3.42.10  Authorized IRS Providers (Cont. 1) 
Retention of Forms  (10-01-2015)
Retention of Fingerprint Cards (FPC)

  1. Fingerprint cards (FPC) may be destroyed 3 years after they are scanned. The electronic back up copy will be available if necessary.  (10-01-2015)
Retention of Office of Appeals

  1. Generally, the Office of Appeals retains e-file appeal cases for 2 years plus the current year. The file includes the information sent by Andover plus their case memorandum.

  2. Andover will maintain the case files for 1 year after they are scanned into the EHSS.

  3. For additional information, see Document 12990, Records Control Schedules: Appeals.  (10-01-2015)
The Third Party Data Store (TPDS)

  1. TPDS, maintained at the Enterprise Computing Center in Martinsburg, WV, is a database that is used to store and update all IRS e-file application information and generate electronic filing identification numbers (EFIN), electronic transmitter identification numbers (ETIN), letters and reports. The database is also used to store information for other e-services products as well. There are two ways to access the information:

    1. Integrated Enterprise Portal (IEP) Employee User Portal (EUP) is a web hosting infrastructure. It supports an Intranet portal that allows IRS employees to access business applications and data. The IEP EUP registration process allows users to register for access to e-services. The Online 5081, Automated Information System (AIS) User Registration/ Change Request is used to identify the IEP EUP user roles for managerial approval. Refer to the Form 5081 for a complete listing of roles and role definitions. View "e-file" application (AVEA) is the most commonly selected role associated with application usage. The role only allows view access of the e-file application within the IEP EUP.

    2. Integrated Enterprise Portal (IEP) Registered User Portal (RUP) infrastructure gives users the ability to electronically file certain returns and create or revise certain applications via the internet after registering as an e-services user.

  2. All e-file applications receive a unique tracking number that can be used as a search criterion for e-file applications on the database. The tracking number indicates the year, month, day and time that the e-file application was entered into TPDS.

  3. A six digit numeric EFIN is generated for all new Authorized IRS e-file Providers.

  4. Applicants who choose the provider option of transmitter, software developer, online filer, large taxpayer or affordable care act provider (ACA provider) will be issued a five-digit numeric electronic transmitter identification number (ETIN).  (10-01-2015)
Login to E-Services

  1. Employees access e-services products via the Integrated Enterprise Portal (IEP) Employee User Portal (EUP).

  2. The Standard Employee Identifier (SEID) and password are used to login.

  3. Once the SEID and password are entered and the submit button is selected, the employee will be able to navigate through e-services.  (10-01-2015)
Two Major Menu Areas

  1. Two major menu areas are displayed after login:

    1. Applications section which allows the user to access applications such as e-services.

    2. Tools sections which allows the user to perform actions such as password maintenance and logging off of the system.  (10-01-2015)
Accessing the e-file Application

  1. The IRS e-file application is accessed by clicking the following links in the "Applications" section:

    1. select the "esrv-appl-efile" link;

    2. select the "e-services" link on the following page;

    3. select the "e-file" link on the next page.

  2. When the "process" link is accessed, the following items may display:

    1. New Print Notice

    2. Finger Print Card Entry

    3. Group worklist

    4. Recheck Suitability

    5. Individual worklist

  3. Under the "reports" link, the following items will display:

    1. Create New application

    2. Software Developer

    3. Search e-file application

    4. Personal Suitability  (10-01-2015)
Disclosure and IRS e-file Application

  1. Observe disclosure safeguards as prescribed in IRM 11.3, Disclosure of Official Information.

  2. The Internal Revenue Code (IRC) Section 6103 and the Privacy Act contain the disclosure restrictions for tax and non-tax information.

  3. See IRM, Authentication and Disclosure Guidelines for durable power of attorney.

  4. An unauthorized disclosure that involves an Authorized IRS e-file Provider viewing the information of another provider on the third party data store must be reported to your Manager, then to the Computer Security Incident Response Center using the Computer Security Incident Reporting Form or calling 240–613–3606. This disclosure can occur if an Integrated Enterprise Portal (IEP) Registered User Portal (RUP) user accesses the system and views application information that they are not authorized to access. Please reference IRM , Unauthorized Access and Disclosures of Returns or Return Information for unauthorized disclosure procedures.

  5. When an e-help assistor receives a telephone call from a caller concerning the status of their Freedom of Information Act (FOIA) request, direct them to the IRS Disclosure Office for their state. Provide the caller with the public liaison telephone number and the disclosure office address.

  6. IRS Disclosure Offices respond to written FOIA requests for agency records not available in the IRS reading room. They receive and process these requests within time frames set by law. You can refer them to the IRS FOIA Guide available on IRS.gov for more detailed information.

  7. E-help assistors can provide a yes or no response to a telephone inquiry requesting verification as to whether a business or organization is a provider.

  8. Refer the caller to http://www.irs.gov for a list of providers in their area.


    E-help assistors can only verify those providers who chose to be listed on the "Authorized IRS e-file provider locator" .  (10-01-2015)
Updating the TPDS for Previously Accepted Applicants

  1. If the applicant needs to update or revise their application direct them to e-services.

  2. If the provider is unable to access the e-services application, a documented interaction may be used. For disclosure purposes, the name, company name (if applicable), electronic filing identification number (EFIN), electronic transmitter identification number (ETIN), taxpayer identification number(TIN) (SSN or EIN) or preparer tax identification number (PTIN) ) must be verified in an interaction. For additional authentication, the company address is sufficient (for example, if the company name the caller gives differs from our records). The individual requesting the revision or to update the application, must be listed as a principal, responsible official or delegated user with the appropriate authorities on the existing e-file application. Exception: Some applications have EINs with only one person on them as a principal and/or responsible official. If an employee of the corporation contacts you stating that the person on the application is no longer associated with that EIN, do the following:

    1. Ask the person who will be added on as a principal and/or responsible official to fax, on company letterhead, a note stating who is to be removed from the application and why, who is to be added, their SSN, DOB and certification that the structure of the company has not changed due to the removed person no longer working for the firm. Ask if they can provide information on the company charter listing the names of the current officers. This can also be researched on Secretary of State Contact Information the Secretary of State Contact Information page. Request that the original letter be mailed to the Andover e-help Desk for inclusion in the EFIN file. The letter must be signed by a current officer of the firm.


      Sole proprietorships are not transferable. Potential EROs who purchase an existing e-file business must apply for a new EFIN.

    2. On receipt of the fax which contains all necessary information, input the person on the application and remove the original principal and/or responsible official. Do not input the terms of agreement or suitability questions for the individual.

    3. Contact the new principal/responsible official and request that he/she registers for e-services if they have not previously done so. The new principal/RO must complete the revisions on the application and submit it.

  3. If the legal name of the business is being changed, the entity change must already be reflected on IDRS before it can be changed in TPDS. However, if the company has a new EIN and/or the business structure has changed, a new application is required.

  4. Assistors will not add or remove principals, responsible officials or delegated users or submit an application based on a phone call, even if speaking to an authorized person. These changes require a signature of the authorized person.  (10-01-2015)
Processing of Fingerprint Cards

  1. Applicants must include fingerprint cards (FPC) for all principals and responsible officials listed on the e-file applications unless they are exempt from submitting the FPCs. If they are exempt and claim professional status, evidence of the professional status must be validated as stated in IRM, Professional Status Review and Processing. The third party data store (TPDS) provides an alert to submit all FPCs from e-file application for FBI processing.

  2. Review FPCs to ensure that the following is included on the card:

    1. Name;

    2. Date of birth;

    3. Citizenship;

    4. Sex;

    5. Social security number;

    6. Signature of the person fingerprinted;

    7. Signature of the official taking fingerprints.

  3. With the exception of a signature, any information missing from the FPC can be obtained by telephone call or correspondence to the applicant or by copying the information from the online application.

  4. FPCs without signatures will be returned and not entered into TPDS. Send Letter 3643 (Exhibit 3.42.10-52 Letter 3643).

  5. On a daily basis, scan all FPCs for Federal Bureau of Investigation (FBI) check into the Automated Electronic Fingerprinting (AEF) and submit them to the FBI electronically in accordance with the AEF User Manual.

  6. Third party data store (TPDS) displays six statuses for FPCs:

    1. "Not-on-File" - no FPC was received from the applicant.

    2. "Not-Pulled" - the FPC was received from the applicant but not pulled for FBI check.

    3. "In-process" - the FPC was received and sent to the FBI for processing but has not yet been returned.

    4. "Data" - findings with history are received back from the FBI.

    5. "no data" - findings with no history are received back from the FBI.

    6. "Unprocessable" - FBI was unable to process the fingerprint that was submitted.

  7. Procedures after FBI results have been received.

    1. Manually update TPDS to show the FBI findings by using the drop-down box located in the fingerprint tab.

    2. Clerical will forward the FBI findings for adjudication.

    3. If the FBI is unable to process the FPC and no second fingerprint card is available, generate Letter 3643 (Exhibit 3.42.10-52) requesting a new FPC. If the applicant does not provide a new FPC within thirty days from the date of the letter, place the applicant’s provider options in "dropped" status.

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  9. If the name check is returned with a negative search result, the applicant can be accepted into IRS e-file. A negative search result means that the FBI did not find the name in its criminal arrest database. If the name check is returned from the FBI showing a criminal history or as a reject, forward FBI findings for adjudication.

  10. For retention of fingerprint card, see IRM, Retention of Fingerprint Cards (FPC).  (10-01-2015)
Review of Professional Status and Credentials

  1. Acceptable evidence of a currently active professional status:

    1. A certified public accountant (CPA) must show qualifications to practice as a CPA in any state, commonwealth, possession, territory or the District of Columbia and must not currently be under suspension or disbarment from practice.

    2. An enrolled agent may submit a copy of a currently active enrollment card issued by the IRS or provide their enrolled agent number.

    3. A banking official must submit a copy of their bonding certificate and proof of fingerprinting within the last two years.

    4. An officer of a publicly owned corporation must submit evidence on corporate letterhead which carries their name as an officer, the stock symbol, the exchange where listed and the name under which the stock is traded for the individuals listed as principal and/or responsible official.

    5. An attorney must show good standing in the bar of the highest court in any state, commonwealth, possession, territory or the District of Columbia and also show they are not currently under suspension or disbarment from practice before the IRS or the bar.  (10-01-2015)
Professional Status Review and Processing

  1. All principals and responsible officials that have selected a professional status of attorney, bank official, certified public accountant (CPA), enrolled agent (EA) and officer of a publicly owned corporation will have completed the professional status information on the personal information page. This will include:

    • Professional type

    • State where licensed/ credentialed, license number, expired (yes or no) and expiration date for CPAs and attorneys

    • Enrolled agent number for EAs

  2. Upon submission of the e-file application a worklist, APP_CRDNTL_NEEDED, will be created in the application review workgroup.

  3. When working APP_CRDNTL_NEEDED worklist, click on link to access the personal suitability/suitability tab of the individual and then select the professional credentials tab at the top of the page.

  4. Professional type will be populated from the drop down menu with the first professional status indicated by the principal or responsible official on the Personal Information page.

    1. For CPAs and attorneys, the state, license/credential number and expiration date will populate from the personal information page for up to five credentials provided for each professional status. Verify this information as indicated below (If more than one appears, only one needs to be verified). Research “The American Institute of Certified Public Accountants” found on the EPSS Portal “Quick Links” for CPAs. Check the appropriate state bar association for attorneys found at PublicRecordCenter.com

    2. For enrolled agents, their number will populate from the personal information page.

    3. To verify officers of publicly held corporations, check the List of Publicly Traded Companies on Public Record Center.com. Select the first letter of the company; Once you locate the company select profile; Select company profile and you will see the officers listed under Executives.

    4. To verify bank officials, request the documentation indicated in IRM, Personal Information Page for Principals either by telephone or by mailing Letter 3643 to the individual.

  5. Select the appropriate response from the drop down menu as to whether supporting documentation was received (Validating status as indicated above is equivalent to receiving documentation).

  6. If professional status cannot be confirmed or documentation is needed, contact the applicant either by telephone or by mailing Letter 3643 requesting the documentation needed for the indicated professional status as described in IRM, Personal Information Page for Principals.

    1. If a certificate is not normally issued, a letter indicating good standing from the bar or regulatory agency will be sufficient.

    2. The credentials for attorney, CPA and EA can be destroyed after they have been entered in TPDS. Documentation received for banking official and officer of a publicly owned corporation must be maintained for three years after the application has been dropped.

    3. Input all required information, obtained from documentation provided, on the personal information page of the integrated enterprise portal (IEP) employee user portal (EUP).

  7. After verifying professional status select a professional validation status from the drop down menu.

    • Select a professional validation status from the drop down menu.

    • Select the current date as the professional validation status date.

    • Select a status, as of the effective date, from the drop down menu.

    • Make the same entries above for each principal and responsible official on the e-file application, if applicable.  (10-01-2015)
Credit Checks

  1. Credit checks may be performed on an as needed basis by the Andover e-help Desk and the assistor will update the application with related information.  (10-01-2015)

  1. Suitability is the process used by the IRS to determine if the firms and individuals listed on e-file applications are appropriate to distribute electronic filing products and services under IRS e-file.

  2. The IRS sets suitability standards to screen and monitor applicants to ensure that they maintain a high degree of integrity and adhere to the highest professional and ethical standards.

  3. Suitability checks may include an FBI criminal background check, credit history check, IRS tax compliance check and prior history check for compliance in IRS e-file.

  4. The suitability statuses are "passed" , "failed" , "recheck" , "in-process" , "none required" and "incomplete" .

  5. Suitability checks are not conducted on the following:

    1. Software developers who function solely as software developer

    2. Providers who offer e-file solely as an additional benefit

    3. IRS sponsored Not for Profit organization

    4. Large Taxpayers

    5. Delegated users

    6. Contacts/ Alternate contacts

    7. Affordable Care Act Provider (ACA) providers who are covered entities

  6. Suitability checks for new applications must be completed within 45 calendar days of submission. If the suitability status remains “in process” for more than 45 days, the assistor must send acknowledgement, Letter 2462, indicating that an additional 30 days is needed to process the application.

  7. See Publication 3112 and Rev. Proc. 2007-40 for suitability information.  (10-01-2015)
Fingerprint Cards Results

  1. Applicants will not be accepted into IRS e-file until any applicable FBI fingerprint results are received and analyzed.

  2. The applicant will be accepted into IRS e-file when the fingerprint card (FPC) is returned showing no criminal data and all other suitability checks have been completed and passed.

  3. Adjudication will evaluate the fingerprint reports for the following:

    1. History of conviction or current indictments for financial crimes; e.g., tax crimes, money laundering, false claims, etc;

    2. Dishonesty, e.g. bank fraud, mail fraud, securities fraud, etc;

    3. Breach of trust; e.g., embezzlement, violations of fiduciary trust, theft by misrepresentation, etc. (U.S. Title 18, 26 and 31).

  4. If convictions are found, adjudication may recommend that the applicant be denied participation or the provider may be sanctioned from IRS e-file as a result of conviction or indictment of crimes under revenue laws of the U. S. under Title 18, 26 and 31 or of a state or other political subdivision.

  5. Adjudication will evaluate other items on the criminal record to determine if the nature of the items will adversely impact IRS e-file.

  6. Adjudication will consider the seriousness of the offense and duration of time since the offense when recommending that the applicant/provider be denied participation/sanctioned.  (10-01-2015)
Recommendation for Executive Review Board

  1. When or if EPSS disagrees with the decision recommended by CI (Criminal Investigation) or adjudication of a one or two year suspension or expulsion, take the following actions:

    1. Forward the case to manager for contact via telephone, e-mail etc. with CI or adjudication for further discussion or reversal of recommended decision.

  2. If manager/ CI or adjudication is not able to agree/resolve the recommendation after additional discussions, contact the suitability program analyst before any action is taken. The analyst will advise when to prepare and send Interim Letter 2462 (SC/CG) to applicant advising of extension of review. Update comments on integrated enterprise portal (IEP) employee user portal (EUP).

    1. The suitability analyst will be notified if no agreement is reached and forward the case for review by adjudication executive for "FINAL" decision on case.

    2. Upon completion of the review by the executive, the suitability analyst will provide instructions to resolve the case in accordance with the decision rendered.  (10-01-2015)
Daily Suitability

  1. Daily suitability is completed on new e-file applications prior to their acceptance into IRS e-file.

  2. The daily suitability process conducted on new applicants may include an FBI criminal background check, professional status check, a credit history check and tax compliance check.

  3. Daily suitability is conducted on all taxpayer identification numbers (TINs) listed on the e-file application for the firms and the principals and responsible officials. Applicants with compliance issues will be denied participation in the program until all issues have been satisfactorily resolved. See IRM, Levels of Infractions-Level Two

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    Identity Theft See IRM
  5. For daily suitability, applicants that require a suitability check will have an electronic filing identification number (EFIN) generated or reactivated and associated TINs will be added to the daily ASAP extract for processing. The program updates the ASAP results with a "hit" or "no hit" and provides comments in the file when there are hits. Andover leads will receive a worklist notification for the hits and assign them to an assistor for research and follow up.

  6. There are several worklist items related to daily suitability:






    See IRM , Worklists for a description of each worklist item shown above.

  7. If the decision is made to fail suitability, it will affect all associated EFIN(s).  (10-01-2015)
Procedures for Daily Worklist

  1. A daily worklist is generated when the IRS receives an issue from the automated suitability analysis program (ASAP) on a firm or individual within an e-file application. ASAP results will post as a "hit" and the issue will be annotated in the ASAP description.

    • Research via IDRS to determine if the EIN/SSN is in compliance.

    • Research to determine all associated electronic filing identification number (s) (EFINs) for the employer identification number (EIN)/ social security number (SSN) in question.

    • Research EFIN comments to see if the issue is already being worked.

  2. Additional steps for daily worklist

    If Fingerprint Status is Then
    Not on file and professional status is not passed Move suitability status from "in-process" to "incomplete"
    Not on file and professional status is passed Enter in application comments, "Working entire case"
    Not on file and comments indicate that FPC was received over a week ago Bring case to your lead’s attention
    In-process and the worklist item is current Work current issues and all other TIN(s) on the application that can be passed
    In-process and the worklist item is "Late Suitability" Check comment to see if assigned, reassigned to assistor, if not resolved
    Unprocessable Work all other TIN(s) on the application that can be passed, reassign worklist to ANSC_Lead_TE_Clerks
    Data Work all other TIN(s) on the application that can be passed, 1. Check fingerprint tab description to ensure results were forwarded to ASDC, if not bring to your lead’s attention for print and forwarding, reassign worklist to designated employee 2. Check fingerprint tab description, if a specific TE is indicated, reassign worklist item to the applicable assistor. 3. If no specific TE is indicated, annotate in comments "Reassigned" to ANSC_Management Workgroup
    No Data or Not Pulled Enter in application comments "Working Entire Case"  (10-01-2015)
Procedures for Data to be Sent to North Atlantic Area Scheme Development Center and Fingerprint Card Adjudication (FPC) for Review

  1. When fingerprint cards are processed electronically by Automated Electronic Fingerprints (AEF) and data is found, an official record of arrest and prosecution sheet is printed.

  2. Clerks will match the social security number (SSN), name and date of birth on the record of arrest and prosecution sheet to the application. If they do not agree, the assistor will research IDRS (e.g., INOLE, name, etc.) to verify the applicant.

  3. Clerks will create an e-mail to include area scheme development center (ASDC) referral report containing the SSN and names to criminal investigation. Update application comments page and the fingerprint cards tab: "Data forwarded to adjudication . do not pass" and save.

  4. Criminal investigation (CI) will run the information through their database (e.g. STARS, CIMIS, etc). Criminal investigation (CI) will place a check mark next to the SSN that they are requesting to retain for review.

  5. Clerical will send Form 3210, Document Transmittal containing all new cases marked, including annotating the electronic filing identification number (EFIN) and SSN on the upper right hand corner, to CI. This should be done weekly.

  6. Clerks will input remaining cases (cases not selected by CI) into EHSS for adjudication by FPC adjudication and update comments on the application comments page and the Fingerprint Cards tab;" Data forwarded to adjudication. Do not Pass" , then save.

  7. Fingerprint adjudication will determine if the applicant is subject to suitability criteria. If subject to adjudication criteria, a referral sheet will be completed and include the proper terminology for the fail letter or court disposition (CD) letter. Adjudication will then return the RAP sheet and referral back to EPSS Andover.

  8. The assistor will then complete the regular suitability checks on the SSN (and employer identification number (EIN), if applicable). Suitability will be worked as a daily worklist item. Follow procedures in suitability procedures after initial research (See IRM, Suitability Procedures for Daily Research), with the following adjustments:

    • If adjudication recommends pass and there are no other suitability issues, change all relevant TIN suitability statuses to passed. Allow automated system to update all other status and issue the acceptance letter.

    • If adjudication recommends "fail" , send Letter 2916 SC/CG, Denied FBI Research and address all suitability issues. See Exhibit 3.42.10-26

    • If adjudication needs additional information, then send the CD letter.

    • If adjudication recommend "pass" , but there are suitability issues, follow suitability procedures and send to management review. Issue Letter 3479-D.  (10-01-2015)
Procedures for Appeals on Fingerprint Card Data

  1. Below are the appeal procedures to be followed regarding fingerprint card data.  (10-01-2015)
1st Appeal

  1. Get the folder with original record of arrest and prosecution sheet and paperwork.

  2. Attach a new fraud referral sheet with electronic filing identification number (EFIN), social security number (SSN), name of applicant and Z /-T freeze (if applicable). See IRM Exhibit 3.42.10–5, Form 14632, Electronic Filing Suitability North Atlantic Area Scheme Development Center (NAASDC) Referral and attach it to the appeal and previous paperwork.

  3. Send to adjudication for reconsideration. If no personal information page was included in the first NAASDC referral, include it now.


    If no Z /-T Freeze information was indicated in the first referral and there is a Z /-T freeze, then the case will go to NAASDC.

  4. Document on the application comment section, "appeal forwarded to adjudication" .

  5. The appeal will be reviewed and decision whether to pass the applicant or uphold the previous fail recommendation will be made.

  6. When the response is received from adjudication, complete Form 14629, First Appeal – Suitability Recommendation.

  7. If pass, update application statuses and comments and send pass Letter 2914D: D/OwnAft1S Daily Ltr Exhibit 3.42.10-23 and also the appropriate acceptance letter.

  8. If upholding the fail, send Letter 3062, NAASDC: Resp to 1st Appeal/Request Denied ( Exhibit 3.42.10-32 ).

  9. If necessary, send Letter 2913D (SC/CG) Officer & Corp Partner Failed Suit ( Exhibit 3.42.10-21).  (10-01-2015)
2nd Appeal

  1. Get folder with original and 1st appeal paperwork.

  2. Complete Form 14633, OOA Appeal RightsSuitability Recommendation (see Exhibit 3.42.10-4 )

  3. Make complete copy of all paper work and give case to designated Office of Appeals assistor.

  4. Wait for decision; the Electronic Return Originator (ERO) will be unable to participate in IRS e-file until a decision is rendered by the office of appeals.  (10-01-2015)
Suitability Credit Check

  1. Credit checks may be requested at the discretion of e-help Desk.  (10-01-2015)
Suitability Processing Time

  1. Daily suitability checks of all new applicants must be completed within 45 days of submission or receipt of the complete applications and all documentations.

  2. When the assistor determines the 45 day processing time for e-file applications will not be met, the assistor will send the applicant Letter 2462 (SC/CG) Delay in Processing and Acknowledgement Letter, acknowledging that we received their application and to allow an additional fifteen (15) days for processing. See Exhibit 3.42.10-61  (10-01-2015)
Continuous Suitability Review

  1. After acceptance into IRS e-file, providers are subject to continuous suitability checks, which is the review of IRS records.

  2. The checks are performed to determine:

    1. if all business and personal tax returns are filed

    2. if all tax liabilities are paid or appropriately addressed (e.g., installment agreement)

    3. if there are any fraud penalty assessments

    4. if there is an open IRS criminal investigation

  3. Third party data store (TPDS) provides weekly worklists of Taxpayer Identification Numbers (TINs) that meet continuous suitability criteria status. Suitability must be "passed" , a provider status must be of "accepted" and electronic filing identification number (EFIN) must be "active" .

  4. When automated suitability analysis program(ASAP) criteria are identified, ASAP results must be manually entered prior to the TIN being manually updated to "recheck" .

  5. Inquiries such as telephone contact or Letter Of Inquiry (LOI) must be made to determine if the criteria identified in the ASAP report constitutes passing/failing the EFIN(s). All telephone contacts must be documented on the comments section of the e-file application and in the e-help Support System (EHSS).

  6. If a provider submits a new e-file application for an additional office and there are compliance issues with the firm(s)/ individual(s), the new office will not be allowed to participate until all compliance issues are resolved. TPDS automatically monitors suitability of principals, responsible officials and firms.  (10-01-2015)
Automated Suitability Analysis Program

  1. The automated suitability analysis program(ASAP) program uses criteria from Master File (MF) to determine a provider's compliance.

  2. ASAP is used for new/revised applications and continuous suitability review. It analyzes both IMF and BMF data to determine if applicants meet various suitability criteria. ASAP also analyzes the valid, invalid and spousal SSN files (SSF).

  3. ASAP may identify issues that an assistor has previously addressed or new issues may be identified through research that did not originally appear on the ASAP report.

  4. In either case, the assistor must address all issues with the provider through either a telephone call or correspondence.

  5. Review the comments section of the e-file application to see if prior ASAP issues were identified. Historical data file folders must be reviewed for all ASAP reports with literals/hits to ensure the issue was not previously addressed.

  6. Some cases contain unusual circumstances such as those involving the North Atlantic Area Scheme Development Center (NAASDC). The appropriate field office or submission processing center function must be contacted to obtain further clarification on these issues. Cases must be referred to the NAASDC via the designated assistor. Tax specialists and e-file monitoring coordinators must be contacted ONLY when a suitability issue may have been previously addressed by the respective function.  (10-01-2015)
Suitability Analysis Worklists from Master File

  1. An entity code on MF (Master File) identifies individuals and businesses that participate as EROs (Electronic Return Originators), transmitters and reporting agents, etc. This entity code generates a worklist when specific transactions appear on a tax account that would impact suitability.

  2. An extract of all taxpayer identification number (TINs) subject to suitability in IRS e-file is used to mark the masterfile account on a biannual basis for IMF and an annual basis for BMF. The system turns this indicator on and off.

  3. The current ASAP (Automated Suitability Analysis Program) criteria is used to generate worklists MF_FIRM_TRANS_IRS and MF_FIRM_IND_IRS. The specific criteria used is;

    1. Fraud penalties (TC 320) of any amount for any of the last 6 years.

    2. Intelligence Hold/Criminal Investigation (Z or -T Freeze).

    3. Deceased taxpayers, TC 540.

    4. Extension of Time for Filing (TC 460) for other than current year or later and no TC 150 present.

    5. Offer-in-Compromise Pending (TC 480)

    6. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    7. No return posted and MF status 02, 03 or 04 on any of the last 6 tax modules on record. If the extension has expired work.

    8. Potentially Dangerous Taxpayer (PDT), TC 971 with AC 271 or AC 272.

    9. Currently Not Collectable accounts (TC 530) with the following closing codes: 03, 09, 10, 12, 13 and 39.

    10. Identity Theft Indicator (IDT) TC 971 with AC 501, AC 506, AC 522 or AC 524.

  4. The worklists are generated for the specific tax modules affected for each applicant’s account when the suitability criteria are met and include the tax year, MFT code and the dollar amount when applicable.

  5. The worklists are worked in accordance with continuous suitability processing procedures.  (10-01-2015)
Procedures for Master File Transcript Suitability Worklists

  1. Worklists MF_TRANS_FIRM_IRS and MF_TRANS_IND_IRS are issue driven, on a weekly basis included in workgroup ANSC_Leads and generated only once per issue. These worklists will be generated as the information is received. firm and/or personal suitability will systematically move to "recheck". automated suitability analysis program(ASAP) results will post as a “hit” and the issue will be notated in the description:

    • Research via IDRS to determine if employer identification number (EIN)/ social security number (SSN) is in compliance.

    • Research EFIN comments to see if the issue has been included in a previous letter sent within the previous 45 days. If letter was issued add comment, "transcript no action-already worked" .

    Additional steps for worklists MF_TRANS_FIRM_IRS and MF_TRANS_IND_IRS:

    • Research to determine all associated EFIN(s) for the EIN/SSN in question.

    • If the Electronic Return Originator (ERO) is in compliance, enter ASAP results "no hit" and third party data store (TPDS) comments "no hit from IMF (BMF) worklist" .

    • Move suitability status to "pass"

    • Manually update firm and/or personal suitability to ‘re-check’ if LOI is to be issued.


      If the firm has suitability issues, only update the firm suitability to "recheck" .

    • If ERO is non compliant then notate in "ASAP comments" the issue and EFIN which the Letter of Inquiry (LOI) was generated from.

    • If Z or -T freeze is identified and it is a new issue or has not been addressed in the previous six months, forward the case to a designated assistor for elevation to North Atlantic Area Scheme Development Center (NAASDC).

    • If LOI is issued, up to two EFIN(s) may be listed on the Letter 3479(CG). The wording and all associated EFINs, systematically populates on all letters generated.

    When a worklist generates for an issue (ex. balances due, missing return, fraud penalties assessed) and the taxpayer has not received any notice from the IRS and there are no other issues, do not send the LOI. However, if additional delinquent issues, are discovered by research, then address all issues in the LOI.  (10-01-2015)
Initial Research for Automated Suitability Analysis Program(ASAP) Literals/Hits For worklist Items Transcripts and Provider Suitability Report

  1. The research tools for IMF and BMF are:

    1. The third party data store (TPDS)


    3. Integrated Automation Technologies (IAT)

    4. Document 6209, ADP and IDRS Information, for explanation of sequence, status, transactions and indicator codes

    5. Internal Revenue Manuals

  2. Research required to include but is not limited to:

    • Module balances

    • Returns filed

    • Reverse transaction codes

    • Installment agreements

    • Freeze codes

    • Unpostables

    • Offers in Compromise

    • Assessment of fraud penalty

    • Bankruptcy

    • Currently Not Collectible (CNC)

    • Citizenship

    • Incarceration

    • Identity Theft

  3. If new/additional issues are identified through ASAP/research, research IDRS. These issues must be addressed in the initial contact, e.g., LOI or telephone call.


    If no new/additional issues are identified, update ASAP to "no hit" and suitability of SSN and/or EIN to "pass" . Notate in the description field and application comment page, "Transcript dated mm/dd/yy already being worked" or "Transcript dated mm/dd/yy no suitability issues" .

  4. When a phone call is made to a provider to address personal suitability issue(s) and the individual no longer works for the company, request that they revise their application via the Integrated Enterprise Portal (IEP) Registered User Portal (RUP).

    1. If the firm is replacing the individual, a fingerprint card (FPC) may also be necessary. If a FPC is necessary, please have them submit it after revising the application online and enter appropriate comments on TPDS.

    2. If a revised application is not received within 30 days, a Letter of Inquiry (LOI) is issued with a reference made to the telephone conversation.  (10-01-2015)
Reasonable Cause and Automated Suitability Analysis Program Literals

  1. Reasonable cause is based on all the facts and circumstances in each situation.

  2. The firm(s)/ individual(s) must provide the necessary tax returns, payments and/or information and must address reasonable cause concerning each violation/infraction.

  3. Reasonable cause relief is generally granted when the taxpayer exercises ordinary business care and prudence in determining their tax obligations, but was unable to comply with those obligations.

  4. Ordinary business care and prudence includes making provisions for business obligations to be met when reasonably foreseeable events occur.

  5. In determining if the taxpayer exercised ordinary business care and prudence, review available information including taxpayer's reason, compliance history and circumstances beyond the taxpayer's control.

  6. Reasonable cause is referenced in IRM, Penalty Handbook or Part 21, Customer Account Services.

  7. If there is a -C (combat zone), -O or -S (disaster freezes) on an account, this constitutes reasonable cause.  (10-01-2015)
Procedures for Literal/Hits on Automated Suitability Analysis Program Report

  1. This process is designed to automate the input of the automated suitability analysis program(ASAP) results from the compliance check against the IMF and BMF systems. The process records the results received back for each TIN. A worklist item is generated for each TIN where there is a "hit" received on the results. The suitability status changes to "pass" for TINs with no "hits" and where all supporting documents have been received and passed validation or have no issues, returned back from the FBI check.

  2. The worklist contains only applicants that have issues identified on their applications, a "hit" from the ASAP upload or ASAP results not updated within 14 days from being selected. Note that the persons and organizations that have been selected for ASAP and are "in process" , may be on the worklist if the fingerprint card (FPC) results have not been received or the assistor is having problems validating the professional credentials.

  3. Literals that appear on ASAP reports are based on programmed criteria. Some circumstances such as late filing/paying history are not part of the criteria, but may be considered when other ASAP criteria are present.

  4. IRM Procedures After Initial Research, for specific and for pass/fail instructions are to be followed after a decision is made.  (10-01-2015)
No Suitability Checks Met Literal on Automated Suitability Analysis Program Report

  1. The literals "NO SUITABILITY CHECKS MET AGAINST MF" and/or "NO SUITABILITY CHECKS MET AGAINST SP" will only appear on daily suitability ASAP reports.  (10-01-2015)
Offer in Compromise (OIC) Literal on Automated Suitability Analysis Program Report

  1. Check for pending/posted Offers in Compromise (OIC), TC 480. ASAP will check for TC 480 (offer pending), TC 481 (offer rejected) and TC 482 (offer withdrawn). The assistor will check CC TXMOD, IMFOL and BMFOL for these transaction codes.

    1. If an OIC is pending (TC 480) or if an OIC is accepted (TC 780) and no other literal is present, pass.

    2. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  2. See IRM Procedures After Initial Research.  (10-01-2015)
North Atlantic Area Scheme Development Center (NAASDC) Literal on Automated Suitability Analysis Program Report

  1. North Atlantic Area Scheme Development Center (NAASDC) literals include:

    1. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    2. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    3. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    4. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  2. If the issue is the same as a previous year, the case must be resubmitted to NAASDC to get an updated status/recommendation.

  3. If NAASDC transaction/freeze codes have been reversed and no other literal/hits appear, update this information on the ASAP (Automated Suitability Analysis Program) section of application.

  4. If the NAASDC transaction/freeze codes have not been reversed, submit documentation to a designated assistor for referral to NAASDC. The designated assistor will:

    1. Prepare the NAASDC Suitability NAASDC referral (Exhibit 3.42.10-5., Form 14632, Electronic Filing Suitability North Atlantic Area Scheme Development Center (NAASDC) Referral)

    2. Attach IDRS screen print highlighting the TC 91X

    3. Attach TPDS summary page

    4. Return the case so it can be routed to the NAASDC for review and recommendation

  5. Upon receipt of NAASDC's recommendation, the designated assistor will review the suitability, prepare the recommendation sheet and make the appropriate recommendation.

  6. The assistor will review the NAASDC recommendation for appropriate and specific language for the denial/sanction letter. See Publication 3112, IRS E-File Application and Participation for denial/sanction and reasons on denial to participate in IRS e-file.

  7. If NAASDC recommends fail and provides specific reasons that support that recommendation, recommend fail. If appropriate and specific language is provided, issue the applicable letter. The NAASDC will indicate the level of Infraction and the lead and/or manager will determine the suspension time frame.

  8. If appropriate and specific language is not provided, the assistor will return the recommendation to the NAASDC for correction.

  9. If NAASDC returns the case without additional appropriate and specific language , recommend pass. Annotate the Suitability NAASDC referral sheet, update TPDS and document comments in ASAP section.  (10-01-2015)
Potentially Dangerous Taxpayer Literal on Automated Suitability Analysis Program Report

  1. The potentially dangerous taxpayer (PDT) literal, TC 016 identified in the automated suitability analysis program (ASAP) report. If you are threaten, harassed or forcibly interfered during or related to, the performance of official duties or have been assaulted you must report it to your local Treasury Inspector General for Tax Administration (TIGTA) per IRM, Reporting to TIGTA. Visit the web site of the Office of Employee Protection (OEP) for a list of TIGTA field division addresses and phone numbers.


    The assistor must notify the lead of a PDT.

  2. The e-file monitoring coordinator (EMCs) must be notified that the PDT indicator has been placed on the provider's account by using secure e-mail. For the list of e-file monitors see e-file Monitor Coordinator by State. Provide the EMCs with the electronic filing identification number and applicable provider's name. Update comments to state "PDT" on provider's name and date.

  3. Also, notify the EMC of a condition, suspected condition or unusual circumstances regarding a provider that would aid or assist in monitoring. For example, unusual circumstances would include referrals or newspaper articles that show that the provider is involved in criminal activity, etc. or an unusual phone call received from an Electronic Return Originator (ERO) or concerned party.  (10-01-2015)
Balance Due Literal on Automated Suitability Analysis Program Report

  1. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡


    The assistor will pursue balances due in masterfile status 21 only when working daily suitability cases or in conjunction with other issues when working continuous suitability cases.

  2. Check CC IMFOL, CC BMFOL, CC ENMOD and/or CC TXMOD for pending or posted transactions which would resolve the literal/hit or issue.

    1. If the liabilities have been addressed or resolved on all modules and no other literal/hit or issue is present, pass. Examples: posted or pending transactions including payments, current or pending installment agreements (IA) and accepted/pending Offers in Compromise.

    2. If working appeals and the ERO states that the balance has been previously paid, but the payment has not posted to IDRS, send the next letter, including the Accounts Management phone number, 800-829-1040, for payment tracer assistance.

    3. If all of the outstanding balances have been addressed through bankruptcy (TC 520) and the bankruptcy has not been reversed, pass. If TC 520 is not present on all balance due accounts and the cumulative balance on which the TC 520 is not present (or has been reversed) ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ , send the appropriate suitability letter to resolve those accounts. Include in the letter, that any payment(s) for the return(s) must be made.

    4. If all outstanding balances are in a current IA, pass. check for manually monitored installment agreements (MMIA) as they are considered legitimate IAs.

  3. If payment or proof of payment, See IRM, Reasonable Cause and Automated Suitability Analysis Program Literals. Each case is required to be reviewed base on its own history, facts and circumstances.

    1. If the provider provides reasonable cause and the payment/proof of payment is posted to Integrated Data Retrieval System (IDRS), pass.

    2. If the provider provides reasonable cause and no payment/proof of payment is posted to IDRS, issue letter.

    3. If the provider does not provide reasonable cause but provides the payment/proof of payment, send a reprimand letter reminding the provider of their obligation to pay timely and that any future infractions may result in suspension. When proof of payment is received showing the payment was made timely and eliminated the balance due, reasonable cause is not necessary.

    4. If the provider does not provide reasonable cause or payment, issue letter.

    5. If outstanding balance shows TC 470 with closing codes 90 or 93 and at least 30 days have elapsed, send the next letter.

    6. If TC 470 closing code 90 is present, it will full pay module balance

  4. If the provider is unable to pay balance due, recommend that an installment agreement (IA) be established and ask for a faxed copy of the agreement. When the IA is established, pass.


    If the individual meets the criteria, the IA is established immediately and can be researched on IDRS within a short time using command code IADIS. Confirmation, via Letter 2823C, Voice Response Unit (VRU) Monthly Payment Plan Confirmation, is sent to the individual.

  5. If a provider does not provide all information within 30 days of correspondence, issue letter.

  6. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ The account can also be in another status such as "uncollectible" , "bankruptcy" and/or "offer in compromise" . Resolution can include revision of the IA to include the other unpaid tax periods.

  7. If any IA is in default status, send letter to taxpayer and include the information regarding all defaults.

  8. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  9. If balance is not reduced below ≡ ≡ ≡ ≡ call or send letter.

  10. See IRM, Suitability Procedures After Initial Research, for specific pass/fail instructions.  (10-01-2015)
Uncollectible Accounts Literal on Automated Suitability Analysis Program Report

  1. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    Closing Code: Closing Code denotes:
    03 Unable to locate
    09 Tolerance
    10 Defunct corporation
    12 Unable to contact
    13 In business corporation
    39 ACS cases with low RWS score
  2. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    1. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  3. See IRM, Suitability Procedures After Initial Research, for specific pass/fail instructions.  (10-01-2015)
No Return Literal on Automated Suitability Analysis Program Report

  1. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  2. If the research shows no returns for the last six years and they are in status 02, 03 or 04 the assistor must pursue them.

  3. The assistor will check CC IMFOL/BMFOL (and TXMOD for pending transactions) for a TC 150 (return filed and tax liability assessed), TC 610 (remittance with return) or TC 460 (extension of time for filing). The assistor must allow an additional 45 days from the due date or extension to allow for the processing of the tax return.

  4. Check CC INOLE for a spousal cross reference social security number. If a cross reference SSN is found, check CC IMFOL under the cross reference SSN for a joint return. See TC (Transaction Codes), SC (Status Codes) and CC (Closing Codes) in Document 6209, ADP and IDRS Information:

    1. If a TC 150 is posted under the spouse's SSN, check the status of the tax account under the SSN appearing on the ASAP report.

    2. If the account is in status code 02 or 03 or 04 with a TC 140, input TC 971, closing code 17 on the secondary spouse's SSN, using REQ77. This action will cross reference the account where the return is posted. Also, input TC 594 with closing code 84 to indicate the return was filed as a spouse on a joint return.

    3. If research does not indicate that all returns are posted or satisfying transactions, request the information from the provider. As a courtesy you may include in the letter that any payment for the return or request for an installment agreement can be made accordingly.

    4. Statute returns (original unprocessed return) are sent to the Statute Control area for clearance and processing. See IRM, Statute dates, for applicable forms and statute dates.

    5. If there are no other issues, pass.

  5. Research all EINs on IDRS using CC BMFOL.

    1. If CC BMFOL has "N" (for no return posted) and no status, pass.

    2. A written statement from the provider indicating that they are not liable is acceptable. However, the statement must be specific. For example, if the issue were a non-filed Form 94X return, the firm would have to spell out why they are not liable for this return, e.g., no employees.


      If there is a credit on the account, the assistor should inform the principal of the firm as a courtesy.

  6. For BMF accounts, check CC INOLE for Filing Requirement Code 11 (seasonal filer) for Form 941, Employer's Quarterly Federal Tax Return.

    1. If a provider is a seasonal filer or research indicates the possibility that the provider may be a seasonal filer (the same quarter for prior years is in status 06, pass.

    2. If there is no indication that the provider is a seasonal filer, proceed with research.

  7. Check for TC 610 indicating a payment received with a return but return has not yet posted. If TC 610 is present, pass; if TC 610 is over one year old, send the appropriate letter.

  8. If research indicates that there are no unresolved accounts in status 02, 03 or 04 pass. See IRM, Suitability Procedures After Initial Research, for specific pass/fail instructions.

  9. If there are unresolved modules in status 02, 03 or 04, the assistor may choose to contact the provider by phone to attempt to resolve the issue.

    1. If the provider indicates that the return was previously filed, a copy (with documentation to support the filing) with a letter of explanation may be faxed. Upon receipt, pass. Send return for processing. Using CC FRM49 input TC 599 with appropriate closing code. Input comments on TPDS that return secured.


      The clerical department routes returns secured for processing as detailed above.

    2. If the return was not filed, the provider must provide the original return to the local office or submission processing center within 30 days and provide, via fax, stamped proof of filing along with a letter of explanation. Upon receipt of proof of filing or original tax return, pass.

    3. If the provider provides an original return or proof that an original return was recently filed but posting of the return will create a balance due, the provider must be contacted via telephone or supplemental letter regarding the balance due.


      Upon receipt of any original tax return or copies of tax return(s) that need to be processed, send the tax return(s) for processing. Use the Purple routing sheet and notate Live Return-Please Expedite with date stamp and route to Campus Support Stop 505 and they will ship to Fresno after processing. Input TC 599 with the applicable closing code on each tax period to indicate the return(s) were secured. Refer to Document 6209 Section 11 for TDI Closing Codes.

  10. If providers indicate they are not liable to file a particular IMF/BMF return because there were no employees, they are not required to file based on income or are no longer liable to file the return, complete research via IDRS and other tools such as IAT, CC IRPTR, etc. to insure that the provider’s claim is correct.

    1. If no indication that provider is liable to file, pass and input TC 590 or TC 591 with applicable closing codes.

    2. If research indicates the provider may be liable to file, provide them with the information found during research and request that they review their filing requirements again.

    3. If the provider still claims that they are not liable to file, refer the caller to customer service.

    4. Faxed documentation to resolve suitability issues is acceptable only when requested by the assistor working the suitability case. For example a letter from the Internal Revenue Service (IRS) stating no return required etc.

  11. If the provider does not provide the requested information within:

    1. 48 hours of telephone call, issue appropriate letter.

    2. 30 days of initial letter, issue appropriate letters.

  12. See IRM, Suitability Procedures After Initial Research, for specific pass/fail instructions.  (10-01-2015)
Fraud Penalties Literal on Automated Suitability Analysis Program Report

  1. Automated suitability analysis program (ASAP) will check for any fraud penalties (TC 320) assessed within the last six years.

    1. The assistor will check CC IMFOL and/or BMFOL for TC 321 which reverses TC 320. If the penalty was abated in full, pass.

  2. If the penalty was not abated or partially abated, attach IDRS screen print to ASAP page and give to designated assistor for contact with the appropriate e-file monitoring coordinator for further information regarding the assessment of the penalty. The designated assistor will then do the following:

    1. Forward the request to the appropriate e-file monitoring coordinator based on the location of the individual for information on the assessment and recommendation. (For the List of e-File Monitor Coordinators, see e-file Monitor Coordinators by State)

    2. Obtain the recommendation to "pass" or "fail" from the e-file monitoring coordinator.

  3. If the e-file monitoring coordinator recommends pass and no other issues are present, recommend pass.

  4. If the e-file monitoring coordinator recommends fail and provides specific information that can be divulged to the filer, recommend fail.  (10-01-2015)
Cross Reference SSN Literal on Automated Suitability Analysis Program Report

  1. Daily automated suitability analysis program(ASAP) will check for any cross referenced SSNs that may be related to the individual(s) SSN listed on any e-file application. This literal is suppressed for continuous suitability review.

  2. If the above literal appears with literal NO SUITABILITY CHECKS MET AGAINST MF and SSN, the assistor will verify that the SSN has filed jointly with the individuals listed on the application.

    1. If a joint return was filed and there are no other literals, pass.

    2. If a joint return has not been filed with the cross reference SSN, See IRM, No Return Literal on Automated Suitability Analysis Program.

    3. If the cross reference SSN is Married Filing Separate and no return has been filed for the individual shown on the TPDS, follow the procedures in IRM, No Return Literal on Automated Suitability Analysis Program.

  3. See IRM Procedures After Initial Research, for pass/fail specific instructions.  (10-01-2015)
Deceased Taxpayer Literal on Automated Suitability Analysis Program Report

  1. Automated suitability analysis program (ASAP) checks for a date of death on the Data Master 1 (DM1) file.


    If this literal is present see below.  (10-01-2015)
Deceased Individuals

  1. When information is received that an individual is deceased, move personal suitability of the deceased individual to "incomplete" if it is not already "incomplete" due to system update for preparer tax Identification number (PTIN) deceased status.

  2. Research the application for associated EFINs (electronic filer identification numbers), SSNs (social security numbers) and employer identification numbers (EINs).

  3. If the deceased individual is the only principal on the application inactivate all applicable EFIN(s) and electronic transmitter identification numbers (ETINs), update all provider options to dropped, place firm suitability in "incomplete " and enter the following comment "principal deceased" .

  4. If the deceased individual is not the only principal on the application or is only a responsible official, request, either by telephone contact or LOI, that the provider remove the deceased individual from the e-file application within 30 days. Place firm suitability in "recheck" and enter comments "firm to remove deceased" .

    1. If provider has not removed deceased individual within 30 days, inactivate applicable EFIN(s) and related ETIN(s).


      Inform the provider that if the death resulted in a change in business structure, it may need to obtain a new EIN and complete a new e-file application.

  5. If the deceased individual is a delegated user remove the delegated user from the e-file application and enter comment "Delegated user (last name) deceased/ removed" .

  6. Refer cases to national office analyst when an issue arise where a firm has no other EFIN and they need to use the current EFIN until the new EFIN is assign.  (10-01-2015)
Citizenship Literal on Automated Suitability Analysis Program Report

  1. Lawful permanent resident (LPR) is defined as any person not a citizen of the United States who is residing as an immigrant in the U.S. under legally recognized and lawfully recorded permanent residence status also known as" Permanent Resident Alien, Resident Alien Permit Holder and Green Card Holder" . The appropriate term according to the reference 8 U.S.C. § 1101(a) (20) is "lawfully admitted for permanent residence" . Alien is defined as "any person not a citizen or national of the United States" and lawfully admitted for permanent residence means "the status of having been lawfully accorded the privilege of residing permanently in the United States as an immigrant in accordance with the immigration laws, such status not having changed" .

    1. Automated suitability analysis program (ASAP)will check daily any individual citizenship code on the DM1 of the National Account Profile (NAP) to ensure all individuals subject to suitability are either US Citizens or Lawful Permanent Resident (LPR).

    2. If the literal "Citizenship Code C, D E or F" appears, the assistor will research CC DDBOL to verify the citizenship code. fail the individual if citizenship code C, D, E or F is present on IDRS.


      A - American Citizen  
      B - Legal Alien  
      C - Alien not allowed to work  
      D - Other than A, B or C  
      E - Alien Student  
      F - Conditional-Legal Alien  
      Blank/space - Unknown  
    3. See IRM, Suitability Procedures After Initial Research, for pass/fail specific instructions.


      Examples of paragraphs for Letter 3479(CG):

      1. You indicated you are a U.S. Citizen on your IRS e-file application. Each individual who is listed as Principal/ Responsible Official on the application must be a U.S. Citizen or an alien lawfully admitted for permanent residence (legal resident alien) at the time they sign/submit their application. However, our records indicate you are not a U.S. Citizen.  
      2. You indicated you are an alien lawfully admitted for permanent residence (legal resident alien) on your IRS e-file application. Each individual who is listed as Principal or Responsible Official on the application must be a U.S. Citizen or an alien lawfully admitted for permanent residence (legal resident alien) at the time they sign/submit their application or are added as a Principal or Responsible Official to the application. However, our records do not match the information reported on the application.  
Suitability Documents for Proof of Citizenship

  1. Authorized providers will be required to provide documentation for verification when SSA shows citizenship code hit on automated suitability analysis program(ASAP).

  2. Documents that can be accepted as proof of citizenship:

    1. Green Card- gives official immigration status (Lawful Permanent Residency) in the United States

    2. Birth Certificate- issued by a U.S. State (if the person was born in the United States) or by the U.S. Department of State (if the person was born abroad to U.S. citizen parents who registered the child’s birth and U.S. citizenship with the U.S. Embassy or consulate)

    3. U.S. Passport- issued by the U.S. Department of State

    4. Certificate of Citizenship- issued to a person born outside the United States who derived or acquired U.S. citizenship through a U.S. citizen parent

    5. Naturalization Certificate- issued to a person who became a U.S. citizen after 18 years of age through the naturalization process

  3. Photocopies of the proof of residence are acceptable forms of documentation.

  4. If these documents are not provided, the individual will not be allowed to participate.


    Any additional questions regarding citizenship status or documents refer the applicant to the U.S. Citizenship and Immigration Services at 800-375-5283.  (10-01-2015)
Suitability Procedures After Initial Research

  1. On the Form 14628, Initial Suitability Recommendation, assistors must notate any returns not filed, liabilities not addressed and assessed fraud penalties. These issues must be addressed in any correspondence or telephone contact. This includes any principal or responsible official who previously failed suitability must provide new fingerprint cards or enter professional status information. IRM (5) Reapply Applications.

  2. If a "pass" decision is determined after initial research:

    1. Change suitability status to "passed" for all applicable taxpayer identification number (TINs)

    2. Document in comments and description field section passed suitability per W/L electronic filing identification number (EFIN).


    Review by second line review is not needed on a "pass" decision, except when working appeals or NAASDC (North Atlantic Area Scheme Development Center) cases with recommendation to fail.

  3. If a "fail" recommendation is determined after initial research:

    1. Pull file folder

    2. Prepare Form 14628, Initial Suitability Recommendation on all worklist items if recommendation is "fail" (See IRM, Suitability Recommendation);

    3. Input comments "sent for second line review" on the application;

    4. Forward the case file for second line review

  4. Upon concurrence of "pass" decisions see above:

    1. Prepare a written response only if a firm/individual has been previously contacted.

    2. Input TC 590/591/594/599 if required.

    3. For worklist items or appeals, change suitability status to "pass" in TPDS for all applicable TINs/ EINs; input comments "passed suit" .

    4. File all information in the designated area.

  5. Upon concurrence of "FAILED" decisions by management, See IRM, Procedures for Rejecting and Sanctioning Firms and Individuals.

    1. If a principal or responsible official or a corporation/partnership is non-compliant or if a "no Response" , "Proposed Sanction" or "Suspension" letter is being sent to the provider, send one letter to the firm and a different letter to the appropriate individual at the firm's mailing address.


      Ensure the firm's letter is addressed to the correct individual

    2. Be sure to include all literals/hits that appear on the ASAP report which are valid and any other pertinent information.

    3. Forward letter and case file for review.

    4. The letter will be mailed by the reviewer.

    5. Comments will be automatically added to TPDS showing the type of letter that was generated. The assistor must add comments indicating the suitability issues/ automated suitability analysis program(ASAP) tab(s) and the action(s) taken in application comments area.


      For transcripts, the provider will remain in "recheck" suitability until the Office of Appeals makes the final determination.

    6. For worklist items, update all applicable TINs to "fail" status, document issues in suitability ASAP tab(s) and actions in application comments area and send the appropriate letter. It is permissible to enter comments "See EFIN XXXXXX" instead of typing the same lengthy comment under individual EFIN(s). Be sure to include the EFIN from which the letter was generated in the suitability field. Change application status to "complete" .


      See IRM, Daily Suitability if this is a new application for an additional office.

    7. System will update provider option to "rejected" and deactivate EFIN.

  6. The designated TE must contact EPPM (E-File Provider Program Management Branch) if an applicant and/or provider assigned to a national account manager does not pass suitability before any action is taken and letter sent. In addition, the designated TE can contact EPPM when a firm or provider is affiliated with more than 100 locations.

    1. E-File Provider Program Management Branch (EPPM) will initiate a review of the facts of the case and make a determination on the level of the infraction and the impact on IRS e-file. This review will be conducted by EPSS management, EPPM and national account managers.

    2. Upon completion of the suitability review, EPPM will provide instructions to resolve the case in accordance with the reasonable cause guidelines and Publication 3112 participation rules.  (10-01-2015)
Suitability Recommendation

  1. Suitability recommendations are used by assistors to summarize the results of their research.

  2. Upon completing their initial research, assistors will indicate on Form 14628, Initial Suitability Recommendation/ IM Activities area: "pass" or "fail" . Assistors will not make a determination as to what sanction can be imposed, if applicable. The second line reviewer will review the TE decision.

  3. Each case will go through one review with the exception of "Office of Appeal" recommendations which will go through two levels of review.

  4. Form 14628, Initial Suitability Recommendation must state whether reasonable cause was established, the appeal was received timely and if the issues were resolved.

  5. There are four levels of suitability review/ recommendations:

    1. Form 14628, Initial Suitability Recommendation is used after the response/appeal to the LOI or as the Initial recommendation for Daily Suitability.

    2. Form 14629, First Appeal - Suitability Recommendation is used for the first appeal/proposed sanction

    3. Form 14634, Suspension without Appeal Rights - Suitability Recommendation is used when a response is received to a sanction

    4. Form 14633, OOA Appeal Rights Suitability Recommendation is used for appeal to the office of appeals  (10-01-2015)
Suitability Reason Codes

  1. A reason code must be entered when either a firm, principal or responsible official fails suitability or when the Andover e-help Desk places a provider option in "reject" , "non-compliant" or "dropped" status. See figures below for these codes.

    Figure 3.42.10-1

    Reason Codes Reprimand Rejected Dropped Non-Compliant (8453) Non-Compliant (Field monitoring)
    1. Conviction of a criminal offense X X     X
    2. Failure to file timely          
    3. Failure to pay timely          
    4. Reserved          
    5. Suspensions/disbarment from practice X X     X
    6. Conduct of disreputable nature X X     X
    7. Misrepresentation on application X X     X
    8. Suspension/rejection prior year   X      
    9. Unethical practices in return prep X X     X
    10. Stockpiling returns prior to acceptance X X     X
    11. Knowingly employing a denied/suspended provider X X     X
    12. Knowingly working for a denied/suspended provider X X     X
    13. Credit check X X      
    14. Fingerprint Check   X      
    15. Date of birth   X      
    16. Citizenship   X      
    17. Advertising standards X       X
    18. Deterioration in format of transmissions X X     X
    19.    Unacceptable cumulative error rate X X     X
    20. Untimely, missing or incomplete 8453 X     X X
    21. Stockpiling returns X       X
    22. Failure to retrieve acknowledgement files X       X
    23. Failure to provide taxpayer acknowledgement          
    24. Significant complaints about provider X       X
    25. EFIN compromised by provider X X     X
    26. ETIN compromised by Transmitter X X     X
    27. ETIN compromised by Software Developer X X     X
    28. Failure to cooperate with monitoring efforts X       X
    29. Improper use of W-2 indicator by provider X       X
    30. Improper use of RAL indicator X       X
    31. Failure to use providers EFIN by transmitter X X     X
    32. Other X X     X
    33. No return for one or more years IMF X X      
    34. No return for one or more years BMF X X      
    35. Failure to adhere to signature requirements X X     X
    36. IMF balance due X X      
    37. BMF balance due X X      
    38. Fraud penalty assessed X X      
    39. History of defaulted installment agreements X X      
    40. Uncollectible account X X      
    41. Offer in Compromise X X      
    42. Bankruptcy/Litigation X X      
    43. Criminal Investigation X X      
    44. Intelligence Hold (-T & Z freezes) X X      
    45. No reasonable cause provided X X      
    46. Owner/principal of controlling office failed suitability X X      
    47. Accepted returns from persons other than taxpayers or authorized e-file providers X X     X
    48. More than one EFIN for the same business entity at the same location X X     X
    49. Improper origination X X     X
    50. Failure to retain or provide records X X     X
    51. Failure to notify IRS of changes X X     X
    52. Other or Undeliverable mail     X    
    53. Voluntarily dropped (filers request/deceased provider)     X    
    54. Inactive (no response to inquiries)     X    
    55. No returns e-filed for the last two years     X    
    56. Other X X X   X

    Figure 3.42.10-2

    Status Codes
    1. Applied
    2. Accepted
    3. Rejected (App only/Suit only)
    4. Dropped
    5. Testing
    6. Non-compliant
    7. Non-compliance (8453 only)
    8. Non-compliance (Field monitoring)
    9. Revoked
  2. The provider option and electronic filing identification number (EFIN) status are updated automatically. The application status must be manually updated.

  3. The overall suitability field is automatically updated to "pass" when the firm and all related principals and responsible officials have passed suitability.

  4. The overall suitability field is automatically updated to "fail" when the firm or any related principal or responsible official fails suitability.

  5. The overall suitability field is automatically updated to "recheck" when the firm or any related principal or responsible official suitability is changed to "recheck" .  (10-01-2015)
Suitability Telephone Contact and Correspondence

  1. The first inquiry may be made by telephone. If there are complex issues or multiple issues that could not be easily addressed during a telephone inquiry, send the appropriate Letter of Inquiry (LOI).

  2. All telephone conversations must be documented in an interaction and included as a comment on the application.

  3. Supporting information/documentation requested must be received within 48 hours. If not received, the LOI must be sent.

  4. The correspondence must address all automated suitability analysis program(ASAP) issues including any new issues identified through IDRS research or issues not previously addressed. However if an issue was inadvertently left out, or a return becomes due in the interim and an appeal is received, the next notice must include any issues that arose since the original letter was issued.

  5. The appropriate letter must be sent to an individual who is contacted by telephone on a compliance issue and who provides the necessary information to satisfactorily resolve the issue.

  6. If a notice/letter is returned by the postal service as undeliverable, the undeliverable suitability procedures must be followed. See IRM, Undeliverable Suitability Letters.

  7. Suitability letters must contain all associated electronic filing identification number(s).

  8. When responses are received from individuals/firms regarding suitability issues, follow the specific procedures for the ASAP literal.  (10-01-2015)
Disclosure Guidelines for Suitability

  1. Disclosure guidelines must be followed when contacting filers by telephone. Information cannot be disclosed to any person not listed on the application. In the case of a literal/hit on the SSN, you must speak to the individual with the suitability issue. See IRM, Authentication/Authorization for e-file application for disclosure guidelines.  (10-01-2015)
Suitability Acceptance Letters

  1. Acceptance letters are sent systematically upon original acceptance into the e-file program.

  2. Acceptance letters may be manually generated, as needed, for any provider who requests a copy. Providers are encouraged to register for e-services and retrieve acceptance information themselves from the "summary page" of the application. Go to http://www.irs.gov and enter "e-services registration" in the keyword/ search terms search box.

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