21.7.10  No-Merge Cases

Manual Transmittal

August 21, 2015


(1) This transmits revised IRM 21.7.10, Business Tax Returns and Non-Master File Accounts, No-Merge Cases.

Material Changes

(1) Various editorial and formatting changes have been made throughout the IRM.

Effect on Other Documents

This IRM supersedes IRM 21.7.10 dated 09-02-2014 (effective 10-01-2014).


This IRM is intended for Wage and Investment, Customer Account Services, and Small Business/Self-Employed employees who handle issues related to Business Master File Tax Returns.

Effective Date


Kevin M. Morehead
Acting Director, Accounts Management
Wage and Investment Division  (10-01-2007)
No-Merge Overview

  1. This section contains information on account consolidation. An unsuccessful attempt to merge (consolidate) an account is called a "NO-MERGE" . This section also describes the various transcripts a "NOMRG" generates.  (01-21-2009)
What Are No-Merge Transcripts?

  1. No-merge (NOMRG) transcripts include:



    • NOMRG–400 - IRM



  2. Business Master File (BMF) Generated NOMRG Transcripts and Description are listed below:

    • NOMRG AF - A complete transcript generated when a merge is attempted, both accounts have an Exempt Organization (EO) section, and one account has affiliation code of 6 or 8 (central organization) and the other has affiliation code of 7 or 9 (subordinate organization).

    • NOMRG CONS - A transcript generated when the sum of the transaction section byte counts, excluding the return byte count, if present, exceeds 20,900 bytes.

    • NOMRG DUP - A complete transcript generated when an account merge fails because tax modules for equal periods each contain Transaction Code (TC) 150.

    • NOMRG FYM - A complete transcript generated when a merge fails because both Taxpayer Identification Numbers (TIN) have a different fiscal year month (FYM).

    • NOMRG GEN - A complete transcript generated when a merge is attempted, both accounts have an EO section, and the Group Exemption Numbers (GENs) are different (neither EO status is zero).


      The Group Exemption Number is a four-digit number that uniquely identifies a central organization and its named subordinates on whose behalf the central organization has applied for a group ruling of exemption.

    • NOMRG NOUS - A complete transcript generated when a merge fails because one account has a foreign address and the other does not.

    • NOMRG RPS - A complete transcript generated for an attempted merge when the Remittance Processing System (RPS) transaction codes are not compatible. Both modules contain a Transaction Code (TC) 150 with multiple TC 610 (one is an RPS). The TC 610 and TC 150 Document Locator Numbers (DLNs) do not match.

    • NOMRG SS - A complete transcript generated when a merge is attempted, both accounts have an EO section, and both accounts have non-zero EO current status codes and non-zero subsection codes which are different.

    • NOMRG STAT - A complete transcript generated when a merge is attempted, both accounts have an EO section, and their EO statuses are incompatible.

    • NOMRG TOP - A complete transcript generated when a merge failed because tax module either had an unreversed TC 896 dated less than 6 years prior to Revenue Accounting Control System (RACS) 006 date, or any TC 898 with significant net memo amount dated less than 6 years prior to RACS 006 date and does not meet REVAL conditions.

    • NOMRG VEST - A complete transcript generated when an account merge fails because one account contains a vestigial record and there is an equal period tax module or vestigial record present in the other account.

    • NOMRG 400 - A complete transcript generated when an account merge fails because one or both accounts contain modules for equal tax periods with an unreversed TC 400 posted.

    • NOMRG 520 - A complete transcript generated when a merge attempt fails because there is an unreversed TC 520 in each module.

    • NOMRG 91X - A transcript generated if there is an unreversed TC 914 posted to either account, and if both accounts contain an unreversed TC 910 with significant Agent Identification (ID) and the Agent's ID does not match, or one account contains a 918 freeze, or both accounts contain a 918 freeze but the File Location Code (FLC) of the unreversed TC 918 is different.

    • NOMRG 930 - A complete transcript generated when both modules contain a posted TC 930.

    • NOMRG 8752 - A transcript generated when Form 8752 tax module merge failed due to posted return with significant transfer amount or an unreversed TC 766 with "8899" in Blocking Series (BS) of DLN.

  3. No Merge cases received electronically are controlled on Command Code (CC) ENMOD. Cross-reference (X-REF) TINs are listed in a new section of the case page labeled "Associated TINs" beneath the images section. "No Documents were found for this case" will be displayed in the Document Images section of the page. The specific type of No Merge transcript (e.g. NOMRG-DUP) can be identified by the case note that is written when the case is created. These cases are distributed to CSRs (Customer Service Representatives) active inventories since they do not pull documents from Files.


    The Associated TINs section of the page isn't visible while the case is in work distribution (UA). It is visible once the case is assigned to a CSR.

  4. Additional information on the electronic notice process can be found at the Correspondence Imaging System (CIS) link on Servicewide Electronic Research Program (SERP).  (10-01-2008)
No-Merge Research

  1. In order to carry out NOMRG procedures, you must understand the transaction codes. If you are not sure of a transaction code, see IRM, Consolidating Accounts, or Document 6209, IRS Processing Codes and Information.

  2. Some BMF accounts cannot be consolidated because they have incompatible filing requirements.


    Form 1041 filing requirement is incompatible with Form 1120 filing requirement.

    See IRM (5) (d) Figure 3.13.2-30 for additional information regarding Incompatible Filing requirements.

  3. If you identify a NOMRG case while staffing the AM toll-free telephone line, prepare Form 4442, Inquiry Referral, and route it to the AM Paper function within your Directorate.


    If there is an open control on the account, refer Form 4442 to the employee who has the open control. See IRM and IRM to identify a successful and failed merge.  (09-02-2014)
No-Merge Procedures

  1. The remainder of this section contains the following:

    • TC 011 Merge Accounts Procedures - IRM

    • TC Related to Entity Changes - IRM

    • Determining if Accounts Can/Should be Merged - IRM

    • Successful Merge - IRM

    • Failed Merge - IRM

    • No-Merge Cases - IRM  (10-01-2007)
TC 011 Merge Accounts Procedures

  1. CC BRCHG is used to input TC 011 and TC 05X. This procedure is restricted to the Entity Control Unit. TC 011 will change the Employer Identification Number (EIN) of an account already on Master File (MF), or it will consolidate two EINs. No other entity change can be made with this transaction code. TC 011 always posts last to the entity portion of the MF. It will re-sequence to the next cycle. TC 05X is used to make changes to the FYM.

  2. Failed consolidation attempts are time consuming to correct. You must:

    • Verify the same taxpayers are involved.

    • Recognize the account module and the entity conditions that prevented a successful merge.  (09-02-2014)
Transaction Codes Related to Entity Changes

  1. The following TC relate to entity changes.

    • TC 011 - Restricted to Entity Control and changes TIN of an account on the Master File (MF) or used to consolidate two TINs.

    • TC 012 - Reactivates an Entity Account

    • TC 013 - Indicates a change to primary name

    • TC 014 - Indicates a change to taxpayer's address

    • TC 016 - Indicates a change to various entity data (e.g., filing requirements, fiscal year month, employment codes, etc.)

    • TC 020 - Deletes an account or makes it inactive (changes all filing requirement codes to 8)

    • TC 026 - Deletes the Entity data that remained on the MF under the old EIN/Social Security Number (SSN) (Generated transaction).

    • TC 040 - Changes SSN or name of an account on the valid segment of the Individual Master File (IMF) or the valid portion of the BMF.

    • TC 041 - Changes SSN or name of an account which is on the invalid segment of the IMF/Individual Retirement Account File (IRAF) or the invalid portion of the Business Master File (BMF).


    See Document 6209, IRS Processing Codes and Information, IRM 3.13.2, BMF Account Numbers, and IRM 2.4, IDRS Terminal Input, for additional information and input requirements.  (10-01-2007)
Determining if Accounts Can/Should Be Merged

  1. To determine whether accounts should be merged:

    1. Utilize Integrated Data Retrieval System (IDRS) and Corporate Files On Line (CFOL) command codes to research entity and account records.

    2. Contact taxpayer(s) (if possible) when you cannot determine from in-house research if the same taxpayers are involved.


    If contacting the taxpayer by telephone, use proper authentication prior to discussing the tax account information.

  2. When researching taxpayer records, note differences in:

    • Name lines

    • Addresses

    • Filing requirements (e.g., Form 1041, U.S. Income Tax Return for Estates and Trusts, filing requirement is incompatible with Form 1120, U.S. Corporation Income Tax Return, filing requirement)

    • Entity establishment dates


      Entities established years apart may indicate different taxpayers. Final returns posted to oldest established TIN may indicate a change in ownership.

  3. Analyze status of specific types of tax and tax periods.


    If the returns are posted under the same tax period and Master File Tax (MFT) code with different liabilities, the entities may be for different taxpayers.

  4. When it is determined a merge is necessary, process as follows:

    1. Attach proper documentation for each entity to Form 3465, Adjustment Request. Forward to Entity Control to input TC 011. (See Note below table.)

    2. Attach a history sheet to the case and it must contain the employee number, all research actions, and the reason for the merge. (The employee number is cross-referenced on the TC 011 document input by Entity Control.)

    3. Follow the procedures in the table below.

      If... Then...
      A merge will resolve the case 1. Assign the control base to Entity Control.
      2. Input the history items on CC TXMOD (used to display all of the modules data) and the entity module listing cross-reference TIN information.
      Additional actions are necessary to resolve the case after the merge is processed 1. Retain the case control.
      2. Input the history items to indicate the case is forwarded to Entity Control.
      3. List cross-reference TIN information on CC TXMOD and the entity module.


    Before forwarding to Entity Control, the manager/lead customer service representative will review the case to ensure the accuracy of the merge request.  (09-02-2014)
Successful Merge

  1. The posting of TC 005/TC 006 combination on the new ("to" ) TIN indicates a successful merge. The account shows a TIN cross-reference to the from account.  (10-01-2007)
Failed Merge

  1. TC 003 posted on the "from" account, and is not resequenced, indicates an unsuccessful merge.


    The same tax module under both numbers contains a posted return (TC 150).

  2. TC 006 without a cross-reference TIN indicates an unsuccessful merge.  (09-02-2014)
No-Merge Cases

  1. When a taxpayer is erroneously assigned two EINs, a TC 011 is input to consolidate duplicate numbers. A tape of the consolidation is sent to Social Security Administration (SSA).

  2. Consolidation will not be successful if any of the following conditions are present:

    • A return posts (TC 150) in each module - generates NOMRG-DUP transcripts

    • A return posts (TC 150) in one module and retention record (vestigial record) in the other - generates NOMRG-VEST transcripts

    • Unreversed TC 400 (if transaction section has exceeded posting size) in either module - generates NOMRG-400 transcripts

    • Each module contains a combination of a TC 150 and multiple TC 610 (payments post with return) one of which is an RPS - generates NOMRG-RPS transcripts  (10-01-2007)

  1. Duplicate return (both tax modules) in a merging pair contain a posted returns (TC 150), or more than 25 Tax Modules are involved in the merge.

  2. When a merge is unsuccessful, complete Enterprise Computing Center at Martinsburg (ECC-MTB) transcript generates for all modules on both accounts. If any modules merge, transcripts generate for all the modules on the " to" account, but only on the remaining unsuccessfully merged modules of the "from" account.

  3. Use CFOL command codes or request original returns, if necessary.

  4. Before taking any adjustment action, determine if another taxpayer is involved under either TIN.

  5. In all situations, include a determination of future tax liabilities and delete the filing requirements, if necessary.

  6. If a statute is scheduled to expire within 90 days from the date the no–merge case is received, use local procedures to route to the Statute Unit located at your campus or the Statute Coordinator on your team.  (09-02-2014)
One Taxpayer Involved (NOMRG-DUP)

  1. If only one taxpayer is involved:

    1. Input TC 291 and any other applicable TC to reduce the tax and related penalties and interest to zero for duplicate modules on the incorrect TIN.

    2. Use BS 15/05.

    3. Use the ECC-MTB transcript as a backup document.

    4. Enter HC (Hold Code) 4 to prevent generating the adjustment notice and hold the credit. If there is credit in the module, transfer the credit to the correct TIN.


      Enter TC 570 (additional liability and or credit pending, hold) when necessary, and monitor. Reverse with TC 571.

    5. Do not delete the filing requirements for an incorrect TIN. It is not necessary, because the filing requirements are deleted when a merge occurs ("from" EIN filing requirements are changed to 8s) .

    6. Input TC 290 and the appropriate BS. Input any other TC necessary to increase the tax to the correct amount on the correct TIN.


      If there is no change in the tax liability, do not adjust the tax.

    7. Enter HC 3 to prevent generating the adjustments notice if no additional tax or refund is due.


      This will not prevent any other notice.

  2. If the account to be merged contains transactions which cannot be transferred with the above documents (e.g., TC 300, TC 301, TC 400, etc.), prepare Form 3465, Adjustment Request, and route to Accounting.  (10-01-2008)
More Than One Taxpayer Involved, Merged in Error (NOMRG-DUP)

  1. Follow the procedures below when a merge is in error and more than one taxpayer is involved.

    1. Determine the correct TINs.

    2. Input the appropriate entity transaction to each affected TIN.

    3. Transfer credits, as appropriate.

    4. Determine, from the ECC-MTB, if other modules were moved to an incorrect TIN during the merge. (TC 446 indicates merged transactions.)

    5. Move modules back to the correct TIN, if moved to an incorrect TIN during the merge. (If necessary, reopen the TIN via TC 012.)

    6. Refile any returns, as appropriate.  (09-02-2014)
More Than One Taxpayer Involved, Merged Correctly

  1. Follow the procedures below when the merge was correct and more than one taxpayer is involved (this may occur when a successor company files using a different EIN).

    1. Use the ECC-MTB transcripts, IDRS and CFOL Command Code (CC) to review the accounts and verify whether the tax returns posted to the correct TIN.

    2. Verify the assessment (TC 150) is correct as filed. If correct, do not adjust the account. Refile the returns.

    3. Reopen the TIN, via TC 012, if the final returns have not posted.

    4. Move the credits to the correct module(s) and allow the final returns to post.  (09-02-2014)

  1. NOMRG–RPS transcripts generate when two accounts attempt to merge as a result of an entity transaction and both contain a module for the same tax period with a combination of:

    • A posted return (TC 150)

    • Multiple payments (TC 610), one of which is an RPS

  2. If there is only one taxpayer involved, follow the procedures below:

    If... Then...
    Only one taxpayer Input TC 291 in BS 15/05 and any other necessary TC to reduce the tax, related penalties, and the interest to zero on the incorrect TIN.
    Credit should be held Use HC 1.
    Credit and notice should be held Use HC 4.
    TC 610 payment is on the account Transfer to the valid account.
    Credit should be prevented from offsetting or refunding Input TC 570.
    Returns are secured Analyze the accounts and returns.
    Adjustment actions are necessary Adjust the accounts.
    No adjustment is necessary Input TC 290 .00 using the appropriate BS.
    Both accounts are valid Do not input TC 020. Combine all the returns belonging to one taxpayer under the correct TIN (TC 290) and back out the data pertaining to the other account (TC 291).
  3. If there are two taxpayers involved, follow the procedures below:

    If... Then...
    A taxpayer files a return using an incorrect TIN Research for the correct TIN for the taxpayer that is posted to the invalid segment.
    Taxpayer's return post to incorrect TIN Take the appropriate action to post the data to the correct TIN.
    A TIN needs to be reopened Input TC 012.
    A valid TIN cannot be determined Contact both taxpayers. (If contacting by telephone, you must authenticate who you are speaking to prior to discussing tax account information.)
    Both taxpayers claim the same TIN or one does not respond Route the case to Entity Control with all pertinent information.  (10-01-2015)

  1. NOMRG-400 transcripts generate when one or both accounts contain a module with an unreversed TC 400. (When an account returns to a different file validity than the account's correct SSN validity, REVAL-400 transcripts generate.)

  2. To resolve the NOMRG-400 transcripts, examine the transcripts and returns (if secured) to determine if the account consolidation is necessary.

  3. If the account consolidation is NOT necessary, or impossible, destroy the transcripts.

  4. If the account consolidation is necessary (the "from" account has a return or payment data necessary to update the "to" account), follow procedures below:

    1. Prepare a Form 12810, Account Transfer Request Checklist, for Accounting to reverse the TC 400.

    2. Attach transcripts to the memo.

    3. Maintain a suspense file until Accounting verifies the TC 400 is reversed.

    4. Receive verification, input entity transaction to consolidate the accounts. (Input TC 040 or 041, as appropriate.)

    5. Close the case file and destroy the transcripts.  (10-01-2008)

  1. NOMRG-VEST and REVAL-VEST transcripts generate when one or both accounts contain a vestigial (retention) record for the same tax period. REVAL-VEST transcripts generate when the file validity account is returned to the account's correct TIN validity.

  2. Examine the transcripts and returns (if secured) to determine if the account consolidation is necessary. Take the following action:

    1. Request the transcripts for those tax modules on the retention register.

    2. If consolidation is unnecessary or impossible, destroy the transcripts.

    3. If consolidation is necessary, see IRM, Reinstating Retention Register Accounts, for instructions on reinstating retention register accounts and when to maintain a suspense file waiting a reply.  (09-02-2014)
One Taxpayer Involved

  1. If one taxpayer filed two tax returns using different TINs, data on both of the returns can result in a tax assessment.

  2. Request and review tax returns, if needed. Do the following:

    1. Transfer the account involved from the retention register to the MF.

    2. Follow NOMRG-DUP procedures if each account has a TC 150 (return posted).

    If... Then...
    There is one TC 150 and account can be merged 1. Resequence account.
    2. Input TC 290 for refiling on valid EIN, if returns pulled for verification.
    3. Input entity transaction to consolidate accounts when reinstatement is completed. (On REVAL-VEST transcripts, input TC 040 or TC 041, as appropriate.)
    There are two TC 150 1. Zero out invalid account and combine tax on valid account.
    2. Input TC 020 to delete filing requirements one or more cycles after invalid account has been zeroed out.
    3. Input entity transaction to consolidate accounts when reinstatement is completed. (On REVAL-VEST transcripts, input TC 040 or TC 041, as appropriate.)  (09-02-2014)
Two Taxpayers Involved

  1. Determine if returns are for separate entities.

    If... Then...
    Entities are separate Close the control base as "NOACT" .
    Entities are not separate 1. Follow procedures in IRM and IRM, as appropriate.
    2. When reinstatement is complete, input the entity transaction to consolidate accounts. (On REVAL-VEST transcripts, input TC 040 or TC 041, as appropriate.)

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