4.15.3  Assessment Procedures (Centralized Case Processing )

Manual Transmittal

September 16, 2011

Purpose

(1) This transmits a complete revision with Table of Contents and text for IRM Part 4.15.3, Jeopardy/Termination Assessments, Assessment Procedures (Centralized Case Processing).

Background

This IRM was renamed to reflect the correct reference to Centralized Case Processing. Also all references to "Case Processing Support" in the text have been updated to "Centralized Case Processing" .

Legal references and form references were reviewed and updated as necessary.

Minor editorial changes have been made throughout this IRM. Other significant changes to this IRM are reflected in the table below:

IRM Description
IRM 4.15.3.2 Deleted example of control number.
IRM 4.15.3.2.1(2) Included cross reference.
IRM 4.15.3.4 Deleted obsolete form.

Material Changes

(1) This transmittal reissues existing procedures. The text has been renumbered and updated as necessary to reflect changes pursuant to the IRS reorganization such as the new organizational names and titles.

Effect on Other Documents

This material supersedes IRM 4.15.3, dated August 16, 2001.

Audience

Small Business and Self-Employed (SB/SE) and Wage and Investment (W&I) employees.

Effective Date

(09-16-2011)

Signed by
Tamera L. Ripperda
Director, Abusive Transactions - Technical Issues (ATTI)

4.15.3.1  (09-13-2011)
Overview

  1. This section establishes procedures for the preparation, assessment, and confirmation of jeopardy/termination assessments.

4.15.3.2  (09-16-2011)
Preparing Assessments

  1. A jeopardy/termination assessment must be approved by the Area Director and Counsel. The assessment must be made on the same day that the jeopardy/termination assessment is approved. Jeopardy/termination assessments will be prepared following quick assessment procedures. See IRM 4.4.25 , Quick Assessments. Quick assessments are made on either master file (MF) or non-master file (NMF). NMF are processed in the same manner as MF, except the numbering is different and abstract codes are needed for individual master file (IMF) and business master file (BMF) adjustments.

  2. Requests for quick assessments will be made by telephone or facsimile. Facsimile should be used if possible. Form 2644 , Recommendation for Jeopardy/Termination Assessment, will be used to request quick assessments, in addition to Form 2859 , Request for Quick or Prompt Assessment.

    IF the request is made by: THEN provide the following information:
    Telephone 1.  Affirmative statement that the Area Director approved Form 2644;
    2.  Name, address, and TIN of the taxpayer;
    3.  Type of tax;
    4.  Taxable period;
    5.  Amount of tax, penalties with the appropriate transaction code(s), interest to be assessed, credit adjustments and/or reference numbers;
    6.  Amount of payment, if any, the balance due, 23C date; and
    7.  Document locator number (DLN).
    Facsimile 1.  Form 2859 for each type of tax return, with a control number; and
    2.  Form 3210, Document Transmittal Form, for each type of tax return. Include the name control, MFT, TIN, Tax period, and Control number. In the remarks area, enter the 23C date and "FAX QUICK ASSESSMENT." Address the form to the appropriate function and include the originator's complete address, mail stop, and fax number so the receipted Form 3210 can be faxed back.

4.15.3.2.1  (09-16-2011)
Information Transmitted

  1. The quick assessment is transmitted to the Cincinnati Campus Accounting and Control Operation, AMA Team.. Only Centralized Case Processing will transmit the quick assessment.

  2. Faxing should be done only once each day, if possible, and prior to 1:30 p.m. EST. If there are numerous entities and returns, the information should be transmitted as early as possible.

    Note:

    If two work days or less remain before the statute of limitations will expire, follow telephonic quick assessment procedures.

    See IRM 5.1.4.4, Quick Assessment and IRC 6871.

4.15.3.2.2  (09-16-2011)
How Assessment is Made

  1. The assessment is made according to the type of assessment.

  2. Jeopardy — Assessment is made on MF for the full period.

  3. Termination — Assessment is made on NMF as a short period, even though the period may be a full period. It is made as a short period to differentiate between the termination period and the full period under normal filing requirements.

  4. Possessor of Cash — The possessor of cash assessment is made as either a jeopardy or termination assessment, as noted above. A new taxable entity and temporary TIN is created for possessor of cash assessments.

    1. New Taxable Entity — A new taxable entity (dummy file) is created for the individual who is in physical possession of the cash. All documents requiring entity information must use "(Possessor's Name) as Possessor of Certain Cash" as the name line.

    2. Temporary TIN — A temporary TIN must be obtained for all assessments made under IRC 6867 irrespective of information indicating the possessor's personal TIN. Contact the campus entity function to obtain a temporary TIN. The use of the temporary TIN will enable separate tax liability treatment for the possessed cash and avoid any effect on the possessor's personal individual tax liability, which remains separate from the IRC 6867 assessment.

4.15.3.3  (09-16-2011)
Assessing Amounts

  1. After the jeopardy/termination assessment information is transmitted to the campus, the campus will process the assessment. The campus will provide Centralized Case Processing with the required information that the assessment was made.

  2. Campus Action — The campus will process the assessment and notify the Area of the DLN and Form 23C,Certificate of Assessment - Summary Record of Assessments data. This information will be placed on Form 2644 and Form 2859.

  3. Centralized Case Processing Action — After the assessment is made by the campus, Centralized Case Processing will forward the originals to the campus and return one copy of Form 2644 to the examiner.

  4. After the assessment is processed by the campus and the DLN and 23C data have been placed on Form 2644 and Form 2859, the following items will be forwarded within one day to the campus Accounting Operation, Accounting and Control Services, RACS Team.

    • Original Form 2644;

    • Original Form 2859;

    • Original Form 3198, Special Handling Notice for Examination Case Processing that has already been prepared by the agent;

    • Copy of Form 943-A,Income Tax Discrepancy Adjustments ,portion of the Tax Computation; and

    • Copy of narrative.

  5. A copy of Form 2644 , with the DLN and 23C data, will be returned to the examiner responsible for the jeopardy/termination assessment.

4.15.3.4  (09-16-2011)
Confirming Assessment

  1. After the jeopardy/termination assessment is processed by the campus, the campus will provide Centralized Case Processing with confirmation that the assessment has been made.

  2. The campus will provide Centralized Case Processing with a confirmation copy of the MF or NMF assessment.

  3. Master file Assessment — A confirmation copy of Form 3552, Prompt Assessment Billing Assembly, is mailed to the area office by the campus after processing. The form must be associated with the control copy in Centralized Case Processing .

  4. Non-master file assessment — A confirmation copy of Form 6335, NMF First Notice is mailed to the area office by the campus after processing. The form must be associated with the control copy in Centralized Case Processing .

  5. Upon receipt of Form 3552 or Form 6335 in Centralized Case Processing , the form will be reviewed to verify that the assessment has been made. Verify the name, address, TIN, and tax period on Form 3552 or Form 6335 for consistency with Form 2859.

  6. The statute control examiner will be notified in order to close the case from the open statute control file.

  7. Upon request, the campus will withhold manual and/or computer billing.

  8. Verification Errors — If any errors are detected in Form 3552 or Form 6335, immediately contact the campus for issuance of a corrected bill. If verification of the assessment is not received, the Centralized Case Processing Manager, or designated employee must follow-up with the campus.

  9. Follow-up will be done in sufficient time to prevent barred assessments.

  10. Follow-up will be done three weeks from the 23C assessment date for non-statute assessments.


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