8.20.3  Appeals Centralized Database System (ACDS) (Cont. 1)

8.20.3.3 
INPUT Case/Returns

8.20.3.3.43  (10-15-2014)
WUaccptOfrAmt (WUNO Accepted Offer Amount)

  1. Accepted offer amount entered at the time the case is closed.

8.20.3.3.44  (10-15-2014)
ACTION (Action Taken on a Case)

  1. Action codes represent the actions taken on a case as it moves through Appeals.

  2. A new docketed case sent to Counsel to answer the petition should have an action of ANSWER.

    Note:

    If the current ACTION code is shown as DECENT or ORDENT, it should ONLY be overwritten or updated with ACTION Code ACKCLS (Acknowledged Closure).

  3. Action codes ACKCLS and SHIPPED open a separate box which is populated with the Post of Duty (POD) information.

    • ACKCLS POD information represents the location of the employee closing the case.

    • SHIPPED POD information represents the location the case is being sent to within the Appeals organization.

  4. See Exhibit 8.20.3-4 for a list of action codes.

8.20.3.3.45  (10-15-2014)
TODATE (Date ACTION Began)

  1. This field represents the date when an action on the case began, meaning the date the case was sent TO another Appeals office, Counsel, etc.

  2. Required entry when the ACTION field is entered.

8.20.3.3.46  (10-15-2014)
FROMDATE (Date ACTION Ended)

  1. Enter the date a specific action on the case ended.

  2. This field is a manual entry and made by the sending office (APS TE) when acknowledgement of the case is received.

  3. Exceptions:

    1. The FROMDATE on a transferred case (ACTION = TRXXX) is automatically entered when the case is accepted by the receiving office from the INBOX.

    2. For cases with ACTION Code ANSWER, the FROMDATE is automatically populated when assigned to the ATE.

8.20.3.3.47  (10-15-2014)
LACTION (Local Action)

  1. Action taken on a case - same as ACTION field but is reserved for local definition.

8.20.3.3.48  (10-15-2014)
LTODATE (Local TO DATE)

  1. The date the Local Action began.

8.20.3.3.49  (10-05-2006)
LFROMDATE (Local FROM DATE)

  1. The date the Local Action ended.

8.20.3.3.50  (10-15-2014)
CORWUGR (Corrected WUNO Grade)

  1. The WUNO grade is manually entered by the ATM when the case is assigned.

8.20.3.3.51  (10-15-2014)
TFRCorp (Trust Fund Recovery Corporation Name)

  1. Name of the Trust Fund Corporation related to the taxpayer on TFRP cases.

8.20.3.3.52  (10-15-2014)
TFRTin (Trust Fund Recovery TIN)

  1. The TIN of the TFRP case where the tax or penalty at issue has been generated.

8.20.3.3.53  (10-01-2012)
FOIANum (Freedom of Information Act Number)

  1. If ACDS Type Code "FOIA" is selected, the FOIA Number for the case will be a required entry on ACDS. If Type Code "FOIA" is not selected, the FOIA field cannot be entered on ACDS. For more information refer to IRM 8.7.14.6.1.

8.20.3.3.54  (10-15-2014)
Date DKTAD Skeletal

  1. The DIMS Team must enter the Date DKTAD Skeletal record created. Do not edit this field or remove this field at any time.

8.20.3.3.55  (10-15-2014)
Date DKTAD Dummy

  1. The DIMS Team will enter this date if applicable when the dummy file is created. Do not edit this field or remove this field at any time.

8.20.3.3.56  (10-15-2014)
Date DKTAD Original

  1. Any APS Tax Examiner who receives an original docketed administrative file must enter the date this file is received.

8.20.3.3.57  (10-05-2006)
CIRCTRIDE (Circuit Ride)

  1. If the case will be handled at a circuit riding location, enter the appropriate locally designated city code.

8.20.3.3.58  (10-15-2014)
STATUS (Status of WUNO)

  1. This item is updated by the ATE from the AO function CARATS in ACDS to reflect the current status of the WUNO in their inventory.

  2. The following status codes are computer generated based on the entry of an action code on the case in ACDS:

    • E/DD - Inactive, waiting action/info by Compliance

    • E/STP - Inactive, to Counsel for stipulation filing

    • E/T - Inactive, to Counsel for trial preparation

    • E/TSN - Inactive, waiting TP action on SND

  3. See the ACDS Utilities Menu for a list of current status codes.

8.20.3.3.59  (10-15-2014)
DESICONF ( Desired Conference Date)

  1. This field is updated by the ATE from their CARATS activity record.

8.20.3.3.60  (10-05-2006)
AQMSSELECT

  1. Indicator automatically set when the case is selected for AQMS review based on programmed criteria.

8.20.3.3.61  (10-15-2014)
LOC1 through LOC11

  1. LOC1 - Local use field

  2. LOC2 - Local use field

  3. LOC3 - Local use field

  4. LOC4 - Tracks transfer information. Systemic updates occur to insert the AOC of the transferring office.

  5. LOC5 - Local use field

  6. LOC6 - Local use field

  7. LOC7 - defined by headquarters to track CDP issues

  8. LOC8 - Q W-4 PROJECT - defined by headquarters to identify Questionable W-4 Project determination cases

  9. LOC9 - Local use field

  10. LOC10 - defined by headquarters to track Breakthrough Initiative cases

  11. LOC11 - Local use field in MM/DD/YYYY format

8.20.3.3.62  (10-15-2014)
Specific Item Instructions - RETURNS Screen

  1. Information and definitions for fields on the RETURNS level information screen.

8.20.3.3.62.1  (10-15-2014)
AIMS

  1. Enter the correct AIMS indicator code for all cases as follows:

    1. Y = Yes, return should be controlled on AIMS and is on AIMS at the time of receipt. An AMDISA print should be included in the administrative file.

    2. N = No, return should be controlled on AIMS but is not on AIMS at the time of receipt. IDRS Command Code AM424A is used by Appeals to establish the AIMS control.

    3. E = Exempt, return should NOT be controlled on AIMS and no AIMS controls were established at the time of receipt. There are no AIMS controls for CDP, OIC, penalty appeals, trust fund recovery penalty cases, abatement of interest claims, campus disallowed claims, etc.

    Note:

    The AMATCH validation program is keyed to these codes. It is very important to use them correctly to avoid having cases on the IVL lists needlessly, meaning if the match program reads "E" , the AIMS listing will not be searched. See IRM 8.10.1.10 for additional information regarding the AMATCH reports.

8.20.3.3.62.2  (10-15-2014)
Tax Period/Tax Period Modifiers

  1. Item includes all tax periods (years) associated with the case.

  2. The format is YYYYMM.

  3. The information can be obtained from documents in the administrative file including the tax returns, revenue agent's report, etc.

  4. For Estate Tax cases, Form 706, use the date of death as the tax period.

  5. Tax period modifiers - No tax period modifier is entered if the original return is in the file. The following is entered when the original return is not included in the administrative file:

    • N - no original return

      Note:

      For electronically filed returns such as IDRS command code TRPRT, if the Document Locator Number (DLN) appears in the upper right hand corner, then the TRPRT is considered to be the original tax return. Refer to Document 6209, Chapter 12 for additional information regarding TRPRT prints.

  6. The following definers are entered as a separate return line to control the statute when it is different from the rest of the return.

    • 199912F - Federal Insurance Contributions Act (FICA) tip tax

    • 199912P - prepayments credits

  7. When an ATE inputs a change to the statute-critical data fields of tax period, statute date, or statute code, the entry will trigger the Statute Validation System (SVS). When the original return is received on a case with a tax period modifier, the tax period must be updated in the SVS via the AIVP Validation Menu (which is accessible from the CAR or the Case Summary Card). All changes in SVS for the tax period critical data field is considered a Normal Update (N). Once the validation is submitted, ACDS will be updated and an automatic entry of VA (Validation Accepted) will be made in the CAR.

  8. If the APS Tax Examiner is requested to remove a tax period from ACDS because it is not part of the case, the APS Tax Examiner MUST CONSIDER THE STATUTE IMPLICATIONS AND UPDATE ALL APPLICABLE DATABASE SUCH AS IDRS, AIMS, AOIC, etc.

8.20.3.3.62.3  (10-15-2014)
Statute Date

  1. Next to each tax period, enter the expiration date of the statutory period for assessment. if there is an open statute (live or non-assessed), the date must be entered.

  2. When an ATE inputs a change to the statute-critical data fields of tax period, statute date, or statute code, the entry will trigger the Statute Validation System (SVS). All changes must be designated as either a Normal Update (N) or an Error Correction (E). Once the validation is submitted, ACDS will be updated and an automatic entry of VA (Validation Accepted) will be made in the CAR.

  3. If the case involves a FICA tax adjustment, the FICA tax may carry a different statute date. Two statute dates can be entered for the same tax period by using a tax period modifier for FICA tax, as follows:

    • 201312

    • 201312F

  4. For non-petitioning spouse cases, also see IRM 8.20.5.30.5.

  5. If the notice of deficiency is rescinded under Rev. Proc. 98-54, the statute date must be recomputed. Generally the statute date that existed prior to the issuance of the notice is reinstated. The recomputed statute date will be provided by the ATE. See also IRM 8.2.2.14.

  6. The statute date field is also used to track the CSED (Collection Statute Expiration Date) for Collection cases (CDP, OIC and TFRP). The statute date field is only entered for late CDP cases with Feature Code EH or retained jurisdiction CDP cases with Feature Code RJ. See IRM 8.20.5.13, post-assessment TFRP claim cases. See IRM 8.20.5.39.2.3. The statute date field will be blank for non-CDP OICs. See IRM 8.20.5.30. The statute date field will be completed for CDP OIC cases. See IRM 8.20.5.13.1.5.1 but the date is two years from the REQAPPL date for the offer, not the CSED.

8.20.3.3.62.4  (10-15-2014)
Statute Code

  1. Enter the appropriate code to denote the special period of limitations. Remember, if there is a valid statute code, it must be entered. See IRM 8.21.2-2 for a complete listing of all valid statute codes.

  2. When an ATE inputs a change to the statute-critical data fields of tax period, statute date, or statute code, the entry will trigger the Statute Validation System (SVS). All changes must be designated as either a Normal Update (N) or an Error Correction (E). Once the validation is submitted, ACDS will be updated and an automatic entry of VA (Validation Accepted) will be made in the CAR.

  3. Follow the rules below to determine the code:

    1. If the period of limitations is extended by special consent Form 872–A , Special Consent to Extend the Time to Assess Tax, enter 872–A.

    2. In bankruptcy cases, enter BKRUP, however, the actual statute date must also remain in the "statute date" field.

    3. If the statutory period for assessment has expired and the year is open only by reason of the filing of a claim, enter the word CLAIM.

    4. If the statutory period for assessment has expired and the return is open only because of the assertion of a fraud penalty, enter the FRAUD. If the statutory period for assessment has not expired in a year for which there is an assertion of a fraud penalty, the open statute date must also be entered.

    5. If the return being established is docketed before the tax court, enter DOCKT.

    6. If there is an omission from gross income which is in excess of 25% of the gross income stated on the return, enter 6501E. If there is a valid open statute date, it must also be entered. If the statute date has expired and the case is being held open only by the 6501E issue, then the six year statute date should be entered.

    7. If the statute is only open because of a carryback enter CBYYYYMM (YYYY MM represents the year and month creating the carryback). The following chart will help identify the proper entry for multiple scenarios where a carryback is involved:

      • How to control the statute where there is an open ASED for the Net Operating Loss (NOL) year(s) which carries back to years where the statute is only open resulting from the CB:

        Tax Period Statute Date Statute Code Comments
        201012   CBYYYYMM = CB201212
        • Open only on a carryback

        • The YYYYMM identifies the year with the open statute

        • No statute date will be entered

        200912   CB201212
        • Open only on a carryback

        201212 04/15/2016  
        • No code would be entered as this is the NOL year where the CB comes from

      • How to control the statute when the CB years have open ASEDs but are also covered by the NOL:

        Tax Period Statute Date Statute Code Comments
        201012 12/31/2013  
        • Statute date is entered because there is a valid 872 in the file for this year

        • Even though this year is covered by the CB only the open ASED is entered on ACDS

        201112 04/15/2015   Even though this year is covered by the CB only the open ASED is entered on ACDS
        201212 4/15/2016  
        • No code would be entered as this is the NOL year where the CB comes from

      • How to control statute when the NOL year is open on an 872A:

        Tax Period Statute Date Statute Code Comments
        200712   CB200912
        • Open only on a carryback

        • No statute date will be entered

        • Entering the date could lead one to believe the ASED is open for the entire case as shown in the example above

        200812   CB200912 Same as example above for 200712
        200912   872-A
        • 872-A code entered on the NOL year as that is what is keeping the case year open

    8. To ensure that a control is maintained on reference returns with the same name as the case being established, enter RFRTN in the statute code field. If there is a valid open statute date, it must also be entered in the statute date field. For reference returns with a name different from the case being established, a separate case summary card must be generated, and linked to the key case.

    9. On occasion, AIMS will reflect alpha statute codes (AA-ZZ) in the day field of the statute date, to identify a special reason for keeping the statute open. See Document 6209, Section 12 for a complete listing of AIMS alpha statute codes.

    10. See Exhibit 8.21.2-1 for a complete list of ACDS statute codes.

8.20.3.3.62.5  (10-15-2014)
BodCd (Business Operating Division Code)

  1. The Business Operating Division Code (BodCd) is comprised of three specific fields that are each input separately. Those fields are:

    • PRIBUSCD (Primary Business Code) - 3 digits

    • SECBUSCD (Secondary Business Code) - 5 digits

    • EMPGRCD (Employee Group Type Code) - 4 digits

  2. The three fields combined are also referred to as the AIMS Assignee Code for AIMS cases. The AIMS Assignee Code can be found on the AMDISA.

  3. For AIMS cases input the 12 digit AIMS Assignee Code of the originating office in each of the specific fields.

  4. For non-AIMS cases, determine and input the PRIBUSCD of the originating office only.

  5. Currently, the BODCD and SOURCE fields will be input to identify the source of our work.

8.20.3.3.62.5.1  (10-15-2014)
PRIBUSCD (Primary Business Code)

  1. A three digit code to identify the source of the return. This code should remain constant throughout the appeal process. This is a required field. For AIMS cases, input the PBC of the originating office as shown on the AMDISA in the closing PBC field. For non-AIMS cases, the listings below are provided to assist you in determining the PRIBUSCD.

  2. Digit 1 is the AIMS BOD Code. The following is a list of valid codes to identify the source of work:

    • 1 - Wage and Investment

    • 2 - Small Business/Self Employed

    • 3 - Large Business and International

    • 4 - Tax Exempt/Government

  3. Digits 2 and 3 are referred to as the "Industry-Area-Type-Code" .

    1. SB/SE and W & I identifies "Area"

    2. LB & I identifies "Industry"

    3. TE/GE identifies "Area" or "Type" of case.

  4. The Compliance Collection Campuses and their PBCs are:

    • Andover 190

    • Atlanta 191

    • Austin 192

    • Fresno 193

    • Kansas City 194

    • Brookhaven 295

    • Cincinnati 296

    • Memphis 297

    • Ogden 298

    • Philadelphia 299

  5. The Compliance ACS "Remote" or Field sites and associated campuses are:

    • Buffalo (Andover 190)

    • Denver (Ogden 298)

    • Des Moines (Memphis 297)

    • Detroit (Cincinnati 296)

    • Jacksonville (Atlanta 191)

    • Nashville (Memphis 297)

    • Oakland (Ogden 298)

    • Puerto Rico (Austin 192)

    • Seattle (Fresno 193)

  6. For Bank Secrecy Act cases (IRC 6721 penalties for Form 8300 violations), the PBC is 217.

  7. Refer to Document 6209, IRS Processing Codes and Information for additional information regarding PBCs.

8.20.3.3.62.5.2  (10-15-2014)
SECBUSCD (Secondary Business Code)

  1. A five digit code to further identify the source of the return. Input the SBC of the originating office as shown on the AMDISA. The SBC will not be updated from the prior code when a return is closed to Appeals. This field is not required for non-AIMS cases. See Document 6209 for additional information.

8.20.3.3.62.5.3  (10-15-2014)
EMPGRCD (Employee Group Code)

  1. A four digit code to further identify the source of the return. Input the EGC of the originating office as shown on the AMDISA. The EGC will not be updated from the prior code when a return is closed to Appeals. This field is not required for non-AIMS cases. See Document 6209 for additional information.

8.20.3.3.62.6  (12-27-2011)
SND (Statutory Notice of Deficiency)

  1. Enter Y if the SND was issued and the tax period was included.

  2. Enter N if the SND was not issued or the tax period was not included.

8.20.3.3.62.7  (10-15-2014)
PAYCODE (Payment Code)

  1. This item is used to record whether a payment was received by Appeals for the tax period being closed and the type of payment. This item is optional based on the APS Lean Six Sigma recommendations during Fiscal Year 13.

8.20.3.3.62.8  (10-15-2014)
PropdTax (PROPOSED$ TAX DEF/-OA)

  1. Enter the proposed deficiency or overassessment (rounded to whole dollars) for each tax period established.

  2. The amount should reflect the NET amount of tax and credits including withholding, earned income, etc. and should generally agree with Line 6, Page 2, of the AMDISA print ("Unagreed Amount Appealed/Petition" ).

  3. In those instances where the AMDISA amount reflects only $1, refer to the RAR to determine the correct amount.

  4. Claim amounts are not included in this item and are discussed below in IRM 8.20.3.3.62.12, Claims.

  5. Where a partial agreement (assessment) has been secured by Compliance, only the net proposed deficiency should be entered. The case file should contain two Examination reports (Form 4549) - one for the AGREED issues and one for AGREED AND UNAGREED issues (referred to as UNAGREED below).

  6. On cases where the special tax period modifiers are entered separately to control a different statute, follow procedures in (1) above. Do- not enter dollar amounts on the separate line.

8.20.3.3.62.9  (10-15-2014)
PropdPen (PROPOSED$ PENALTY DEF/-OA)

  1. The proposed penalty(s) for each tax period established.

  2. The information can be obtained from various documents in the administrative file including the RAR, etc... (round all amounts to the nearest whole dollar).

8.20.3.3.62.10  (10-15-2014)
RevsdTax (REVISED$ TAX DEF/-OA)

  1. Generally, this item is completed at closing.

  2. Appeals revised determination of tax liability, rounded to whole dollars, including any Appeals partial assessments.

  3. Amount can be taken from the Form 5402, audit statement, SND, etc.

  4. Penalty amounts are excluded.

  5. There are two special situations that determine the amount entered in revised dollars. They are as follows:

    1. If the case is settled by Counsel, or it is tried, enter the total amount of NET tax and credits shown on the Tax Court Decision.

    2. If the case is dismissed, enter the total amount of NET tax and credits shown on the statutory notice of deficiency.

8.20.3.3.62.11  (10-15-2014)
RevsdPen (REVISED$ PENALTY DEF/-OA)

  1. Generally, this item is completed at closing.

  2. Enter Appeals results only and round all amounts to the nearest whole dollar.

8.20.3.3.62.12  (10-15-2014)
CLAIMS

  1. The following claim fields reflect amounts for Revenue Base Protection (RBP).

  2. RBP applies only if tax has been assessed and paid.

  3. All other claim amounts are reflected in proposed tax and penalty fields.

8.20.3.3.62.12.1  (10-05-2006)
DDAMTCL (Amount of the claim received by the former District Director now referred to as Compliance Examination that was disallowed)

  1. Enter the amount of the claim considered by Compliance Examination and subsequently disallowed. This amount can be verified on page 2 of the AMDISA.

8.20.3.3.62.12.2  (12-27-2011)
DD AMTDIS (Amount of the claim received by the former District Director now referred to as Compliance Examination that Appeals disallowed)

  1. Entered at closing, this is the amount of DDAMTCL disallowed by Appeals.

8.20.3.3.62.12.3  (10-15-2014)
APPEALS AMTCLM (Amount of the claim received while the return was in Appeals' jurisdiction)

  1. The amount of the claim received directly from the Campus or filed while the return was in Appeals' jurisdiction.

8.20.3.3.62.12.4  (12-27-2011)
APPEALS AMTDIS (Amount of the claim received in Appeals that was disallowed)

  1. Entered at closing, this is the amount of APPEALS AMTCLM disallowed.

8.20.3.3.62.13  (10-15-2014)
RETURN DUPLICATION

  1. Duplication involves more than one taxpayer for the same income or deduction adjustment if it is certain that the adjustment is proper for at least one taxpayer. The deficiency attributable to the non-key should be shown as a duplication such as whipsaw, alimony, etc.

  2. Partial assessment dollars secured by Compliance will not be shown as duplication.

  3. When adding new returns to either a new or existing case, the input for duplicate dollars is duplication for that return (NOT FOR THE ENTIRE CASE). When updating a return, the duplicate dollars shown are for the entire case.

8.20.3.3.63  (12-27-2011)
Total DD CLAIM (Total amount of the DDAMTCL fields)

  1. This field is computer generated. It represents the total amount of dollars input in the DDAMTCL fields. No manual input is required. This field is printed on the case summary card or visible on the search screen.

8.20.3.3.64  (12-27-2011)
Total APP CLAIM (Total amount of the Appeals AMTCLM fields)

  1. This field is computer generated. It represents the total amount of dollars input in the Appeals AMTCLM fields. No manual input is required. This field is printed on the case summary card or visible on the search screen.

8.20.3.3.65  (12-27-2011)
Total Case Deficiency (TOTPRODEF)

  1. This field is computer generated. No manual input is required. This field is only printed on the case summary card.

8.20.3.3.66  (10-05-2006)
Total Case Overassessment including Penalty (TOTPROASS)

  1. This field is computer generated. This field is printed on the case summary card or visible on the search screen.

8.20.3.3.67  (10-15-2014)
TOTAL WORK UNIT (WUDOLRS)

  1. Total dollars for all cases in the WUNO.

  2. This field is computer generated.

  3. This field is printed on the case summary card or visible on the search screen.

8.20.3.4  (10-15-2014)
CASE SUMMARY CARD

  1. After the CASES and RETURNS level information has been input on the screens, the computer will display a prompt to ask if you want to print a case summary card.

  2. The case summary card displays all information for the case just established. The system will compute the total work unit dollars.

  3. The case summary card will be used by the ATE to identify and control cases in his/her inventory.

Exhibit 8.20.3-1 
ACDS TYPE Codes

Code Description Source Document
ABINT Abatement of Interest Claim Form 843
CAPIA Collection Appeals Program Installment Agreement Form 4442, Form 9423
CAPLN Collection Appeals Program Lien Form 9423
CAPLV Collection Appeals Program Levy Form 9423
CAPSZ Collection Appeals Program Seizure Form 9423
CDPTD CDP Timeliness Determination Form 14461 and Form 12153-B
DOP Director of Practice Case  
DPL2 Collection Due Process Lien & Levy case Form 14461 and Form 12153-B
DPLN Collection Due Process Lien Form 14461 and Form 12153-B
DPLV Collection Due Process Levy Form 14461 and Form 12153-B
EMPL Employment Tax Case Form 941, Form 940
EOD Exempt Organization Determination Case Form 1023, Form 1024, Form 1028 (EO)
EOE Exempt Organization Examination Case Form 990, Form 990BL, Form 990C, Form 990T
EOR Exempt Organization Revocation Case Final Adverse Determination Letter
EPD Employee Plan Determination Case Form 5300, Form 5301, Form 5303, Form 5307, Form 5310, Form 6406EP
EPE Employee Plan Examination Case Form 5500, Form 5500C, Form 5500R (EP)
EPR Employee Plan Revocation Case Final Adverse Determination Letter
ES Estate Tax Case Form 706
EX Excise Tax Case Form 720
FBAR Foreign Bank Account Reporting  
FOIA Freedom of Information Act Case Form 3210
G Gift Tax Case Form 709
I Income Tax Case Form 1040 or Form 1120
OIC Offer in Compromise Form 656
OTHPEN Other IRC Penalty Code Sections not Identified Form 8278
PENAP Penalty Appeal Case Form 5880, Form 8278, etc.
REF Reference Return Form 941, Form 1065 (except TEFRA), etc.
TEFRA TEFRA Key Case Form 3198
TEFRAI TEFRA Investor Only Case Form 3198
TEFRAP TEFRA Penalty Only Case Form 3198
TFRP Trust Fund Recovery Penalty Case Form 2751
USBANK Bankruptcy Appeals Process (Test Program)
WPT Windfall Profits Tax Case Form 6407, Form 6248, Form 6249, etc.
6161 Extension of Time for Prepayment of Estate Tax  
6166 Extension of Time for Payment of Estate Tax Form 706 & various Counsel documents
6676 Erroneous Claim for Refund or Credit Penalty Case Form 8278
6694A Tax Preparer Conduct Penalty ($250) Form 8278, Form 3198
6694B Tax Preparer Conduct Penalty ($1000) Form 8278, Form 3198
6695 Tax Preparer Penalty Form 8278, Form 3198
6695A IRC 6695A Appraiser's Penalty Cases  
6700 Abusive Tax Shelter Penalty Form 8278, Form 3198
6701 Understatement of Tax Liability Form 8278, Form 3198
6702 Frivolous Income Tax Return Form 8278, Form 3198
6703 IRC Section 6703 Form 3198
6704 Failure to Keep Records Form 3198
6705 Failure of Broker to Provide Notice to Payor Form 8278
6706 Original Issue Discount Information Form 3198
6707 Failure to Furnish Tax Shelter Information Form 8278
6707A Failure to Include Reportable Transaction with Return Form 3198
6708 Failure to Maintain List of Investors in Abusive Tax Shelter Form 8278
6709 Penalties with Respect to Mortgage Credit Certificates Form 3198
6715 Dyed Diesel Fuel Form 3210
6721 IRC 6721 Bank Secrecy Case Form 8278, Form 3645, Form 3198
7430 Administrative Costs Form 3198

Exhibit 8.20.3-2 
Historical District Office (DO) and Service Center (SC) Codes

Code Description
04 New England
06 Connecticut-Rhode Island
07 Atlanta Service Center (ATSC)
08 Andover Service Center (ANSC)
09 Kansas City Service Center (KCSC)
11 Brooklyn, NY
13 Manhattan, NY
16 Upstate NY
17 Cincinnati Service Center (CSC)
18 Austin Service Center (AUSC)
19 Brookhaven Service Center (BSC)
22 New Jersey
23 Pennsylvania
28 Philadelphia Service Center (PSC)
29 Ogden Service Center (OSC)
31 Ohio
33 Southern California
35 Indiana
36 Illinois
38 Michigan
39 Midwest
41 North Central
43 Kansas-Missouri
49 Memphis Service Center (MSC)
52 Delaware-Maryland
54 Virginia-WestVirginia
56 North-South Carolina
58 Georgia
59 North Florida
62 Kentucky-Tennessee
65 South Florida
66 Puerto Rico
72 Gulf Coast
73 Arkansas-Oklahoma
74 South Texas
75 North Texas
76 Houston
77 Central California
84 Rocky Mountain
86 Southwest
89 Fresno Service Center (FSC)
90 Detroit Computing Center (DCC)
91 Pacific Northwest
94 Northern California
95 Los Angeles, CA
98 A/C International

Exhibit 8.20.3-3 
Counsel Office Codes

Office Name Office Code Office Name Office Code
Anchorage ANC Los Angeles LA
Atlanta ATL Louisville LOU
Austin AUS Manhattan MAN
Baltimore BAL Miami MIA
Birmingham BIR Milwaukee MIL
Boston BOS Nashville NAS
Brooklyn BRO New Orleans NO
Buffalo BUF Newark NEW
Chicago CHI Oklahoma City OKL
Cincinnati CIN Omaha OMA
Cleveland CLE Philadelphia PHI
Dallas DAL Phoenix PNX
Denver DEN Pittsburgh PIT
Detroit DET Portland POR
Fort Lauderdale FTL Richmond RCH
Greensboro GBO Sacramento SAC
Hartford HAR Salt Lake City SLC
Honolulu HON San Diego SD
Houston HOU San Francisco SF
Indianapolis IND San Jose SJ
Jacksonville JAX Seattle SEA
Kansas City KCY St Louis STL
Laguna Niguel LN St Paul STP
Las Vegas LV Thousand Oaks THO
    Washington WAS

Exhibit 8.20.3-4 
ACDS ACTION Codes

Code Description To Date From Date
ACKCLS Closing of case Date sent to APS, etc. Date Form 3210 was acknowledged
ANSWER Unassigned case sent to Counsel to answer petition Date sent to Counsel Date returned from Counsel
APPEALED Tax Court Decision that has been appealed Date of Appeal Date Court of Appeals Decision is received
COURT Case Tried in Tax Court Date case was tried Leave blank
DCJUR Case transferred to Counsel Jurisdiction Date sent to Counsel Leave blank
DCOTHER Case sent to Counsel for review suspense Date sent to Counsel Date return from Counsel
DDJRET Case sent to Compliance (Appeals retains jurisdiction) Date case was sent Date case was returned
DECENT Decision entered by Tax Court Date of Decision Leave blank
DKTLSTXXX Docket list/number Date of docket list Leave blank
FILERCVD Administrative file received- awaiting petition Date admin file received Leave blank
INTERIM Interim assessment or abatement requested Date sent to APS Date verification of assessment/abatement
ORDENT Order of dismissal by Tax Court Date order entered Leave blank
PETNRCVD Petition received-awaiting administrative file Date petition received Leave blank
PREPSTIP Stipulation sent to Counsel for preparation Date sent to Counsel Leave blank
REJECT Case reject from APS Date corrected case returned to APS Date of acknowledgement
SNDC Statutory Notice of Deficiency sent to Counsel for concurrence Date case sent to Counsel Date case returned to Appeals
SHIPPED Ship cases between offices/PODs in the same Area Date case was sent Date case received in new location
STIPFF Filing of stipulations by Counsel Date case sent to Counsel Leave blank
TRXXX Case transferred from one Area to another Area Date case transferred Leave blank

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