4.29.5  PCS TEFRA/NonTEFRA Notices and Cover Letters

4.29.5.1  (09-02-2008)
TEFRA Notices

  1. PCS generates all TEFRA notices to TEFRA notice investors.

  2. Procedures for processing these notices are contained in IRM 4.31, Flow-Through Entity Handbook.

4.29.5.2  (01-01-2004)
TEFRA Notice Generation (TSLOD and TSNOT)

  1. The sub-sections below discuss the various notices required by the statute, and the various notices provided for administrative proceedings.

  2. PCS command codes TSLOD and TSNOT are used to generate notices. CC TSLOD is used to establish investors on the PCS database, and will generate a Notice of Beginning of Administrative Proceeding (NBAP) with the proper definer. CC TSNOT will generate a variety of notices depending on the definer used. The generation of the different notices is explained in the following sub-sections.

4.29.5.2.1  (03-01-2006)
General Information on Notices and Form 886–Z(C) Investor Listing

  1. Form 8342, PCS Notice Generation, is used to generate TEFRA investor notices (60-Day Letters, FPAAs, FSAAs (does not apply to S corporation tax years beginning after December 31, 1996), and Appeals Settlement Letters (does not apply to S corporation tax years beginning after December 31, 1996).

    1. Exhibit 4.29.5-2 ( See Exhibit 4.29.5-2. ), Instructions for Form 8342, PCS Notice Generation, provides instructions for completing Form 8342.

    2. To generate notices, the key case and investor records must both be present on PCS.

    3. In addition, the investor must be linked to the TEFRA key case and the investor’s TEFRA indicator must be present.

    4. If there is a one-year assessment statute date present on the linkage, a letter will not generate for the investor.

  2. Notices and forms which can be generated by PCS are:

    1. Notice of Beginning of Administrative Proceeding (NBAP),

    2. 60-Day Letter (investor settlement package),

    3. Final Partnership Administrative Adjustments (FPAA) or S Corporation (FSAA). (Does not apply to S corporation tax years beginning after December 31, 1996),

    4. Appeals Settlement Letter for non-docketed cases with affected items, to all linked investors (does not apply to S corporation tax years beginning after December 31, 1996),

    5. Appeals Settlement Letter for non-docketed cases, to all TEFRA linked investors (does not apply to S corporation tax years beginning after December 31, 1996),

    6. Appeals Settlement Letter for docketed cases (does not apply to S corporation tax years beginning after December 31, 1996),

    7. Form 886-Z(C),

    8. TMP Settlement Letter

    9. Notification of beginning of nonTEFRA flow-through entity audit, and

    10. AAR 60-Day Objection Letter

  3. Exhibit 4.29.5-1, TEFRA Output Generated by the PCS, See Exhibit 4.29.5-1.( Form 8340 and Form 8342)

4.29.5.2.2  (09-02-2008)
Notice of Beginning of Administrative Proceeding (NBAP)

  1. The NBAP is a letter which notifies each notice investor or notice group that the TEFRA key case is under examination. It is generated via CC TSLODK ( Form 8340) using information on the Schedules K-1.

  2. Input of CC TSLODK generates:

    1. Letter 1787(SC) for partnership investors

    2. Form 886-Z(C), Partners’ or S Corporation Shareholders’ Shares of Income,

    3. A certified mail listing. (Prior to Chief Counsel’s recommendation to send NBAPs by certified mail, a Certification of NBAP Notices, listing investors to whom NBAP letters were sent, was generated by the PCS.)

    4. A cover sheet necessary for certified mailing.

  3. After the partnership is established on PCS, TSCHG must be used to add the address of the partnership. The address is needed for the generation of investor NBAP's. TSCHG items 31, 32 and 33 will be used to enter the partnership address information.

  4. Review all NBAP's to insure the partnership address was correctly printed within the body of the letter. If no address was printed, it must be typed in manually.

  5. The NBAP notices are sent by certified mail. The TSLOD generates three Certified Mail Lists:

    1. Version A (two copies): One listing is sent to the area or Appeals Processing Manager as proof of mailing of the notices. The other listing is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed. ( See Exhibit 4.29.5-3.)

    2. Version B (one copy): This list is certified by the post office and returned to the CTF as proof of certified mailing. ( See Exhibit 4.29.5-4 Cont.) The certified copy is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed.

  6. Three copies of the letter, (2)(a) above, are generated for each notice investor. Two copies of an NBAP must be mailed to the investor, and one copy is filed in the key case administrative file.

  7. Three copies of the Form 886-Z(C) are sent to the area office PCS Coordinator, and one copy is filed in the key case administrative file.

4.29.5.2.3  (04-01-2007)
60 Day Letter

  1. The 60-Day Letter is generated by input of CC TSNOT, notice type 2.

  2. Letters and forms generated for partnership investors are:

    1. Letter 1829(SC), and

    2. Form 870-LT, Agreement to Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax, and Additional Amounts and Agreement for Affected Items. ( Form 870–L for key case partnership tax years ending before August 6, 1997.)

    3. Letter 1827(SC), and

    4. Form 870-PT, Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts. ( Form 870–P, for key case partnership tax years ending before August 6, 1997.)

  3. Forms 870-L/LT/P/PT generated with a 60-Day Letter will have " 60" displayed in the upper left hand corner, to denote that the agreement form was generated with a 60-day letter.

    Note:

    The generation of the correct notice is dependent upon the tax year end and the input of the penalty/affected item code on the key case record. Below is a table explaining when each notice will be generated:

    P/AI Code Package type Notices and Attachments for Tax Year Ending Before 8-6-97 Notices and Attachments for Tax Years Ending After 8-5-97
        870–P 870–L Attach- ment 870–PT 870–LT Attach- ment
    "Blank" 60 Day X   N/A X   N/A
    FPAA X   N/A X   N/A
    A 60 Day   X N/A   X N/A
    FPAA X   E X   E
    P 60 Day   X N/A X   N/A
    FPAA X   D X   D
    X 60 Day   X N/A   X N/A
    FPAA X   D X   E
    D Entered when changing TEFRA Penalty/Affected Item code from one designation to another. The D removes the current designation, and allows a new designation to be entered. See IRM 4.29.3.4.8

    Note:

    IRM 4.29.3.4.8(8) explains the attachments.

  4. Letters and forms are generated for S corporation investors, with or without the penalty/affected item code on the key case record:

    1. Letter 1834 (SC), (does not apply to S corporation tax years beginning after December 31, 1996), and

    2. Form 870-S, Agreement to Assessment and Collection of Deficiency in Tax for S Corporation Adjustments, (does not apply to S corporation tax years beginning after December 31, 1996).

  5. This notice is issued upon receipt of a 60-day Letter TMP package from the area office PCS Coordinator.

  6. Three copies of the 60-day Letter package are generated for each investor. Two copies are mailed to the investor, one is a customer service in case the taxpayer requests a conference, and one copy is filed in the key case administrative file.

  7. Two copies of the 60-Day Letter Certification List are generated. One copy is sent to the area office PCS Coordinator, and one copy is filed in the key case administrative file, ( See Exhibit 4.29.5-5).

4.29.5.2.4  (04-01-2007)
Notice of Final Partnership Administrative Adjustment (FPAA)

  1. The FPAA is generated by input of CC TSNOT, notice type 3.

  2. A separate spousal notice is generated on jointly filed returns. The spousal notice is generated based upon there being a spousal record on the TIF file.

  3. The letters and forms generated for partnership investors are:

    1. Letter 1830,

    2. Form 870-PT ( Form 870-P for key case partnership tax years ending before August 6, 1997), and

    3. The appropriate attachment as required if the key case penalty/affected item notice code is on.

  4. Forms 870-P/PT generated with an FPAA will have "FP" displayed in the upper left hand corner, to denote that the agreement form was generated with an FPAA.

    Note:

    The attachments are provided to notify taxpayers of pending partner level penalties, affected items, or both.

  5. The letters and forms generated for S corporation investors (does not apply to S corporation tax years beginning after December 31, 1996) are:

    1. Letter 1828(SC), and

    2. Form 870–S.

    Note:

    For S corporation tax years beginning after December 31, 1996, TEFRA procedures do not apply so the form and letter above do not apply.

  6. Three copies of each FPAA or FSAA (does not apply to S corporation tax years beginning after December 31, 1996), Form 870–P (for key case partnership tax years ending before August 6, 1997), Form 870–PT or Form 870–S (does not apply to S corporation tax years beginning after December 31, 1996) and any applicable attachments are generated for each investor. Two copies are mailed to the investor, one as a customer service in case the taxpayer files a petition, and one copy is filed in the key case administrative file.

  7. The FPAA notices are sent by certified mail. Input of CC TSNOT, notice type 3, also generates three Certified Mail Lists:

    1. Version A (two copies): One listing is sent to the area or Appeals Processing Manager as proof of mailing of the notices. The other list is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed. ( See Exhibit 4.29.5-6.)

    2. Version B (one copy): This list is certified by the post office and returned to the CTF as proof of certified mailing. ( See Exhibit 4.29.5-7.) The certified list is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed.

  8. A cover sheet is necessary for certified mailing.

4.29.5.2.5  (01-01-2004)
Letter 2064 - No Change FPAA

  1. The No Change FPAA is generated by input of CC TSNOT, notice type 9.

  2. A Letter 2064 will be generated for each partner.

  3. The no change FPAA is generally used to no-change a TEFRA case after the initial 45 day period. It is also used when a taxpayer believes there are adjustments in their favor, but the Service does not agree. The No-Change FPAA allows the taxpayer to petition the court regarding the adjustments.

4.29.5.2.6  (01-01-2003)
Electing Large Partnership – Final Notice

  1. For an electing large partnership a Notice of Partnership Adjustment is the final document instead of a Final Partnership Administrative Adjustment.

4.29.5.2.7  (09-02-2008)
Appeals Settlement Letter for non-Docketed Cases with Affected Items to ALL Linked Investors

  1. The Appeals Settlement Letter to all linked investors in a TEFRA partnership is generated by input of CC TSNOT, notice type 4.

  2. Letters and forms generated for partnership investors are:

    1. Letter 3394(CG), Transmittal Letter for Form 870-L(AD) and Form 870-LT(AD) for nondocketed TEFRA partnership cases, and

    2. Form 870-LT(AD), Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, and Agreement for Affected Items, ( Form 870–L(AD) for key case partnership tax years ending before August 6, 1997.)

    Note:

    The generation of the correct notice is dependent upon the input of the penalty/affected item code on the key case record. In the 60 day section above is a table explaining when each notice will be generated. See IRM 4.29.5.2.3.

  3. This notice is issued upon receipt of a TMP package and request to issue the settlement letter from the Appeals office.

  4. Three copies of each letter package are generated. Two copies are mailed to the investor and one copy is filed in the key case administrative file.

  5. Two copies of the Appeals Letter Certification List are also generated. One copy is sent to the Appeals office Appeals Processing Manager for the Appeals office that has the key case, and one copy is filed in the key case administrative file.

4.29.5.2.8  (03-01-2006)
Appeals Settlement Letter for Non-Docketed Cases to All TEFRA Linked Investors

  1. Appeals Settlement Letters to all linked investors with a TEFRA indicator present on the linkage record are generated by input of CC TSNOT, notice type 5.

  2. Letters and forms generated to partnership investors are:

    1. Letter 3395(CG), Transmittal Letter for Form 870-P (AD) and Form 870-PT (AD) for nondocketed TEFRA partnership cases, and

    2. Form 870-PT (AD) Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, . ( Form 870-P (AD) for key case partnership tax years ending before August 6, 1997.).

    Note:

    The letter and forms generated depends on the penalty/affected item code input on the system. See IRM 4.29.3.4.8 for further explanation. IRM 4.29.3.4.8, and the related chart, references Exam letters and forms but applies equally to Appeals letters and forms.

  3. Letters and forms generated to S corporation investors are:

    1. Letter 2608 (CG), Transmittal Letter for Form 870-S(AD) for nondocketed TEFRA corporation cases (does not apply to S corporation tax years beginning after December 31, 1996), and

    2. Form 870-S(AD), Settlement Agreement for S Corporation Adjustments, (does not apply to S corporation tax years beginning after December 31, 1996).

    Note:

    The letter and forms generated depends on the penalty/affected item code input on the system. See IRM 4.29.3.4.8 for further explanation. IRM 4.29.3.4.8, and the related chart, references Exam letters and forms but applies equally to Appeals letters and forms.

  4. This notice is generated upon receipt of a TMP package and request from the Appeals office.

  5. Three copies of each letter package are generated for each investor. Two copies are mailed to the investor, and one copy is filed in the key case administrative file.

  6. Two copies of the Appeals Letter Certification List are generated. One copy is sent to the Appeals office Appeals Processing Manager for the Appeals office that has the key case, and one copy is filed in the key case administrative file.

4.29.5.2.9  (09-02-2008)
Appeals Settlement Letters for Docketed Cases

  1. The Appeals Settlement Letter for docketed cases to all investors is generated by input of CC TSNOT, notice type 6.

  2. Letters and forms generated for partnership investors are:

    1. Letter 2607 (CG), Transmittal Letter for Form 870-L (AD) and Form 870-LT (AD) for docketed TEFRA partnership cases, and

    2. Form 870-LT (AD), Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, and Agreement for Affected Items ( Form 870-L (AD) for key case partnership tax years ending before August 6, 1997.),

    3. Letter 2606 (CG), Transmittal Letter for Form 870-P (AD) and Form 870-PT (AD) for docketed TEFRA partnership cases, and

    4. Form 870-PT (AD) Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, ( Form 870-P (AD) for key case partnership tax years ending before August 6, 1997).

    Note:

    The letter and forms generated depends on the penalty/affected item code input on the system. See IRM 4.29.3.4.8 for further explanation. IRM 4.29.3.4.8, and the related chart, references Exam letters and forms but applies equally to Appeals letters and forms.

  3. Three copies of each letter package are generated for each investor. Two copies are mailed to the investor, and one copy is filed in the key case administrative file.

  4. Two copies of the Appeals Letter Certification List are generated. One copy is sent to the Appeals Processing Manager for the Appeals office that has the key case, and one copy is filed in the key case administrative file.

  5. The docket number and TMP name and address must be present on the key case record for PCS to accept a request for notice type 6. It is extremely important that the literal "Tax Matters Partner" is NOT included as part of the TMP name.

    Note:

    The term Tax Matters Person was used with S corporations for tax years that began before January 1, 1997.

4.29.5.2.10  (03-01-2006)
Schedule of Adjustments

  1. The functionality of generating the schedule of adjustments via PCS has been removed. The campus should use a copy of the schedule of adjustments provided by the field when sending notices to investors. Sending the copy eliminates any transcription errors that can occur when inputting that data in PCS for the purpose of having PCS generate the schedule.

4.29.5.2.11  (01-01-2003)
Form 886–Z(C), Partners’ Shares of Income

  1. The Form 886-Z(C) is a listing of all investors linked to a particular key case. The form lists each investor with their name, address, TIN, and Schedule K-1 income/loss percentage.

  2. The Form 886-Z(C) is originally generated using CC TSLODK when all investors are initially linked to the key case.

  3. Subsequent Form 886-Z(C) may be generated via TSNOT, notice type Z.

4.29.5.2.12  (04-01-2007)
AAR 60-Day Objection Letter, Letter 3904

  1. Letter 3904 is generated to all investors using notice type " A" .

  2. The Letter 3904 is used when the Tax Matters Partner files an AAR requesting substituted treatment. The law requires all partners be given the opportunity to object to the partnership changes if those changes will result in additional tax to them. The letter is generated to all linked partners. If a partner objects, a determination needs to be made as to whether that partner is subject to an assessment and therefore allowed to object.

  3. See IRM 4.31.4 for more information of substituted AARs.

4.29.5.2.13  (01-01-2004)
TMP Settlement Notification Letter

  1. The TMP Settlement Notification Letter provides the TMP with a list of investors that have entered into a settlement agreement.

  2. The letter and list of investors are generated weekly and includes investors that have had a settlement date input with CC TSCHG during the prior week cycle.

  3. Letter 2513(SC), will generate for partnership key case records. Letter 2514(SC) will generate for S corporation key case records, (does not apply to S corporation tax years that begin after December 31, 1996).

4.29.5.3  (03-01-2006)
NonTEFRA

  1. PCS generates nonTEFRA NBAP notices to all nonTEFRA investors.

  2. Procedures for processing these notices are contained in IRM 4.31, Flow-Through Entity Multi-Functional Handbook.

4.29.5.4  (03-01-2006)
NonTEFRA Notice Generation

  1. The sub-sections below discuss the nonTEFRA letters and consents that can be generated using PCS. PCS now generates letters to investors in a nonTEFRA partnership to notify them of an examination.

4.29.5.4.1  (01-01-2004)
Beginning of NonTEFRA Flow-Through Audit Letters

  1. There are three letters available to notify nonTEFRA investors of an audit of a flow-through entity in which they invested. The three letters are:

    • Letter 3457, Notification of Beginning of Partnership Audit,

    • Letter 3458, Notification of Beginning of S-Corporation Audit,

    • Letter 3459, Notification of Beginning of Trust Audit,

  2. These letters are not required by law, but were created to inform investors when an examination is beginning. This way, the investors first contact from us will not be an audit report or a request to extend the statute.

  3. It is recommended that these letters be issued to all investors controlled by the campuses, and all field controlled investors that may not be aware of the flow-through examination.

  4. These letters are not required by law, and should not be sent by certified mail.

  5. PCS will generate these letters by using TSLODK. TSLODK is used to issue the NBAP on TEFRA investors. PCS recognizes the PICF Code of 2 on the nonTEFRA key case and will generate the Beginning of NonTEFRA Flow-Through Audit letters.

4.29.5.5  (06-13-2005)
Notice Suppression Due to Disaster

  1. PCS will automatically suppress any notices that would normally be generated to investors in a disaster area. Investors in a disaster area receive a disaster code on their module. The disaster code is set based upon the taxpayers zip code.

  2. Notice suppression will not apply to FPAA's (TSNOT3 or TSNOT9).

  3. If TSNOT encounters a disaster code on a partner record, an error condition will occur with "DI" in column 41-42 on the terminal, and a message displayed that a disaster code exists for that partner. Alternately, the operator may over-write the "DI" with " OV" to override the suppression, and TSNOT will then transmit the request. If the disaster suppression indicator is not overridden, a Disaster Notice will be generated to put in the file.

    Note:

    If a TSNOTP is used, the operator will not be given the opportunity to override the notice suppression.

4.29.5.6  (04-01-2007)
Notice Letterhead and Signature Changes

  1. Each notice contains several parameters that can be changed using Form 8346. The Form 8346 is used to change the letterhead and signature information.

  2. Form 8346 is also used to add or change the employee contact information.

  3. The completed form needs to be signed by the person requesting the change, approved by their manager. An ITAMS ticket must then be opened. Once a CAS is designated to resolved the ITAMS ticket, the form can be sent to them.

Exhibit 4.29.5-1  (09-02-2008)
TEFRA Output Generated by the PCS ( Form 8340 and Form 8342 Inputs) (Text 4.29.5.2.1)

Type of Output Input Document Command Code
Investor Notice of Beginning of an Administrative Proceeding Form 8340 and Schedule K-1 TSLODK
—Partnership Letter 1787(SC)    
     
—Form 886-Z(C)    
—Certified Mail Listings    
     
Investor 60-Day Letter Packages: Form 8342 TSNOT2
—Partnership (with penalty) Letter 1829(CG) and Form 870-LT or Form 870–L for key case tax years ending before August 6, 1997    
—Partnership (without penalty) Letter 1827(CG) and Form 870-PT/870-P    
—Reserved    
Certification of 60-Day Letters    
     
Investor FPAA Packages: Form 8342 TSNOT3
—Partnership Letter 1830(CG) and Form 870-PT/Form 870-P    
—Attachments A, P or X, if applicable    
—Certified Mail Listings    
     
Appeals Settlement Letter for Non-Docketed Cases with affected items to all linked investors Form 8342 TSNOT4
—Partnership with Penalty Letter 3394 & Form 870-L(AD) or Form 870-LT(AD)    
—Appeals Letter Certification List    
     
Appeals Settlement Letter for Non-Docketed Cases to all TEFRA linked investors Form 8342 TSNOT5
—Partnership Letter 3395 and Form 870-PT(AD) or 870-P(AD)    
—Reserved    
—Certification List    
     
Appeals Settlement Letter for Docketed Cases Form 8342 TSNOT6
—Partnership (with penalty/affected items) Letter 2607 & Form 870-LT(AD) or 870-L(AD)    
—Partnership Letter 2606 & Form 870-PT(AD) or 870-P(AD)    
—Reserved    
—Certification List    
     
No Change FPAA Form 8342 TSNOT9
---Letter 2064    
     
AAR 60-day Objection Letter Form 8342 TSNOTA
---Letter 3904    
     
Form 886-Z(C) Form 8342 TSNOTZ
     

Exhibit 4.29.5-2  (04-01-2007)
Instructions for Form 8342, PCS Notice Generation (Text 4.29.5.2.1)

Item Title of Item Instructions
Part A—Key Case Entity
2 TIN Enter the taxpayer identification number. If the key case is established on non-Master File , indicate one of the following after the TIN: N = non-Master File; —D = Dummy TIN
3 MFT Enter the MFT Code
4 Tax Period Enter the TXPD in "YYYYMM" format
5 Notices to be Issued Enter "P" if notices will be issued to all investors. Enter "I" if notices will be issued to investors specified in Part B only
6 Notice Type Enter 2 for 60 day letter
    Enter 3 for FPAA (or FSAA) (does not apply to S corporation tax years ending after December 31, 1996)
    Enter 4 for Appeals settlement letter to all linked investors
    Enter 5 for Appeals settlement letter to all TEFRA linked investors
    Enter 6 for Appeals settlement offers for docketed cases
    Enter 9 for generation of No Change FPAA, Letter 2064.
    Enter A for generation of an AAR 60-day Objection Letter, Letter 3904
    Enter Z to generate Form 886–Z(C)
7 Employee Indicator (IRM 4.29.3.5.11) Three character field - (ANN) Must enter a "B" or an "O" in the alpha field to designate the campus where the notices will be printed. Two numeric characters may be entered (01-99) to generate specific contact information on the letter. If no number is entered, 99 will be used for default contact information.
Part B—Related Investor
THIS PART WILL BE COMPLETED ONLY IF "I" IS SPECIFIED IN ITEM 5
8 TIN Enter the taxpayer identification number. If the investor is established on non-Master File , indicate one of the following after the TIN: N = non-Master File; —D = Dummy TIN
9 MFT Enter the MFT Code
10 Tax Period Enter the TXPD in "YYYYMM" format
     
11 Requestor Name Enter requestor's name
12 PBC Enter requestor's PBC
13 EGC Enter requestor's EGC
14 Approved by Enter team leader's name
15 Title Enter team leader's title
16 Signature Requestor's signature
17 Date Date signed by requestor
18 Signature Team leader's signature
19 Date Date signed by team leader
20 Name of Input Operator Enter name of input operator
21 Title Enter input operator's title
22 Signature Input operator's signature
23 Date Date form is input by operator

Exhibit 4.29.5-3  (01-01-2004)
NBAP Certified Mail Listing A (Text 4.29.5.2.2)

Name and Address of Sender
     
Department of the Treasury    
Internal Revenue Service    
(Brookhaven or Ogden) Campus, Campus TEFRA Function
    Date 11–12–2000
Internal Revenue Service Campus
P.O. Box ____ (Stop_____)    
__________,________ 12345–6789
     
A Notice of Beginning of Administrative Proceeding (NBAP) for the year(s) indicated below was sent to the following taxpayer(s):
(Postage Fee Paid by IRS)    
Number of Article   Remarks
Manual Re-Write, LLC. 06 9512 11–1111111
     
103 P-903–320–733 Carl E. Flower 123–45–6789
  2 Field Lane  
  Veggie, NY 12345 1995
     
104 P-903–320–734 Phil O. Buster 987–65–4321
  3 Constitution Avenue  
  Verbal, OH 12354 1995
     
104 P-903–320–735 George A. Peach 321–45–6789
  Orchard Lane  
  Farm Acres, GA 12344 1995
     
Total No. of Pieces Total No. of Pieces Postmaster (per Name of
Listed by Sender Received at P.O. Receiving Employee)
     
__3___ ______ _________________
    Date:_____________

Exhibit 4.29.5-4  (01-01-2004)
NBAP Certified Mail Listing B (Text 4.29.5.2.2)

Name and Address of Sender
     
Department of the Treasury
Internal Revenue Service    
(Brookhaven or Ogden) Campus, Campus TEFRA Function
    Date 11–12–2007
Internal Revenue Service Campus
P.O. Box ____ (Stop_____)
__________,________ 12345–6789
     
A Notice of Beginning of Administrative Proceeding (NBAP) for the year(s) indicated below was sent to the following taxpayer(s):
(Postage Fee Paid by IRS)    
Number of Article   Remarks
Manual Re-Write, LLC. 06 9512 11–1111111
     
103 P-903–320–733 Carl E. Flower  
  2 Field Lane  
  Veggie, NY 12345 1995
     
104 P-903–320–734 Phil O. Buster  
  3 Constitution Avenue  
  Verbal, OH 12354 1995
     
104 P-903–320–735 George A. Peach  
  Orchard Lane  
  Farm Acres, GA 12344 1995
     
Total No. of Pieces Total No. of Pieces Postmaster (per Name of
Listed by Sender Received at P.O. Receiving Employee)
     
__3___ ______ _________________
    Date:_____________

Exhibit 4.29.5-5  (01-01-2004)
Certification of 60–Day Letters (Text 4.29.5.2.3)

CERTIFICATION OF 60–DAY LETTERS   11–04–2007
     
Number of Article   Remarks
Manual Re-Write, LLC. 06 9512 11–1111111
     
04 Carl E. Flower 123–45–6789
  2 Field Lane  
  Veggie, NY 12345  
     
05 Phil O. Buster 987–65–4321
  3 Constitution Avenue  
  Verbal, OH 12354  
     
06 George A. Peach 321–45–6789
  Orchard Lane  
  Farm Acres, GA 12344  
     
Total Count of 60–Day Letters for Flow-Through: 3
     
Above Letters Mailed:    
Signature:_______________
Title:___________________
Date:___________________

Exhibit 4.29.5-6  (01-01-2004)
FPAA Certified Mail Listing A (Text 4.29.5.2.4)

Name and Address of Sender
     
Department of the Treasury
Internal Revenue Service    
(Brookhaven or Ogden) Campus, Campus TEFRA Function
    Date 11–12–2007
Internal Revenue Service Campus
P.O. Box ____ (Stop_____)
__________,________ 12345–6789
     
A Final Partnership Administrative Adjustment (FPAA) for the year(s) indicated below was sent to the following taxpayer(s):
(Postage Fee Paid by IRS)    
Number of Article   Remarks
Manual Re-Write, LLC. 06 9512 11–1111111
     
103 P-903–320–733 Carl E. Flower 123–45–6789
  2 Field Lane  
  Veggie, NY 12345 1995
     
104 P-903–320–734 Phil O. Buster 987–65–4321
  3 Constitution Avenue  
  Verbal, OH 12354 1995
     
104 P-903–320–735 George A. Peach 321–45–6789
  Orchard Lane  
  Farm Acres, GA 12344 1995
     
Total No. of Pieces Total No. of Pieces Postmaster (per Name of
Listed by Sender Received at P.O. Receiving Employee)
     
__3___ ______ _________________
    Date:_____________

Exhibit 4.29.5-7  (01-01-2004)
FPAA Certified Mail Listing B (Text 4.29.5.2.4)

Name and Address of Sender
     
Department of the Treasury
Internal Revenue Service    
(Brookhaven or Ogden) Campus, Campus TEFRA Function
    Date 11–12–2007
Internal Revenue Service Campus
P.O. Box ____ (Stop_____)
__________,________ 12345–6789
     
A Final Partnership Administrative Adjustment (FPAA) for the year(s) indicated below was sent to the following taxpayer(s):
(Postage Fee Paid by IRS)    
Number of Article   Remarks
Manual Re-Write, LLC. 06 9512 11–1111111
     
103 P-903–320–733 Carl E. Flower  
  2 Field Lane  
  Veggie, NY 12345 1995
     
104 P-903–320–734 Phil O. Buster  
  3 Constitution Avenue  
  Verbal, OH 12354 1995
     
104 P-903–320–735 George A. Peach  
  Orchard Lane  
  Farm Acres, GA 12344 1995
     
Total No. of Pieces Total No. of Pieces Postmaster (per Name of
Listed by Sender Received at P.O. Receiving Employee)
     
__3___ ______ _________________
    Date:_____________

Exhibit 4.29.5-8  (06-13-2005)
Instructions for Form 8346, Notice Parameters

Item Title of Item Instructions
A. Letterhead Information
1 IRS Signature Name 35 positions. The first position must be "B" , followed by the name of the signing official
2 IRS Signature Title 40 positions. The first position must be "C" , followed by the title of the signing official.
3&4 IRS Address Line 70 positions. The first position must be "D" , followed by the complete return address.
B. Employee Contact Information
5 Employee Indicator 4 positions. The first position must be "1" . The second position must be "B" if the employee resides at the Brookhaven campus, or "O" if the employee resides at the Ogden campus. Positions 3 and 4 are the employees assigned identification number for purposes of generating their contact information on the letters. Each campus must use 99 for default contact information.
6 Employee Name 35 positions. Entry of the employee name begins in position 5 of line beginning with "1" in position 1.
7 Employee ID Number 15 positions. Entry begins in position 40 of line beginning with "1" in position 1. This is were the employee enters their badge number.
8 Mail Stop 13 positions. Entry begins in position 55 of line beginning with "1" in position 1.
9 Employee Office Hours 35 positions. The first position must be "2" .
10 Employee Phone Number 24 positions. Entry begins in position 37 of line beginning with "2" in position 1.
11 Name of Requester Name of person requesting changes.
12 PBC Requester's Primary Business Code.
13 EGC Requester's Employee Group Code.
14 Signature Requester's Signature
15 Date Date the form is signed by the requester.
16 Approved by Name of approving official. Either the employees manager, the local campus PCS Coordinator, or both.
17 Title The title of the approving official.
18 Signature The signature of the approving official.
19 Date Date the form is signed by the approving official.
20 Name of Input Operator Name of the MITS employee inputting the change.
21 Title Title of the Input Operator.
22 Signature The signature of the input operator.
23 Date Date the information is input on the system.

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