5.7.10  Control Point Monitoring (CPM) Trust Fund Recovery Penalty (TFRP) Case Processing

Manual Transmittal

March 15, 2013

Purpose

(1) This transmits revised IRM 5.7.10, Control Point Monitoring (CPM) Trust Fund Recovery Penalty (TFRP) Case Processing.

Material Changes

(1) Minor editorial changes have been made throughout the text.

(2) IRM 5.7.10.2(2) updated to provide guidance to print missing ATFR or ICS case histories and to review the ICS history to determine if the reason a missing core documentation item is not included was addressed by revenue officer.

(3) IRM 5.7.10.2(4) updated to provide guidance that CPM is accountable for ensuring the documents required for an assessment are present, but the revenue officer and group manager are responsible for decisions regarding the willfulness and responsibility factors of the assessment.

(4) IRM 5.7.10.6(2) updated to provide guidance to CPM to review TC 130 on cases returned from Appeals as non-sustained.

(5) IRM Exhibit 5.7.10-1 updated the TFRP Case File Check sheet.

Effect on Other Documents

This material supersedes IRM 5.7.10, dated May 3, 2010. This IRM revision incorporates Collection Interim Guidance Memorandums SBSE-05-0312-030, Interim Guidance for Trust Fund Recovery Penalty Case Review and Processing by Advisory,dated 3/16/2012, and Control Point Monitoring and SB-SE-05-0812-062, Interim Guidance for Ex Parte Communication with Appeals, dated 8/20/2012.

Audience

AI Advisory - Control Point Monitoring Employees

Effective Date

(03-15-2013)

Scott Reisher
Director, Collection Policy

5.7.10.1  (05-03-2010)
Introduction

  1. The Automated Trust Fund Recovery (ATFR) program is a National Standard Application used to control Trust Fund Recovery Penalty (TFRP) case inventories. Control Point Monitoring (CPM) is one of three components of the ATFR program. The CPM component of the program, located in Advisory, is responsible for ensuring that TFRP case files are complete and accurate, the Assessment Statute Expiration Dates (ASED) are protected, and the final disposition of the case has been accurately recorded on the ATFR system.

    The ATFR CPM Inventory consists of four separate inventories:

    • "Pending" - Cases transmitted to CPM which are awaiting receipt of the TFRP case files.

    • "Accepted" – Case file has been received and accepted for review.

    • "2749 to SC" – Case file has been reviewed and transmitted to the campus for assessment.

    • "Appeals" – Case file has been reviewed and forwarded to Appeals.

  2. CPM has the ability to record the following information:

    • Processing dates for Form 2749, Request for Trust Fund Recovery Penalty Assessment(s)

    • Appeals case information

    • Date TFRP package is sent to Federal Records Center (FRC)

    • TFRP assessment information

    • Closed TFRP file requests

5.7.10.1.1  (05-03-2010)
Initial Case Receipt and Processing

  1. Cases are systemically added to the CPM inventory in Advisory after the Revenue officer (RO) selects "2749 to CPM" to dispose of the responsible person’s file. Upon receipt of the physical TFRP file, Advisory will:

    • Acknowledge Form 3210, Document Transmittal.

    • Attach the required "Case File Review Sheet" (See IRM Exhibit 5.7.10-1, TFRP CASE FILE CHECK SHEET for Review of TFRP Case Files.).

    • Review the ATFR CPM "Pending" inventory and accept the case into the CPM "Accepted" inventory.

  2. If the case does not appear in the "Pending" inventory, check ATFR using the "Find" option, to determine if the "2749 to CPM" date has been entered.

    1. If the date has not been entered, CPM will contact the RO by phone or E-mail requesting input of the "2749 to CPM" date. Allow five business days for the RO to take the requested action. If the date is not entered within five business days of the request, return the case to the RO by preparing an "Information Only" Form 5942, Reviewer's Report - Technical Services Advisory, to the RO Group Manager (GM) with a copy to the Field Collection (FC) Territory Manager (TM).

      NOTE: If there are less than 30 calendar days remaining on the ASED, the RO must prepare a quick assessment before resubmitting the case. Include the imminent ASED and the requirement that the RO prepare a quick assessment on the Form 5942 to ensure the FC territory manager and group manager are aware of the situation. Returning the physical case file with a copy of the Form 5942 to the RO will allow the RO to take the necessary action in a timely fashion.

    2. Check your ATFR Employee control to determine if this RO has been input to your CPM "Employee Control Structure" . If the RO is not listed in your "Employee Control Structure" , verify that you are responsible for the RO and add the RO to your control structure.

  3. If you identify a case in "Pending" inventory, and determine that the originating RO is not assigned to you, contact the appropriate CPM to ensure that the RO is reflected in the correct CPM "Employee Control Structure" . Once the appropriate CPM has added the RO to their "Employee Control Structure" , the case will be systemically assigned to that CPM pending inventory. You should then delete that RO from your "Employee Control Structure" .

  4. If you receive a physical file in error, you should immediately forward the file to the CPM location working that assignment area.

5.7.10.1.2  (05-03-2010)
ATFR Case in Pending Inventory No Case File Received

  1. Review the "Pending" inventory to identify cases assigned for more than 10 business days. If you identify cases in "Pending" inventory for greater than 10 business days without receipt of the physical file, contact the RO by phone or E-mail requesting the file. Allow the RO 10 business days for receipt of the file. If the file is not received within this time frame:

    1. Remove the "2749 to CPM" date.

    2. Select the "Return to RO" option and notate the systemic Form 5942 ATFR history with the reason for returning the case to the RO.

    3. Issue an "Information Only" Form 5942 to the RO GM, with a copy to the FC TM.

5.7.10.1.3  (05-03-2010)
Pending Inventory and Receipt of Case File

  1. Within 5 business days of receipt of the paper file and acceptance of the case file into the CPM "Accepted" inventory, a case must be created on Integrated Collection System (ICS). Use the following selections for the Action Requested field when creating the NF OI (Non Field OI):

    • 171 – TFRP Processed

    • 176 – Appeals Case

5.7.10.2  (03-15-2013)
Case Review and Processing

  1. A check sheet has been developed to assist in reviewing TFRP case files. The use of this check sheet is mandatory. See IRM Exhibit 5.7.10-1. Within five business days of the ICS creation date, CPM Advisory will review the case and perform the following actions:

    1. Determine that all ASEDs are protected (See IRM 5.7.3.5(2), Statutory Assessment Period, on how to calculate an ASED.). If an expired ASED is found, consult with your Advisory GM. Inform your GM of any cases in inventory with 60 days or less remaining on the ASED.

    2. Recalculate the current trust fund amount on ATFR to verify that the current amount as shown on page 4 of the Form 4183, Recommendation re: Trust Fund Recovery Penalty Assessment, is equal to or is less than the amount shown on the Form 2749 and Form 2751, Proposed Assessment of Trust Fund Recovery Penalty. If the TFRP amount on the ATFR system is the same as reflected on the Form 2749 and Form 2751, proceed with the case review.

    3. If the TFRP amount on the ATFR system is less than the amount reflected on the Form 2749 and Form 2751, a new Form 2749 must be generated, printed and included in the file.

    4. If the balance is greater than the Form 2751, the case must be returned to the RO by completing the following actions:
      • Complete the case review to identify any other case deficiencies so they may be addressed by the RO before resubmitting the case to CPM.
      • On ATFR, return the case to the "Pending" inventory and select "Return to RO" .
      • From the pick list provided on the ATFR system, mark the case deficiencies that will be systemically notated in the ATFR history. Use the "comments" block to identify any additional information.
      • Prepare an "Information Only " Form 5942, identifying all case deficiencies and explaining the need to determine if the increased dollar amount needs to be included in the TFRP assessment. The original Form 5942 and case file will be sent to the RO GM. A Form 3210 will be used to return the file. The Form 3210 will be monitored for acknowledgement . A copy of the Form 5942 will be sent to the FC TM.
      • Close the NF OI ICS Code 171 case.

    5. Using the physical file, compare the periods on Form 2749 and Form 2751 to the Form 4183 page 4, to ensure that all trust fund periods are listed and included in the proposed assessment.
      1) If a period(s) is listed on the Form 2751 and not included on the Form 2749, check IDRS to determine if the period(s) has been satisfied. If the period(s) is satisfied, process the Form 2749 to the Campus for assessment.
      2) If the period(s) is not satisfied, check the ICS corporate history to determine if there is a reason these periods have not been included. Note both the ATFR and ICS history with the information you have found.
      3) If ICS and IDRS have not identified a valid reason for the period(s) not being included, issue an "Information Only" Form 5942 to the RO GM with a copy to the FC TM to determine why these periods have not been included.
      • On ATFR, return the case to the "Pending" inventory and select "Return to RO" .
      • From the pick list provided on the ATFR system, mark the case deficiencies that will be systemically notated in the ATFR history. Use the "comment" block to identify any additional information.
      •The original Form 5942 and case file will be sent to the RO GM. A Form 3210 will be used to return the file. The Form 3210 will be monitored for acknowledgement . A copy of the Form 5942 will be sent to the FC TM.
      • Close the NF OI, ICS Code 171 case.

      If these periods are now barred by statute, but were a part of the original Form 4183 recommendation, verify that the ASED has expired and issue a Form 5942 requiring a 30 day follow-up through the FC TM to the RO GM requesting that a Statute Expiration Memo be completed (See IRM 5.7.3.8, Reporting Expiration of TFRP Statute). You can continue to process the unexpired modules on ATFR. When the case is transmitted to the campus a new Form 2749 will generate and the expired period(s) will not be included. Open an NF OI ICS Action Requested 173 TFRP-ADJ OTHER case to monitor the Form 5942 response.

      Note: Determine if Trust Funds were full paid or if the ASED expired prior to ICS assignment to the RO. If either of these apply, do not send Form 5942 and continue with normal processing.

      Absent statute concerns, "Information Only" Forms 5942 will be issued and the case returned to the RO on ATFR as outlined in IRM 5.7.10.2(1)(e)(3). The original Form 5942 and case file will be sent to the RO GM. A copy of the Form 5942 will be sent to the FC TM. Form 3210 will be used to return the file. The Form 3210 will be monitored for acknowledgement.

    6. Determine if the proposed assessment is a quick, prompt or regular assessment by checking the ATFR system against the Form 2749. If it is a quick or prompt assessment, the Forms 2859, Form 3210 from the campus containing the assessment date, Document Locator Number (DLN), and Forms 3552 must be in the case file.

    7. Determine if the taxpayer has submitted a protest requiring the case to be sent to Appeals. See IRM 5.7.10.5, Appeals Case Review and Case Processing, for Appeals case processing.

  2. Review the physical file to ensure that the documents provided comply with the core documentation requirements for a complete case file as outlined in IRM 5.7.6.4, Case File Documentation. Record your findings on the check sheet.

    Note: If a Form 4183 has been signed by a RO GM, assume that a collectibility determination has been made even if it is not noted on the Form 4183.

    If a required form is missing from the file that can be printed from the ATFR program, print the form and include it in the file. If the ATFR or ICS history is missing from the TFRP case file, it should also be printed and included in the case file. Do not issue Form 5942 and return TFRP cases solely for missing ATFR or ICS case histories.

    If the file is incomplete for reasons other than missing forms that can be printed from the ATFR/ICS program, the ICS history should be reviewed to determine if the missing core documentation items were addressed by the RO. If not addressed, the case must be returned to the RO by taking the following actions:

    1. Return the case to the "Pending" inventory and select "Return to RO" .

    2. From the pick list provided on the ATFR system, mark all case deficiencies. These deficiencies will be systemically noted in the ATFR history. Use the "comments" section to add any additional information.

    3. Prepare an "Information Only" Form 5942 identifying all case deficiencies. Forward the case file and original Form 5942 to the RO group manager and a copy of Form 5942 to the FC TM. Follow the procedures in IRM 5.7.10(1)(e)3) to return the case to the RO on ATFR. A Form 3210 will be used to return the file. The Form 3210 will be monitored for acknowledgement.

    4. Close the NF OI ICS Code 171 case.

  3. If the file is complete and a regular assessment is being proposed, enter the date the Form 2749 is being transmitted to the campus for assessment in the "2749 to SC" field on ATFR. This action automatically moves the case on ATFR from the "Accepted" inventory to the "2749 to SC" inventory.

    Note: The CPM function will receive TFRP files when the assessment has been made by a RO via the quick, prompt, or jeopardy assessment process. These cases will require CPM ATFR inputs outlined in IRM 5.7.10.3. See IRM 5.7.6.3, Quick and Prompt Assessment Actions, for Quick, Prompt, or Jeopardy processing.

  4. CPM is accountable for ensuring that all paperwork needed to process the TFRP assessment and the mandatory core documentation items are in the case file or that the reason for their absence is documented in the ICS history. The revenue officer and group manager are responsible for decisions regarding the willfulness and responsibility factors of TFRP assessments based on these documents.

5.7.10.3  (05-03-2010)
Processing Quick, Prompt and Jeopardy Assessments Received from the Field

  1. The CPM function will receive quick (Q), prompt (P), or jeopardy (J) assessments made by ROs. After the initial case review and processing have been completed, CPM will verify and update ATFR with the following information:

    • Type of assessment (Q, P, or J). It is critical that the correct type of assessment is posted to eliminate any duplicate assessments when the "2749 to SC" date is input

    • Assessed amount

    • DLN

    • Date of Assessment

    NOTE: In order to enter the above information, click on "View/Edit Assessments" and highlight the period you want to edit. Click on "Edit" , enter the above data, and save the information.

  2. Select "Form 2749 to SC" .

5.7.10.4  (05-03-2010)
Monitoring of 2749 to Campus Inventory

  1. The systemic transmission of Form 2749 to the campus for assessment creates the ATFR "2749 to SC" inventory. This inventory will be reviewed weekly.

    This weekly monitoring will identify cases that have been successfully assessed through the campus and are ready to be closed on the ATFR system. It will also identify cases that have been rejected by the campus having possible assessment problems (e.g., unpostable periods, calculation problems). The cases returned to CPM by the campus will be identified by an "R" for reject.

    Any case remaining in this inventory for more than 21 calendar days requires IDRS research or contact with the campus for resolution. Exception: manual assessments may take up to 8 cycles to post.

  2. Review the "2749 to SC" inventory to determine if a "P" indicator has posted to the case. For regular assessments, the assessment date, DLN and assessment amount will be entered systemically by the ATFR system.

    Verify the posting of the TC 240 DLN, 23C date, assessed balance and TC 971 AC 097 by checking IDRS. When it has been determined that all assessments, DLNs, 23C dates and TC 971s have posted to IDRS, close the case on ATFR within 10 calendar days using the "Close 2749" option on the ATFR case. This action closes the case from the CPM’s "2749 to SC" inventory listing. Also close the corresponding ICS NF OI Time Code 171 case when closing the case from the ATFR system.

    Notate the front of case file folder with date of assessment. This will identify the file for future retirement to the FRC.

5.7.10.5  (05-03-2010)
Appeals Case Review and Case Processing

  1. Upon receipt of a TFRP file containing a taxpayer protest, ensure that an ICS NF OI module 176 Code has been opened.

  2. Complete the same initial case receipt and review as outlined in IRM 5.7.10.2. Upon completion of this review the case file will require additional analysis to ensure that:

    • The protest is timely. See IRM 5.7.3.6.2, Impact of Letter 1153(DO) on Assessment Statute, and IRM 5.7.6.1, Taxpayer's Response to Letter 1153(DO). Appeals will not accept for processing a case not protected by Taxpayer Bill Of Rights (TBOR-2). See IRM 5.7.6.1.6, Receipt of Protest.

    • All potentially responsible officers have been recommended for assertion or have a valid appeal that is being addressed.

  3. When the case is ready to be sent to Appeals:

    1. Annotate Form 2749 in red "ASED extended" by "TBOR-2" for cases with a timely filed protest.

    2. Prepare Form 3210 indicating "ASED protected by TBOR-2" .

    3. Enter the date sent to Appeals in ATFR. This action automatically moves the case from the "Accepted" inventory to the "Appeals" inventory.

    Note: If more than one person of the same corporation is protesting, the files should be submitted to Appeals as a package, whenever possible. If a co-obligor is not protesting, that case should remain in CPM for normal processing (IRM 5.7.10.2) to be associated with the protest file upon its return from Appeals. The file going to Appeals will be considered the "Key" file, which includes all supporting documentation.

5.7.10.6  (03-15-2013)
Appeals Cases - Controlling and Monitoring

  1. Appeals may request additional information. The information should be provided within 30 calendar days of the request. This date may be extended by mutual agreement. Appeals will retain jurisdiction on these cases if the ASED is held open only by the timely protest under TBOR-2. This is to preserve the time in Appeals plus 30 days, under IRC 6672(b).

  2. When a final determination is rendered, Appeals will return the case to CPM with Form 5402, Appeals Transmittal and Case Memo, which will reflect the Appeals decision. CPM will update the ATFR system with the:

    • 5402 Approved Date (the date the Form 5402 was signed by the Appeals Manager)

    • ICS and ATFR history entries will be made reflecting the Appeals determination

    • The Appeals Decision may be:
      a) No Change, i.e., fully responsible (F)
      b) Partially Responsible (P). If partially responsible the periods must be edited to reflect the revised amount to be assessed as determined by Appeals
      c) Not Responsible (N). CPM will close the case no later than 10 calendar days after receiving the Appeals determination not to assess.

      Note:

      TFRP cases that are returned from Appeals as non-sustained must be reviewed by CPM to determine if the release of Transaction Code (TC) 130, Entire Account Frozen from Refunding, is appropriate. Individual case circumstances will dictate if the release is appropriate. TC 130 is a taxpayer entity freeze. If additional TFRP assessments are pending, or there is a prior sole proprietor TC 130 offset in place, release of the TC 130 is not appropriate.

  3. If Appeals sustains the original proposed assessment in full or in part, a new Form 2749 must be generated and printed to reflect the correct TFRP amount based on the Appeals determination.

  4. CPM will be responsible for timely completing any assessment action (See IRM 5.7.6.3, Quick and Prompt Assessment Actions), ensuring the ASED is protected on all Appeals cases, and inputting the Appeals determination information on ATFR. If there are more than 30 calendar days remaining on the ASED, process the TFRP assessment as a regular assessment.

  5. While the ASED was extended by TBOR-2 for the time the case was pending in Appeals and under their jurisdiction, it is only protected for an additional 30 calendar days from the date of the final Appeals determination as indicated by the managerial signature on the Form 5402, Appeals Transmittal and Case Memo, Form 866, Agreement as to Final Determination of Tax Liability, or Form 906, Closing Agreement on Final Determination Covering Specific Matters. The following steps will be taken to ensure the assessment is completed within the 30 calendar day period.

    1. Reflect the correct type of assessment to be completed (Quick, Prompt, Regular).

    2. Generate and print a new Form 2749 for the case file to use when making a quick assessment under TBOR-2 if the dollar amounts on the trust fund assertion have changed.

    3. Generate and print the Form 2859 quick assessment documents from the ATFR system.

    4. Complete all required information on the Form 2859, including the requestor’s full address, phone number, and employee ICS assignment number.

    5. Prepare Form 3210 with the taxpayer’s name, last four digits of the social security number and each period to be assessed listed. Include CPM requestor’s fax number. (This page will be faxed back to CPM with the assessment date and the DLN for each period assessed.)

    6. Prepare a fax cover sheet with the taxpayer’s name and social security number and fax it to the Ogden Manual Assessment Unit with the following documents:

    • Form 3210 complete with all information

    • Form 2749

    • One copy of Form 2859 for each period to be assessed, with the group manager’s signature.

    The Ogden Manual Assessment Unit will fax back Form 3210 with the assessment date and DLN for each period. Upon receipt of this information, update ATFR with the DLN and assessment date and transmit the "2749 to SC" . (Inputting this date automatically moves the case from the Appeals inventory to the "2749 to SC" inventory). Follow the "2749 SC" monitoring procedures as outlined in IRM 5.7.10.5.

    For fax assessments, the Ogden Manual Assessment Unit will prepare Form 3552, Prompt Assessment Billing Assembly, and forward it to the initiator. The initiator will immediately deliver or mail certified Parts 3 and 4 of Form 3552, along with Publication 1, to the taxpayer. Notice 960, Explanation of Penalty Assessment on Form 3552 (Part 3), Notice of Tax Due on Federal Tax Return, will also be included with Form 3552 to remind the taxpayer of the procedures to follow in order to file a claim for refund and request abatement of the liability. Multiple Forms 3552 for the same taxpayer may be mailed together. Accounting Control/Services will also forward copies of the Forms 2749 and 3552 to the TFRP unit in Compliance Services Collection Operations (CSCO) for input of the appropriate cross-referencing information and UNLCER information.

5.7.10.7  (05-03-2010)
Inventory Management and Control

  1. CPM inventory is to be matched against ICS inventory on a monthly basis. All ATFR open cases listed in the "Accepted" , "2749 to SC" , and "Appeals " inventory must have a corresponding ICS NF OI.

  2. A reverse match should also be conducted monthly to ensure that the current ICS inventory of Action Requested 171 cases and ICS Action Requested 176 cases are accurately represented by a corresponding ATFR case in the appropriate category.

  3. Quarterly reconciliations will be conducted with Appeals to ensure that cases are still open in Appeals.

5.7.10.8  (05-03-2010)
Case Retention and Retirement

  1. TFRP case files are retained in Advisory until retirement to FRC (See IRM Exhibit 1.15.28-1, Records Control Schedule for Collection, for TFRP records retention information.). The FRC requirement to retire the TFRP file, forms and documents 2 years after assessment, should be interpreted as 2 years from the latest assessment date of all responsible parties. This will insure that all files related to a specific TFRP are associated and retained for 12 years from assessment at the FRC.

  2. When cases are to be retired to the FRC, Advisory CPM employees will add the accession number and FRC location in the designated field on ATFR.

5.7.10.9  (05-03-2010)
Requests for Closed TFRP Files

  1. CPM may receive requests for closed TFRP files from various requesters (Field, Appeals, Disclosure, etc.) via Form 2275. If the case file is in CPM’s closed TFRP file (assessment date within 2 years):

    1. Pull file and replace with a file charge-out card and send the entire case to the requester via Form 3210.

    2. Open an ICS 174 TFRP Files case under the corporate EIN to monitor the case while it is charged out. Notate ICS history with the requester’s name, location and phone number, as well as the responsible party’s name(s), SSN, and date of assessment.

    3. Close 174 module when the case is returned to CPM and return to closed files.

  2. If the case file has already been sent to the FRC:

    1. Complete Optional Form 11 (OF Form 11), Sections I & III, including the Accession Number and Records Center Location Number (available on ATFR CPM Information Screen or local CPM closed FRC file listing).

    2. Fax OF 11 to the Area AWSS Support Services Specialist, who will request the file from the FRC.

    3. Open an ICS 174 TFRP Files case under the corporate EIN to monitor receipt of the closed file from FRC. Notate ICS history with the requester’s name, location and phone number, as well as the responsible party’s name(s), SSN, and date of assessment. When received, forward the file to requester via Form 3210. Monitor case periodically to ensure file is still in requester’s possession.

    4. Close the ICS 174 TFRP Files case module when case file is returned to CPM from the requester, and return the file to the FRC for re-filing.

Exhibit 5.7.10-1 
TFRP CASE FILE CHECK SHEET for Review of TFRP Case Files

Responsible
Person:
_________________
SSN: ______________________
CORP: __________________ EIN:_______________________
Earliest ASED Date:__________________________
RO Name and Assignment Number :______________________________
Is Form 3210 included? Is Form 2749 included?
Is Form 4183 with Page 4 included? Are any barred statutes addressed?
Is Form 2750 included? If yes, is 2750 signed and dated by TP and IRS?
Is Letter 1153(DO) included? If yes:
 •Enter Date of Letter 1153:           Method of Delivery:
 • If mailed – Is Certified information or Proof of mailing included?
If no, is reason documented in ICS history?
Is Form 2751 included?   If yes, is Form 2751 signed and dated?
Is Form 1155 included?    
Is Form 4180 included?   If no, is reason documented in ICS history?
Is Form 9327 included?    
Is Form 2859 included?   If yes, is Form 3210 with DLN and 23C date included?
Is Form 3552 included?   If yes, is mailing documented in ICS history?
Is CPM History input?   Was 5942 / E-MAIL issued?
Core Documentation Items
Per 5.7.4. and 5.7.10

Note:

If the following documents are not secured, the ICS history must be documented with the reasons they were not secured and why they are not necessary to support the recommendation. Prepare Form 5942 and return to originator if not included or documented.

Is Form 4180 included?   If no, is reason documented in the ICS history?
Are Bank Signature Cards or PIN assignment included?   If no for both, is reason documented in the ICS history?
Are Checks or Bank Statements included?   If no for both, is reason documented in the ICS history?
Are Articles of Incorporation included?   If no, is reason documented in the ICS history?
Are ICS Corporate Investigation History and ATFR History included?
APPEALS FILE
Is Letter 1154 included?   Is Written Protest included? If no, return to RO
Is Appeal Timely?    
   If yes or no, Appeals Request Received by: ______________________
   If Hand Delivery or Fax – Is ICS documented?
   If Mail – Is postmarked envelope included?
CPM REVIEWED DATE

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