4.90.12 Case Closing Procedures

Manual Transmittal

December 27, 2016


(1) This transmits a table of contents and text for 4.90.12, Federal, State and Local Governments, Case Closing Procedures.

Material Changes

(1) The following IRM sections were renumbered, deleted, moved to other IRM sections and modified with revised or additional content.

Previous IRM Subsection Explanation Deleted. Became IRM (3) and content modified/updated. Deleted, replaced with IRM and content modified/updated. Became IRM and content modified/updated. Deleted and replaced with new topic. Moved to IRM 4.90.9, Procedures, Workpapers and Report Writing. Deleted. Moved to IRM 4.90.9 and replaced with new topic. Became IRM and content modified/updated. Moved to IRM 4.90.9. Became IRM and content modified/updated. Content modified and updated. Became IRM (2) and content modified/updated. Became IRM and content modified/updated. Became IRM and content modified/updated. Deleted. Deleted. Deleted. Deleted. Content modified and updated. Content modified and updated. Deleted.
Exhibit 4.90.12-1 Content modified and updated.
Exhibit 4.90.12-2 Content modified.
Exhibit 4.90.12-3 Content updated and modified.
Exhibit 4.90.12-4 Content updated and modified.

(2) Added IRM discussing closing procedures for Whistleblower Claim for Award.

(3) Updated to meet the requirements of P.L. 111-274 (H.R. 946), the Plain Writing Act of 2010. The Act provides that writing must be clear, concise, well-organized, and follow other best practices appropriate to the subject or field and intended audience.

Effect on Other Documents

This section supersedes IRM 4.90.12, dated October 01, 2014. This section incorporates and supersedes Interim Guidance Memorandum TEGE-04-1016-0024, Revised FSLG GSAIN.


Tax Exempt and Government Entities
Federal, State and Local Governments

Effective Date


Paul A. Marmolejo
Director, Federal, State and Local Governments
Tax Exempt and Government Entities


  1. This section provides guidance for FSLG employees closing completed audits. It contains procedures for:

    • Closing cases within standard time-frames.

    • Naming electronic documents according to the FSLG naming convention.

    • Preparing required closing documents.

    • Assembling case files.

Standard Time-frames for Closing Cases

  1. FSLG Specialists (Specialists) must close cases to Field Managers (Managers) within these time frames:

    Type of Audit Closure Calendar Days From when the:
    No Change 10 No-Change is determined
    Agreed 10 Agreement is secured
    Unagreed 20 Earlier of the protest date or the 30 day letter default date
    1. Exception:

      Agreed cases with an unpaid amount of $10,000 or more have a different time frame. See IRM

  2. Managers have 10 calendar days to review and close cases to the Closing Unit or CPM.

  3. Case activity records should reflect the dates cases are closed by the Specialists and the Managers.

  4. Any delays or extended periods of inactivity must be documented in the case activity records.

Form 5599, TE/GE Examined Closing Record

  1. Form 5599, TE/GE Examined Closing Record, is required for:

    • Unagreed cases going to Appeals.

    • Processing partial agreements.

Unagreed Cases Going to Appeals

  1. Form 5599 is required for all unagreed cases protested to Appeals.

  2. Complete Form 5599 as shown in Exhibit 4.90.12-1.

Partial Agreements

  1. Form 5599 is not required for a partial agreement when the partial agreement closes at the same time as the unagreed issues.

  2. Form 5599 is required if the partial agreement is assessed before closing the unagreed part of the case.

  3. Prepare a partial agreement file (paper or electronic) and send to the Closing Unit. Include the following:

    • Form 895, Notice of Statute Expiration (if necessary)

    • Form 3198-A, TE/GE Special Handling Notice (attached to the outside of the case file)

    • Form 5599

    • Signed Employment Tax Report

    • Supporting documentation explaining the partial agreement

  4. The group retains control of the RCCMS case.

  5. Complete the following fields on Form 5599:

    • Partial box (top left corner)

    • P7 thru P34 - TIN, MFT, Tax Period, Name Control and Name

    • Item 12 - Tax Liability Adjustment

    • Item 13 - Disposal Code

    • Item 15 - Credit and Tax Computation Adjustment

    • Item 42 - ARDI code

Form 3198-A, TE/GE Special Handling Notice

  1. Form 3198-A, TE/GE Special Handling Notice, is required for every closed case.

  2. Used to communicate special case features and closing instructions.

  3. Review and complete each section as necessary.

  4. Under "Other instructions," may include, but don’t limit to, the following:

    • "Forms 4669 adjustments allowed by examination"

    • "Wage statements secured by examiner" (send originals to Social Security Administration)

    • "Delinquent Forms 1099 secured by examiner" (send originals to Cincinnati Campus)

    • "Assess Civil Penalty as indicated on Forms 8278 and 3645"

    • "-A freeze addressed-release freeze"

    • "ASEDR5" (enter only when ALL adjustments are subject to IRC 3509 rates)

Expedited Processing of Large Deficiency or Overassessment Cases

  1. The term "deficiency," for this section, refers to:

    • The sum of all deficiencies and penalties for any one taxpayer.

    • For all periods in the case file.

    • Not considering any offsetting overassessment.

  2. Expedite processing of unpaid, agreed deficiency cases of $10,000 or more. Close the case from the group within three days of receiving the signed Form 2504 or other waiver (such as, Form 4549 for Form 1042 cases). See IRM, Expedite Processing of Large Deficiency or Overassessment Cases.

  3. Expedite manual processing of overassesments of $10,000 or more. See IRM

Case File Assembly

  1. It’s important to properly and consistently organize electronic and paper case files so that others can readily locate items and take required actions after the case is closed. For example:

    • Managers

    • Reviewers

    • Closing Unit

    • Appeals

    • Tax Court

  2. Follow the FSLG RCCMS Naming Convention in indexing and naming documents in electronic and paper cases. See Exhibit 4.90.12-3. Include:

    1. The index number in the lower right-hand corner.

    2. The index number and name on all electronic documents. See Exhibit 4.90.12-3.

    3. The quarter on documents for a specific quarter in the name (for example, 32.TRDBV.201503, 32.TRDBV.201506, etc.).

    4. Use a second number and period when there is more than one document in the section (for example, 2.0.AMDIS, 2.1.INOLES, etc.).

  3. Remove unnecessary documents from the case file (for example, extraneous IDRS material, raw IRP data, etc.).

  4. Each form, report or document listed in Exhibit 4.90.12-3 may not be required in every case and, while the list isn’t all-inclusive, it addresses most situations.

Closing Examination Cases 100% Electronically

  1. Most cases can close 100% electronically.

    1. Check the "All Electronic" box in RCCMS.

    2. Include the same wording as the "Other Instructions" section of Form 3198-A in the RCCMS closing record "Remarks and comments" field.

Paper Case Files

  1. Paper case files are required for:

    • Unagreed cases protested to Appeals (disposal code 601). See Exhibit 4.90.12-4.

    • Cases petitioned to Tax Court.

    • Whistleblower Claim information.

Unagreed Cases
  1. Use one folder for all activities for each entity.

  2. Large case files may require more than one folder. Number multiple folders (1 of 4, 2 of 4, etc.). Label all folders with the:

    • Entity’s name

    • EIN

    • Type of return

    • Quarter/period and/or year

  3. Properly assemble the paper case file (for example, unagreed cases going to Appeals). See Exhibit 4.90.12-4.

  4. Use red folders for all paper case files with fewer than 270 days remaining on the Assessment Statute Expiration Date (ASED).

Whistleblower Claim for Award
  1. CPM sends the paper Whistleblower package to the group when the case is assigned to the group on RCCMS.

  2. Specialist must:

    1. Address the Whistleblower claim, see IRM, Referral Involving Form 211, Application for Award for Original Information.

    2. Keep the Whistleblower package separate from the administrative case file.

    3. Never mention the Whistleblower (or informant) in the case file or to the taxpayer or representative.

  3. Manager:

    1. Mail the completed Whistleblower package to the CPM Whistleblower Coordinator with Form 3210, Document Transmittal, in the confidential envelope that CPM provided when the case closes. The Form 3210 should also be emailed to the coordinator.

    2. Close the RCCMS case as mandatory review to CPM in status code 20.

    3. Secure email the CPM Whistleblower Coordinator, CPM MA and CPM Group Manager to inform them of the case closure.

  4. The Whistleblower package must contain:

    1. Evidence provided by the claimant.

    2. Form 211, Application for Award for Original Information.

    3. Completed Form 11369, Confidential Evaluation Report on Claim for Award.


      For instructions, click on the "Instructions" tab at the top left hand corner of the form.

  5. The closed case file must NOT contain any information or reference to the Whistleblower (or informant).

Field Manager Responsibilities

  1. Review and approve all closed cases for procedural compliance and technical accuracy.

  2. Ensure the final case grade is accurate in the RCCMS compliance activity codes tab and on Form 5599 (Item 32), if applicable. See Exhibit 4.90.12-2.

  3. Initial and date case activity record to indicate the review has been completed and include comments on any actions taken.

  4. If a case requires action by another group, transfer the case to the group on RCCMS and send the paper file, if applicable, using Form 3210.

  5. Provide written approval, per IRC 6751, of penalties asserted by Specialists. Written approval can be part of the case activity record. The following penalties don’t require managerial approval:

    • IRC Section 6651 (Failure to File and/or Failure to Pay).

    • Any other penalties automatically calculated electronically.

AIMS/RCCMS Group Processing Responsibilities

  1. When a case is closed, the group must query IDRS (AMDIS and INOLES command codes) to ensure:

    1. Each return is fully established on AIMS.

    2. Each return being closed is in status code 12 or higher.

    3. There are no freeze codes on any of the modules.

    4. Name and name control in RCCMS match IDRS.

  2. Complete a cursory review of the case file to ensure all necessary closing actions have been completed.

Instructions for Completion of Form 5599

  1. Specialist, Manager and CPM completes Form 5599 line items per the table below. Explanations relate to Form 5599 but several of them apply to RCCMS tabs. Refer to IRM, Processing TE/GE Examined Closing Record, Form 5599, for complete instructions to prepare Form 5599.

Item Number Item Name Completed by: Explanation
P7-P18 TIN Specialist
  • Enter EIN in the left-most position. See IRM

P21-P22 MFT Specialist
  • Required. See IRM

  • Most commonly used by FSLG:

    - MFT 01 - Form 941
    - MFT 16 - Form 945
    - MFT 12 - Form 1042

  • For a complete list, See Document 11308, Government Entities Computer Systems Codes.

P24-29 Tax Period Specialist
  • Enter in "YYYYMM" format. See IRM

P31-34 Name Control/Check Digit Specialist
  • Review INOLES for correct name control. See IRM

C Name Specialist
  • Enter name of government entity. See IRM

02 Penalty Reason Code Specialist
  • Complete when penalties are abated.

  • See IRM and Exhibit 4.5.2-2, TE/GE Penalty Reason Codes.

13 Disposal Code Specialist
  • Enter one disposal code that best describes the audit results. See IRM

  • See Document 11308 for disposal code definitions.

14 Statute Extended to Specialist
  • Enter the extended to date when a valid Form SS-10, Consent to Extend the Time to Assess Employment Taxes, is secured.

  • Verify AIMS, RCCMS and IDRS have been updated before the case is closed. "MMDDYYYY" format.

  • See IRM

16 Appeals Office Code CPM
  • Enter three digit code if case going to Appeals.

  • See IRM and IRM Exhibit 4.5.2-6, Appeals Office Codes.

17 EO/GE Appeals Issue Code CPM
  • Enter three digit if case going to Appeals. See IRM

  • See Document 11308.

18 Unagreed Amount CPM
  • Enter the unagreed amount if case going to Appeals. See IRM

20 - 24 Revenue Base Protection Section (RBP) Specialist
  • For claims only, complete Items 22, 23 and 24.

  • For detailed information on claims, see IRM thru

28 Examiner’s Time Specialist
  • Enter total time spent on non-claim activities. See IRM

  • Enter 1 hour in this field for cases that involve consideration of claims only.

30 Technique Code Specialist
  • Required for all examined returns. See IRM

  • No entry is made for surveyed claims.

  • Valid codes are:

    1. 2 - Exam conducted 100% by correspondence/phone.

    2. 3 - Field Examination single issue audits.

    3. 4 - Field Examination full scope.

31 Agent’s Grade Specialist
  • Enter two-digit grade of the Specialist who closed the case. See IRM

  • Required for all examined returns.

  • Not required for surveyed claims (disposal code 34).

32 Case Grade Field Manager
  • Determine case grade for all returns. See Exhibit 4.90.12-2.

  • Position (See IRM

    1. First position -1.

    2. Second position -1 (Grade 11), 2 (Grade 12) or 3 (Grade 13).

    3. Third position must be - 1.

    4. Fourth position is blank or "R" .

  • Related returns are the same grade as the primary return followed by an "R" .

33 Examiner’s Name Specialist
  • Required for all examined returns. See IRM

  • Enter the last name first, followed by a space and the first initial.

37 Delinquent Return Code Specialist
  • Leave blank if the delinquent return is incorporated into the audit. See IRM

  • If Item 37 is entered, Item 414 is required and Item 35 requires a $1 amount.

  • Group the closing records of secured delinquent returns by MFT code. For each type of return in the case file, enter:

    1. A"T" in Item 37 if there’s only one delinquent return.

    2. A "T" on one of the closing records in Item 37 if there’s more than one delinquent return.

  • Enter an "R" in Item 37 on the rest of the closing records having the same MFT code as the closing record marked with a "T" .


    Forms 941 for each quarter of 2014 and 2015 are secured from a taxpayer. A "T" should be entered on the closing documents of the latest quarter of the Form 941 return. The balance of the closing documents are marked with an "R."

38 Fraud Condition Specialist
  • This item may be blank or contain an entry of "C" (Civil) or "F" (Criminal), or "B" (for both). See IRM

40 Special Project Code Specialist
  • Project Codes are used to identify a Priority Emphasis Program or a referral to Examination Division. See IRM

  • Refer to Document 11308.

42 ARDI Code Specialist
  • Enter a one-digit code in this item for an agreed deficiency under the Accounts Receivable Dollar Inventory (ARDI) project. See IRM

  • When closing multiple years, and an overassessment from one year will be used to offset an assessment from another year, consider the overassessment as payment secured. "Full Paid" or "Partially Paid" depends on the amount of the overassessment.

  • The ARDI Code is valid for all FSLG MFT Codes. Valid Disposal Codes are 03, 06, 09, and 12.

  • DC 05 must contain an ARDI Code if an entry is present in Item 34.

  • See Document 11308.

50 Employee Group Code Specialist
  • Enter Employee Group Code (EGC). See IRM

  • An EGC is a required entry on all examined full closures except disposal code 34 – Surveyed Claims.

400 CIC Indicator Specialist
  • If the examination is a large case examination, as defined in IRM 4.90.13, enter an "L" . See IRM

402 International Examiner Time Specialist
  • Percentage of the Total Case time reported in Item 28. See IRM

403 International Exam Amount Specialist
  • Percentage of Total Audit Results. See IRM

405 - 408 Related Return Information Section Specialist
  • Enter "P" only for Primary Return (4th quarter of initial year open).

  • Enter "S" and the following for Secondary Returns:

    - Item 405, Related TIN
    - Item 406, Related MFT
    - Item 407, Related Tax Period
    - Item 408, Related Return Alpha

See IRM through
412 Installment Agreement Code Specialist
  • Enter code if there is an installment agreement. See IRM

  • Enter "N" if there is no installment agreement.

414 Delinquent Return Amount Specialist
  • Enter the balance due or refund amount per the delinquent return received from the taxpayer. If zero, enter $1 in this field. See IRM

  • If Item 414 is entered, Item 37 (Delinquent Return Code), is entered and vice versa.

  • If Item 414 is entered, Item 13 (Disposal Code) must not be 02 or 34.

415 Amended Return Amount Specialist
  • This entry is only valid if Master File (MF) shows that the examination was started before the taxpayer filed the amended return or an original return, if the TC 150 is a Substitute for Return (SFR). Enter the amount of the TC 29X (less any credits posted) that has posted to MF, if the return was filed as a result of an ongoing examination. Include a current transcript in the case file supporting the amount entered in Item 415. The TC 42X date must be before the TC 29X date.

  • Item 415 can be corrected by CC AMAXUO.

  • See IRM

416 Fax Agreement Ind. Specialist
  • Enter a "1" if a FAX agreement has been received. See IRM

701 Principal Issue Code Specialist
  • Left-justify the two-digit entries. See IRM

  • See Document 11308 for list of applicable codes.

722 Employment Tax/GE Specialist
  • Enter the deficiency or overassessment. See IRM

Case Grading Criteria

FSLG Employment Tax Case Grading Criteria
Grade 12
  • Compliance Checks.

  • Cases with an annual total tax liability (FICA / Medicare / FIT) less than $500,000 that do not meet upgrade criteria (*).

  • All cases with $100,000 or less annual liability.

Grade 13
  • Cases with an annual total tax liability (FICA / Medicare / FIT) in excess of $499,999.

  • Cases between $100,000 and $499,000 annual liability that meet upgrade criteria (*).

  • G coded taxpayers with annual compensation in excess of $1.35 Million.

* For upgrade criteria, refer to IRM Exhibit 4.23.19-1, Employment Tax Case-Grading Factors.

GS-12 Specialists can work above grade cases for no more than 25% of their time (per pay period). See IRM

Field Managers should consider the case grading implications of converting a compliance check into an examination. For example, a grade 12 compliance check may be a grade 13 examination due to the taxpayer’s employment tax liability and/or the complexity of its structure.

FSLG Naming Convention for RCCMS

1.0 F895.F94X.YYYYMM (required for all cases with fewer than 270 days on 'normal statute')
1.1 F3198-A
2.0 FCDS (never required to be included in paper file)
2.1 AMDIS (summary of controlled quarters showing all in status 12)
2.3 F2363 (process to FSLG AIMS Coordinator prior to closing case)
30.1 F4665
30.2 Rebuttal to TP Protest
30.3 Taxpayer Protest
30.4 F5599
30.5 L950-C; L950-D; L5376; L3381; L3382; L570; L905; L906; L3523; L937 (POA Transmittal Letter)
31.1 Closing Agreement (CSP or Ad Hoc)
31.2 F2504; F2504-WC; F4666; F4668; F4668-B
31.3 F886-A.XXXX.Issue Name (where XXXX is the GSAIN number)
31.4 Payee List(s) (separate lists for §7436 issues & relief from withholding granted via F4669)
31.5 F4670.Request for Relief from Withholding
31.6 F4669.Payee Statement(s) (for withholding relief granted)
32.1 F3244-A.Payment Posting Voucher (in paper file - attach to front of return)
32.2 F94X.YYYYMM ("Tax Return" = IRS Return/Copy, TP Copy, TRDBV / BRTVU prints - separate document for each tax period)
32.2 F94X.X.YYYYMM (processed amended return, if applicable) (in paper file, attach to back of "Tax Return")
32.3 F2848 or F8821.Power of Attorney (in paper file - attach to back of return, facing out, behind Consents, if any)
32.4 FSS-10; F872-B; F872.Statute Extension (in paper file - attach to back of return, facing out - it should be the first thing seen there)
33.100 F4318.Workpaper Index (ties to issue lead sheets & ET Report)
33.200 F9984.Case Chronology
33.201 TP/POA Correspondence (including initial contact & report transmittal letters)
33.202 Internal Email & other non-TP communications
33.203 Large Case Status Report
33.204 F5701 (indexed by issue, e.g., 33.204.1605.X, etc.)
33.300 IDR LOG
33.301 IDR.XXXX (where XXXX is GSAIN)
33.302 IDR.XXXX
33.303 IDR.XXXX
33.401 FSS-10; F872-B; etc.
33.402 L907; L928; L929
33.501 Pre-Contact Analysis Lead Sheet (Package Audit Lead Sheet, etc.)
33.502 Internal Controls Lead Sheet
33.503 Large Case Team Notes
33.504 Support Request.XXX (where XXX is the support function – CAS, EO, EP, Excise, TEB, etc.)
33.505 Document Name (notes on external information gathered, interviews with prior specialists, notes from prior case file, etc.)
33.506 Form 5666-Referral; Referral Tracking Sheet; Other Referral Materials (pertaining only to the case under audit)
33.601 Pre-Audit Contact Notes
33.602 Initial Interview
33.603 Tour of Facilities
33.701 F941/FW-2 Analysis & Reconciliation - (IRAS; Books/Payroll records to F941/FW-2; IRP & CAWR data)
33.702 F1099-MISC (G; R; etc.) Analysis & Reconciliation - (IRAS; Books/AP records information returns; IRP data)
33.703 Organization Chart
33.704 Chart of Accounts
33.705 Financial Statements (including independent audit reports, federal/state audit reports & footnotes - notes from review)
33.706 Minutes (notes from review)
33.707 Publications (notes from review)
33.708 Contracts, Grants & Leases (notes from review)
33.709 Plans, Policies & Procedures (notes from review)
33.710 Document Name (notes on other information)
34.1106 Section 218 Agreement / Modification (documents on the Share Drive are all pre-named; no need to change)
31111.000 Use this code as the only adjustment in each of the first 3 quarters of all F941 audits
34.1300 FICA
34.1301 31301.218 - 218 Coverage - Social Security
- 218 Coverage - Mandatory Medicare
34.1302 31302.218 - 218 Mandatory Exclusions - Students
- 218 Mandatory Exclusions - Certain VISAs; Emergency
Workers; etc.
34.1303 31303.218 218 Optional Exclusions
34.1304 31304.000 1991 Mandatory Social Security
34.1305 31305.000 Medicare Continuing Employment Exception - Medicare wages only adjusted
34.1306 31306.000

- §3121(a)(16) Remuneration > $100 - no 218 coverage
- Medicare Only (Medicare Qualified Government Employee) - post '86 hires, members of PRS or FICA replacement plan - no - Social Security coverage
- Rehired Annuitant - no 218 coverage
- Other - no 218 coverage
- §3121(a)(16) Remuneration > $100 - 218 coverage
- Rehired Annuitant - 218 coverage
- 218 Other
34.1401 31401.000 Section 530 Relief
34.1402 31402.000
34.1403 31403.000
- WC.3509.No CSP (general) - no 218
- WC.3509.No CSP (general) - 218
- WC.3509.No CSP (elected & appointed public officials) - no 218
- WC.3509.No CSP (elected & appointed public officials) - 218
34.1404 31404.000
- WC.Full Rates (general) - no 218
- WC.Full Rates (general) - 218
- WC.Full Rates (elected & appointed public officials) - no 218
- WC.Full Rates (elected & appointed public officials) - 218
34.1405 31405.000
- Third Party Payments - no 218
- Third Party Payments - 218
34.1406 31406.000
- Other - no 218
- Other - 218
34.1501 31501.000
34.1502 31502.000
34.1503 31503.000
EE Death
34.1504 31504.000
Back Pay, Settlements, Damages
34.1505 31505.000
Awards & Prizes
34.1506 31506.000
Below Market Loans
34.1507 31507.000
Loan Forgiveness
34.1508 31508.000
Severance Pay
34.1509 31509.000
Grossed Up Wages
34.1510 31510.000
Non-Resident Alien
- NRA - F1042/1042C adjustment
- NRA - ITW for IC
- NRA - Foreign Students
- NRA - Student FICA Exception
- NRA - Tuition/Waivers Reclassification to wages/scholarships
- NRA - Other
34.1511 31511.000
Scholarships and Fellowships
34.1512 31512.000
Sick Pay
34.1513 31513.000
Vacation Pay
34.1514 31514.000
- Stipends
- Bonuses
- Tips
- Other
34.1601 31601.000
EE Discounts
34.1602 31602.000
No-Additional Cost Fringe Benefit
34.1603 31603.000
Working Condition Fringe Benefit
34.1604 31604.000
Qualified Transportation
34.1605 31605.000
Moving Expense Reimbursement
34.1606 31606.000
On-premises Athletic Facilities
34.1607 31607.000
Retirement Planning Services
34.1608 31608.000
Meals and Lodging
34.1609 31609.000
Group Term Life Insurance
34.1610 31610.000
Cafeteria Plans
34.1611 31611.000
Dependent Care
34.1612 31612.000
Educational Assistance
34.1613 31613.000
Adoption Assistance
34.1614 31614.000
Medical & Accident Benefits
34.1615 31615.000
Health, Accident & Disability Insurance Premiums
34.1616 31616.000
- Housing Allowance
- Housing Provided
- Athletic Tickets
- Personal Use of Facilities
- Non-Accountable Expense Plan
- Gifts - cash or cash equivalent
- Other
34.1617 31617.000
Entertainment (tickets, entertainment meals, etc.) (accountable plan fails)
34.1618 31618.000
Uniforms and Clothing Provided (accountable plan fails)
34.1619 31619.000
Uniforms and Clothing Allowance (accountable plan fails)
34.1620 31620.000
Internet Allowance (accountable plan fails)
34.1621 31621.000
Travel and Vehicle Allowance (accountable plan fails)
34.1622 31622.000
Equipment Provided (accountable plan fails)
34.1623 31623.000
Equipment Allowance (accountable plan fails)
34.1624 31624.000
Cell Phone Allowance (accountable plan fails)
34.1625 31625.000
Other (title document, lead sheet & explain) (accountable plan fails)
34.1701 31701.000

- ER Provided Vehicle - personal use of ER vehicle - no 218
- ER Provided Vehicle (accountable plan fails) - no 218
- ER Provided Vehicle - personal use of ER vehicle - 218
- ER Provided Vehicle (accountable plan fails) - 218
34.1702 31702.000
ER Provided Aircraft (accountable plan fails)
34.1703 31703.000
ER Provided Transportation - Other (accountable plan fails)
34.1704 31704.000
EE Provided Vehicle (accountable plan fails)
34.1705 31705.000 EE Provided Transportation - Other (accountable plan fails)
34.2101 32101.000
IRC 457 Plans
34.2102 32102.000
IRC 403(b) Plans
34.2103 32103.000
Other Nonqualified Deferred Compensation Plans
34.2201 32201.000 BUW.FW-9 Review-no CP2100
34.2202 32202.000 BUW.CP 2100
34.2203 32203.000 BUW.Prizes & Awards
BUW.Gaming Winnings
BUW.Other (name document, lead sheet and explain in workpapers)
34.2204.1 32204.000 BUW.F1099-MISC Payees
(list of names, TINs, payment amounts, amount eligible for 3402(d) relief, relief granted)
34.2204.2 BUW.F4669 Secured from TP
34.2301 32301.000
Special Emphasis 1 (name the document with the special emphasis name)
34.2302 32302.000
Special Emphasis 2 (name the document with the special emphasis name)
34.2401 32401.000
34.2402 32402.000
6656.Failure to Deposit
34.2403 32403.000
34.2404 32404.000
34.2405 32405.000
Other (explain and title the lead sheet)
34.2501 EP
34.2502 EO
34.2503 TEB
34.2504 Other
34.2601 TP Feedback
34.2602 Recommendations
40.0000 n/a PRIOR COMPLIANCE ACTIVITY (zip file prior audit/compliance check - rename documents as necessary)
CIVPEN.1 F3198-A
CIVPEN.31 F3645
CIVPEN.31 F8278
CIVPEN.31 F886-A
CIVPEN.32 F4318
CIVPEN.33.1 F9984.Activity Record
CIVPEN.33.2 CivPen Lead Sheet
CIVPEN.33.3 Payee List (names, TINs, payment amounts)

Paper Case File Requirements for Unagreed Protests To Appeals

Form 895
Form 3198-A
Form 4665 (optional)
Rebuttal to TP's Protest
TP's Protest
Closing Agreements - signed by TP
Form 2297 - signed by TP
Form 3363 - signed by TP
Forms 2504 / 2504-WC
Forms 4666, 4668, 4668-B, 886-A
Form 4670 - signed by TP
Forms 4669 - signed & dated by payees (valid forms)
Form 5599 (attached to top of return documents - for each tax period)
Form 3244-A (attached to top of return documents, after Form 5599, for each tax period)
Tax Return Document (Tax Return, TRDBV, etc.) for each tax period
Form 2275 w/BMFOLR for SFRs (for each tax return & period)
Form 2848 - signed by TP & Representative (must be valid) - attach to back of return, facing out
Form SS-10 - signed by TP & Group Manager - attach to back of return facing out so it's the first thing seen (ensure statute date updated on AIMS/RCCMS)
Form 4318
Form 9984
Initial interview/meeting notes
Correspondence to/from TP related to unagreed issues
Unagreed issue workpapers (indexed to Form 4318), including lead sheets, supporting workpapers and:
- Delinquent Information Returns (Forms W-2, 1099-MISC, etc.)
- List of Payees for delinquent Information Returns (name, TIN, payment amount, relief granted)
Forms 5701 signed by TP for unagreed issues
Section 218 Agreement, if applicable