause is based on all the facts and circumstances in each situation.
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The firm(s)/ individual(s) must provide the necessary tax returns, payments and/or information, AND must address reasonable cause concerning each violation/infraction.
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Reasonable cause relief is generally granted when the taxpayer exercises ordinary business care and prudence in determining their tax obligations, but was unable to comply with those obligations.
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Ordinary business care and prudence includes making provisions for business obligations to be met when reasonably foreseeable events occur.
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In determining if the taxpayer exercised ordinary business care and prudence, review available information including taxpayer's reason, compliance history, and circumstances beyond the taxpayer's control.
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Reasonable cause is referenced in IRM 20.1.1.3.2, Penalty Handbook, or Part 21, Customer Account Services.
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If there is a -C (combat zone), -O, or -S (disaster freeze) on an account, this constitutes reasonable cause.
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This process is designed to automate the input of the ASAP results from the compliance check against the IMF and BMF systems. The process records the results received back for each TIN. A worklist item is generated for each TIN where there is a "Hit" received on the results. The suitability status changes to "Passed" for TINs with no "Hits" , and where all supporting documents have been received and passed validation or have no issues, returned back from the FBI check.
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The worklist contains only applicants that have issues identified on their applications, a "Hit" from the ASAP upload, or ASAP results not updated within 14 days from being selected. Note that the persons and organizations that have been selected for ASAP and are In Process, may be on the worklist if the FPC results have not been received, the upload has not received the results back from the PAT50 program, or the assistor is having problems validating the professional credentials received.
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Literals that appear on ASAP reports are based on programmed criteria. Some circumstances such as late filing/paying history are not part of the criteria, but may be considered when other ASAP criteria are present. The following procedures for specific literals/Hits will provide assistance in the resolution of each criterion.
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IRM 3.42.10.23.8 Suitability Procedures After Initial Research, for specific PASS/FAIL instructions to be followed after a decision is made.
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The literals "NO SUITABILITY CHECKS MET AGAINST MF" and/or "NO SUITABILITY CHECKS MET AGAINST SP" will only appear on daily suitability ASAP reports. Verify that the TIN and name control shown on the ASAP report are correct by reviewing the application and IDRS Command Code INOLES.
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Check for pending/posted Offers in Compromise (OIC), TC 480. ASAP will check for TC 480 (offer pending), TC 481 (offer rejected), and TC 482 (offer withdrawn). The assistor will check CC TXMOD, IMFOL, and BMFOL for these transaction codes.
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If an OIC is pending (TC 480) or if an OIC is accepted (TC 780) and no other literal is present, AUTOPASS.
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See IRM 3.42.10.19.7 , Suitability Procedures After Initial Research, for specific PASS/FAIL instructions.