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Part 8. Appeals

Chapter 20. Account and Processing Support (APS)

Section 5. Carding New Examination and Specialized Examination Programs and Referrals (SEPR) Receipts

8.20.5 Carding New Examination and Specialized Examination Programs and Referrals (SEPR) Receipts

Manual Transmittal

August 05, 2026

Purpose

(1) This transmits revised IRM 8.20.5, Account and Processing Support (APS), Carding New Examination and Specialized Examination Programs and Referrals (SEPR) Receipts.

Material Changes

(1) Throughout - updated references from Appeals Centralized Database System (ACDS) to Appeals Case Management System (ACMS), including references to ACMS fields, ACMS relationships, ACMS attachments, ACMS validation, ACMS action records, and ACMS statute date/code tables. Replaced work unit number (WUNO) terminology with appeal number terminology, where applicable.

(2) Throughout - removed ACDS paperless feature code PL and related ACDS 2.0 notification instructions where ACMS routing, document attachment, file shipment, and Counsel jurisdiction functionality now apply.

(3) IRM 8.20.5 - changed title from "Carding New Receipts" to "Carding New Examination and Specialized Examination Programs and Referrals (SEPR) Receipts" to reflect the relocation of Collection carding procedures to IRM 8.20.14 and the focus of this IRM on Examination Appeals and SEPR receipts.

(4) IRM 8.20.5.1 - revised the purpose statement to identify carding for Examination Appeals and SEPR cases, replaced ACDS references with ACMS, and added primary stakeholders.

(5) IRM 8.20.5.1.3 - changed title from "Responsibilities" to "Roles and Responsibilities" and updated leadership, Policy, and APS responsibility statements.

(6) IRM 8.20.5.1.4 - changed title from "Program Reports" to "Program Management and Review" . Removed references to ACDS and its subsystems, DIMS and PEAS, from the program-report systems list and updated the program-report references to ACMS and IRM 8.20.13.

(7) IRM 8.20.5.1.5 - added Program Controls, including statute monitoring, ACMS validation, Form 3210/E3210 acknowledgment controls, inventory monitoring, and managerial reviews.

(8) IRM 8.20.5.1.6 - removed the ACDS acronyms exhibit reference and updated exhibit references due to removal of the ACDS exhibit.

(9) IRM 8.20.5.1.7 - added related resources for IRM 8.20.13, Appeals Case Management System (ACMS), IRM 8.20.14, Carding New Collection Receipts, and IRM 8.20.16, Collection Closing Procedures.

(10) IRM 8.20.5.2 - updated statute responsibility guidance to include cases received through the Appeals Shared Programs Hub Electronic Case Receipts (ECR) SharePoint site and electronic cases carded on ACMS pending validation or routing.

(11) IRM 8.20.5.3 - updated general carding rules to remove eCase and WUNO references, revised POA entry procedures for ACMS participants, and added Circular 230 information regarding taxpayer representation.

(12) IRM 8.20.5.3.1 - removed the separate subsection title "Receiving Returns and Administrative Files" and moved/revised the administrative-file content under "Contents of the Administrative File" .

(13) IRM 8.20.5.3.1.1 - added instructions to return an appeal to the originating function if the administrative file does not contain the letter granting appeal rights and the taxpayer's protest or appeal. Added instruction that, when the completed administrative file is later submitted, the Appeal Received Date is the date Appeals received the completed administrative file.

(14) IRM 8.20.5.3.1.1 - incorporated AP-08-0625-0011, IRS Independent Office of Appeals (Appeals) Electronic Case Files Initiative (ECFI) for Small Business/Self-Employed (SB/SE) Excise Tax Cases Implementation.

(15) IRM 8.20.5.3.1.1 - removed collection-related exceptions from the 365-day ASED rule.

(16) IRM 8.20.5.3.1.2 - removed Compliance Collection-source case parameters from Cases Not Accepted by Appeals, including CDP, OIC, and TFRP acceptance guidance, because Collection carding procedures were removed from this IRM.

(17) IRM 8.20.5.3.1.3 - updated AIMS status procedures for ACMS and BBA cases, including BBA status 70/72 guidance and ACMS AIMS Activity Code entry.

(18) IRM 8.20.5.3.1.5 - changed title from "Work Unit Number (WUNO)" to "Appeal Number" and updated docketed and non-docketed carding examples to use appeal number terminology.

(19) IRM 8.20.5.3.2 - changed title from "AIVP Create Case Validation" to "ACMS Case Validation" and updated validation guidance to ACMS critical data fields and Counsel jurisdiction validation.

(20) Former IRM 8.20.5.3.3, eCase - removed because eCase carding procedures are no longer applicable.

(21) IRM 8.20.5.3.3 - moved Issue Management System (IMS) guidance from former IRM 8.20.5.3.4 and updated references to identify ACMS as Appeals' case management system of record.

(22) IRM 8.20.5.4.1 and IRM 8.20.5.5.2.3 - incorporated AP-08-0924-0019, Updated interim guidance on Appeals Reporting Data Needs (ARDN), into non-docketed receipts and docketed original-return procedures.

(23) IRM 8.20.5.4.1.1 - updated non-docketed original-return procedures to direct ATEs to request original returns through a support request when Appeals later needs the return, replacing the prior secretary/administrative assistant or APS request process.

(24) IRM 8.20.5.4.1.3 - updated non-docketed case carding from WUNO/ACDS terminology to appeal number/ACMS terminology.

(25) IRM 8.20.5.4.1.3.2 and IRM 8.20.5.4.1.4.2.1 - updated titles and procedures to refer to ACMS relationship functionality instead of ACDS related/reference case procedures.

(26) IRM 8.20.5.4.1.3.3 - revised Reference Returns Non-Taxable Carding to use ACMS subcategory Reference Return and removed ACDS TYPE/KEYTP/KEYTIN, action-code, and received/assigned-date instructions that applied to ACDS WUNO structures.

(27) IRM 8.20.5.4.1.4 and IRM 8.20.5.4.1.4.1 - updated non-TEFRA flow-through entity carding to establish non-TEFRA FTE returns as separate appeal numbers beginning August 10, 2026, and to link related appeals using ACMS relationship functionality.

(28) IRM 8.20.5.5(3) - removed paragraph containing duplicative instructions.

(29) IRM 8.20.5.5.1.2 - updated the docketed-case timeline to remove DIMS upload references and changed the dummy-file creation trigger from 40 days to 35 days after the petition is served when the administrative file has not been received.

(30) IRM 8.20.5.5.1.3, IRM 8.20.5.5.1.4, and IRM 8.20.5.5.1.5 - removed DIMS-based titles and updated the subsections to "APS Docketed Case Responsibilities" , "APS Docketed Case Procedures" , and "Working Docketed Inventory" .

(31) Former IRM 8.20.5.5.1.3.1, DIMS Tracking - removed because DIMS is no longer used.

(32) IRM 8.20.5.5.1.6 - changed title from "Docketed Case Carding (Skeletal Record)" to "Docketed Case Carding (Docketed Pending)" and updated procedures to use the ACMS Docketed Pending record and Counsel jurisdiction validation.

(33) IRM 8.20.5.5.1.6.1 - updated premature petition carding and certification procedures to use ACMS and remove DIMS actions where applicable.

(34) IRM 8.20.5.5.1.7 - updated dummy file creation procedures to use ACMS action records, Appeal Received Date and Taxpayer Request Date entries, and Counsel jurisdiction validation.

(35) Former IRM 8.20.5.5.1.8, Reopening Procedures for CDP Cases Defaulted Prematurely - removed because CDP case carding procedures were relocated to IRM 8.20.14.

(36) IRM 8.20.5.5.2.1 - updated docketed case attorney-of-record procedures to enter an attorney of record as an ACMS participant with the Counsel of Record role when the taxpayer does not have an active POA.

(37) IRM 8.20.5.5.2.3 - updated original-return procedures for docketed cases to remove ACDS tax period modifier "N" and DKTAD Original field instructions and instead require CAR documentation when APS receives or requisitions the administrative file/original return.

(38) IRM 8.20.5.5.3 - updated NPS monitoring procedures to remove PEAS Type OTH monitoring and require documentation of NPS account monitoring actions in the CAR.

(39) IRM 8.20.5.5.6 - removed former IRM 8.20.5.5.6.2, Joint Return Separate Petitions - Carding the Joint Return, and renumbered the remaining joint-return separate-petition subsections.

(40) IRM 8.20.5.5.7 - updated NPY monitoring procedures to remove PEAS Fast Import, PEAS suspense, PEAS follow-up, and PEAS closing code instructions and replaced them with ACMS CAR and suspense monitoring procedures until Compliance adjustment actions post.

(41) IRM 8.20.5.5.8 - updated paperless docketed case carding to use ECR documentation, ACMS attachments, and ACMS Counsel jurisdiction validation instead of ACDS paperless and ACDS 2.0 notification procedures.

(42) IRM 8.20.5.6 - updated ABINT carding instructions to use ACMS Record Type Exam Appeal / SEPR, category and subcategory entries, and added Date of Claim, Earliest 105/106C Letter Issued Date, Amount Disallowed (Compliance), and Amount Allowed (Compliance) entries.

(43) Former IRM 8.20.5.8, Allocated Tip Tax Case Carding - removed because these cases are included in employment tax carding.

(44) IRM 8.20.5.8 - updated Audit Reconsideration Case Carding to add an Amount Appealed entry for the amount appealed.

(45) IRM 8.20.5.8 and IRM 8.20.5.9.1.1 - incorporated AP-08-0326-0008, New IRM processes for Employee Retention Credit (ERC) cases and ERC claim cases, including feature code RC for audit reconsideration cases with Employee Retention Credits and claim-carding procedures for ERC claim cases, including TS Accounts Management ERC claim timeliness cases under Section 70605(d) of the One Big Beautiful Bill Act.

(46) IRM 8.20.5.9.1.1 and IRM 8.20.5.9.1.3 - separated former Claim or Overassessment Case Carding into Claim Case Carding and Deficiency / Over-Assessment Case Carding and updated the procedures for ACMS.

(47) Former IRM 8.20.5.11, Collection Appeals Program (CAP) Case Carding - relocated to IRM 8.20.14.5, Collection Appeals Program (CAP) Case Carding.

(48) IRM 8.20.5.11 - updated Early Referral Issue Case Carding to identify Early Referral cases in the ACMS Alternative Dispute Resolution field.

(49) Former IRM 8.20.5.12, Collection Cases - New WUNO Creation Requests - removed because the procedures are no longer applicable.

(50) Former IRM 8.20.5.13, Collection Due Process (CDP) and Equivalent Hearing (EH) New Receipts - relocated to IRM 8.20.14.6, Collection Due Process (CDP) and Equivalent Hearing (EH) Receipts.

(51) Former IRM 8.20.5.14, Criminal Investigation (CI) Indicator Awareness - relocated to IRM 8.20.14.6.8, Criminal Investigation (CI) Indicator Awareness.

(52) Former IRM 8.20.5.16, Dyed Fuel and Refusal Penalty Case Carding - removed because these cases are included in civil penalty carding as Excise Penalty / Other Penalty cases.

(53) IRM 8.20.5.16 - updated Estate Tax Case Carding to use ACMS category/subcategory entries, enter the Date of Death field, and enter the tax period as the year and month of death instead of 000000.

(54) IRM 8.20.5.17 - updated Estate Tax IRC 6161 and IRC 6166 Case Carding to use ACMS estate tax category/subcategory entries and removed ACDS type-code, AIMS indicator, and proposed tax field instructions.

(55) IRM 8.20.5.18 - changed title from "Excise Tax Cases and Excise Tax Claim Case Carding" to "Excise Tax Case Carding" and added excise MFT codes 03, 43, 60, 63, 64, and 66 in addition to MFT 40/Form 8849 claim procedures.

(56) IRM 8.20.5.19 - consolidated former source-specific Fast Track Settlement subsections for LB&I, SB/SE, and TE/GE into one FTS carding subsection; updated carding to identify cases using the ACMS Alternative Dispute Resolution field and removed source-specific FTS feature-code entries.

(57) IRM 8.20.5.20 - updated FBAR Penalty Case Carding to use ACMS category Reports of Foreign Bank and Financial Accounts and subcategories FBAR Pre-Assessed and FBAR Post-Assessed, removed feature code IT and AIMS indicator instructions, and added Amount Appealed entry for the total amount appealed per period.

(58) IRM 8.20.5.21 - added Generation-Skipping Transfer Tax Case Carding for MFT 77 Generation-Skipping Transfer Tax Terminations and MFT 78 Generation-Skipping Transfer Tax Distributions, with Deficiency / Over-Assessment and Penalty Abatement Request (PENAP) as available subcategories.

(59) IRM 8.20.5.22 - updated FOIA Administrative Appeal Case Carding to use ACMS category Other and subcategory Freedom of Information Act (FOIA) Appeal, revised the tax period, PBC, statute, and proposed tax/penalty entries, and removed ACDS feature-code, assignment-date, note, and AIMS indicator instructions.

(60) IRM 8.20.5.24.5 - consolidated Innocent Spouse case carding procedures, removed separate joint return WUNO and separate return WUNO subsections, and updated procedures to use ACMS participants and ACMS relationship functionality.

(61) Former IRM 8.20.5.25, Fast Track Mediation - Collection (FTMC) Case Carding - relocated to IRM 8.20.14.7, Fast Track Mediation - Collection (FTMC) Case Carding.

(62) Former IRM 8.20.5.30.6, CDP/EH and Innocent Spouse Case Carding - removed because the procedures are no longer applicable in this IRM.

(63) IRM 8.20.5.25 - added Jeopardy Assessment Case Carding for Administrative Review of Jeopardy Assessments.

(64) IRM 8.20.5.26 - incorporated AP-08-0425-0002, Appeals APS Paperless Procedures for Doubt as to Liability (DATL) Offers in Compromise (OIC) from Small Business/Self-Employed (SB/SE) Field Examination.

(65) IRM 8.20.5.26 - changed title from "Offer in Compromise (OIC) Case Carding" to "Offer in Compromise (OIC) DATL Case Carding" and updated procedures for Exam-originated and Non-Exam originated DATL offers, including the ACMS OIC DATL (Non-CDP) subcategory, source-field guidance for Field and Campus offers, and ACMS relationship procedures for offers involving both SSN and EIN liabilities.

(66) IRM 8.20.5.27 - reorganized Penalty Case Receipts by ACMS civil-penalty subcategory instead of by separate IRC-specific subsections.

(67) IRM 8.20.5.27.1 - updated Civil Penalty Case Carding to include MFT 42 in addition to MFT 13 and MFT 55.

(68) IRM 8.20.5.27.1.1 - added/updated Excise Penalty / Other Penalty Case Carding, including dyed fuel and refusal penalties.

(69) IRM 8.20.5.27.1.2 - added Information Return Penalty Carding.

(70) IRM 8.20.5.27.1.3 - added International Penalty Case Carding and incorporated former IRC 6038 accelerated international penalty carding guidance.

(71) IRM 8.20.5.27.1.4 - renamed and expanded Return Preparer Penalty carding to Return Preparer / Promoter / Appraiser Penalty Case Carding.

(72) IRM 8.20.5.27.1.5 - added Transaction Penalty Case Carding and incorporated former IRC 6676, IRC 670X, and IRC 6707A penalty carding guidance.

(73) Former IRM 8.20.5.32.5, IRC 6707A Penalty Case Carding - removed because these procedures are covered under IRM 8.20.5.27.1.5, Transaction Penalty Case Carding.

(74) Former IRM 8.20.5.32.8, IRC 6682 - Withholding Compliance (WHC) Program Case Carding - removed because these cases are covered by the revised penalty case carding procedures.

(75) IRM 8.20.5.30.1 - updated BBA carding guidance for ACMS by replacing ACDS feature-code and CARAT-code references with ACMS category, feature-code, CAR action record, ACN, appeal number, and AIMS status guidance.

(76) IRM 8.20.5.30.1.2 - added BBA Modification Case Carding, including guidance for identifying BBA modification cases and ACMS entries for FPA/FPAA Date, BBA Modification Date, PICF Code, and Statute Date.

(77) IRM 8.20.5.30.3 - updated title from "TEFRA Investor (TEFRAI) Case Carding" to "TEFRA Investor Case Carding" .

(78) IRM 8.20.5.30.4.3.1 - updated title from "CASES Screen Information for Docketed TEFRA Cases" to "Case Information for Docketed TEFRA Cases" .

(79) Former IRM 8.20.5.35.4.3.2, RETURN Screen Information for Docketed TEFRA Partnership Key Cases - removed because the information was no longer needed after conversion from ACDS RETURN screen procedures to ACMS carding procedures.

(80) IRM 8.20.5.31 - updated TE/GE case carding categories to include Employee Plans, Exempt Organizations, Government Entities - Federal, State and Local & Indian Tribal Governments, and Tax Exempt Bonds.

(81) IRM 8.20.5.31.1.4 - moved TE/GE Employee Plans (EP) 6707A carding to EP 6707A Carding under Employee Plan (EP) Cases.

(82) IRM 8.20.5.31.2 - added Exempt Organization (EO) Case Carding and renumbered EO Determination and EO Revocation subsections.

(83) IRM 8.20.5.31.5 - added Government Entities - Federal, State and Local & Indian Tribal Governments - Case Carding.

(84) IRM 8.20.5.31.6 - added Tax Exempt Bonds Carding.

(85) IRM 8.20.5.32 - updated Transferee/Transferor Case Carding to use ACMS relationship functionality.

(86) Former IRM 8.20.5.37.1.2, Transferee ACDS RETURN Input Screen, and former IRM 8.20.5.37.1.5, Transferor ACDS RETURN Input Screen - removed because the information was no longer needed after conversion from ACDS RETURN screen procedures to ACMS carding procedures.

(87) Former IRM 8.20.5.38, Trust Fund Recovery Penalty (TFRP) Cases - relocated to IRM 8.20.14.10, Trust Fund Recovery Penalty (TFRP) Cases.

(88) Exhibit 8.20.5-1 - updated title from "Innocent Spouse - ACDS STATDATE/Statute CODE Tables" to "Innocent Spouse - ACMS Statute Date/Statute Code Tables" .

(89) Former Exhibit 8.20.5-3, Appeals Centralized Database System (ACDS) Acronyms and Codes Included in IRM 8.20.5, 8.20.6, and 8.20.7 - removed because ACDS acronym and code procedures are no longer applicable.

(90) Former Exhibit 8.20.5-4, AIMS Acronyms and Codes Used in IRM 8.20.5, 8.20.6, and 8.20.7 - renumbered to Exhibit 8.20.5-3.

(91) Former Exhibit 8.20.5-5, IDRS and CFOL Command Codes Used in IRM 8.20.5, 8.20.6, and 8.20.7 - renumbered to Exhibit 8.20.5-4.

(92) Throughout - reviewed and updated website addresses, internal references, IRM references, subsection numbering, and editorial content, as necessary. An artificial intelligence (AI) tool assisted with identifying material changes and editorial revisions, including applying plain language techniques, adhering to the IRM Style Guide, and content organization.

Effect on Other Documents

This IRM supersedes the information in IRM 8.20.5, Account and Processing Support (APS), Carding New Receipts, dated January 30, 2026, and incorporates the following Interim Guidance Memoranda:
AP-08-0924-0019, Updated interim guidance on Appeals Reporting Data Needs (ARDN)
AP-08-0425-0002, Appeals APS Paperless Procedures for Doubt as to Liability (DATL) Offers in Compromise (OIC) from Small Business/Self-Employed (SB/SE) Field Examination
AP-08-0625-0011, IRS Independent Office of Appeals (Appeals) Electronic Case Files Initiative (ECFI) for Small Business/Self-Employed (SB/SE) Excise Tax Cases Implementation
AP-08-0326-0008, New IRM processes for Employee Retention Credit (ERC) cases and ERC claim cases

Audience

Appeals Account and Processing Support (APS)

Effective Date

(08-05-2026)

Steven M. Martin
Director, Operations Support
 

8.20.5.1 (08-05-2026)

Program Scope and Objectives

  1. Purpose: This IRM section describes the carding process for cases worked by Examination Appeals and Specialized Examination Programs & Referrals (SEPR), and the procedures used by Account and Processing Support (APS) for carding these cases. Carding is creating a case record on the Appeals Case Management System (ACMS). Specifically, IRM 8.20.5:

    1. Provides general carding rules for non-docketed and docketed cases.
    2. Provides specific instructions for carding specific case types.
    3. Includes an ACMS statute date/code table for innocent spouse (INNSP) cases as an exhibit.

     

  2. Audience: IRS Independent Office of Appeals (Appeals).
  3. Policy Owner: Appeals Policy is under the Director, Operations Support (OS).
  4. Program Owner: Appeals Policy is the program office responsible for providing technical and procedural guidance to the Appeals organization and is under the Director, Policy, Planning, Quality and Analysis (PPQ&A).
  5. Primary Stakeholders: APS employees.
  6. Contact Information: Appeals employees follow established procedures on How to Contact an Analyst. All other employees should contact the Product Content Owner provided on the Product Catalog Information page for this IRM.
8.20.5.1.1 (08-05-2026)

Background

  1. APS Area Directors report to the Director, Case Support (CS).
  2. The APS-specific IRM sections are in IRM 8.20, Account and Processing Support (APS).
  3. APS responsibilities are described in IRM 8.20.5.1.3, Roles and Responsibilities.
8.20.5.1.2 (07-01-2017)

Authority

  1. IRM 8.20, Account and Processing Support (APS), establishes the APS program and policy framework for Appeals.
8.20.5.1.3 (08-05-2026)

Roles and Responsibilities

  1. The Director, OS, is the executive responsible for designing, developing, delivering, and monitoring short- and long-range tax administration policies, programs, strategies, and objectives for the Appeals organization.
  2. The Director, PPQ&A, is responsible for providing technical and procedural guidance to Appeals employees and establishing and maintaining policies and standard procedures for Appeals’ workstreams.
  3. PPQ&A has two teams of analysts: Collection Policy and Examination Policy. The analyst(s) responsible for APS programs report to the manager for Collection Policy.
  4. The Policy analyst shown on the Product Catalog page as the originator is the assigned author of this IRM.
  5. For more information on Appeals Policy, see the Policy, Planning, Quality & Analysis page on the Appeals website, where you can navigate to the two Policy teams’ web pages.
  6. APS is comprised of three areas: APS Collection, APS Exam, and APS Special Programs. The Director for each of these areas is the senior manager responsible for the control and processing of all Appeals cases. They report to the Director, CS. For more information on APS, see the APS page on the Appeals website.

  7. APS has primary responsibility for the following:

    • Receiving and controlling docketed cases from IRS Compliance (Examination-source) Field and Campus functions.
    • Receiving and controlling non-docketed cases from IRS Compliance (Examination-source) Field and Campus functions.
    • Receiving and controlling all other case types subject to a formal appeal upon the request of the taxpayer.
    • Verifying and controlling the assessment statute expiration date (ASED) on all cases with an open ASED.
    • Timely and accurate entry of all case-related information under Appeals’ and Counsel’s jurisdiction onto ACMS.

     

8.20.5.1.4 (08-05-2026)

Program Management and Review

  1. The APS function utilizes a variety of reports from the following systems to verify, control, analyze, and monitor cases under Appeals’ and/or Counsel’s jurisdiction:

    • Appeals Case Management System (ACMS)
    • Audit Information Management System (AIMS)
    • Innocent Spouse Tracking System (ISTS)
    • Integrated Data Retrieval System (IDRS)

     

  2. The following IRMs provide specific information related to APS program reports:

    • IRM 8.10.1, Internal Reports
    • IRM 8.20.13, Appeals Case Management System (ACMS)

     

8.20.5.1.5 (08-05-2026)

Program Controls

  1. APS program oversight includes participation in operational and evaluative reviews. Controls include statute monitoring, ACMS validation, Form 3210, Document Transmittal, or E3210 acknowledgment controls, inventory monitoring, and managerial reviews.
8.20.5.1.6 (08-05-2026)

Terms and Acronyms

  1. The APS processing IRM terms and acronyms are provided in the following Exhibits:

    • Exhibit 8.20.5-2, General Acronyms and Acronym Definitions Included in APS IRMs 8.20.5, 8.20.6, and 8.20.7
    • Exhibit 8.20.5-3, Audit Information Management System (AIMS) Acronyms and Command Codes (CC) Included in IRM 8.20.5, 8.20.6 and 8.20.7
    • Exhibit 8.20.5-4, Integrated Data Retrieval System (IDRS) and Corporate Files On-Line (CFOL) Acronyms and Command Codes (CC) Included in IRM 8.20.5, 8.20.6, and 8.20.7

     

8.20.5.1.7 (08-05-2026)

Related Resources

  1. Additional APS program information and resources are available as provided below:

    • Account & Processing Support (APS)
    • IRM 8.20.6, Interim Actions
    • IRM 8.20.7, Closing Procedures
    • IRM 8.20.13, Appeals Case Management System (ACMS)
    • IRM 8.20.14, Carding New Collection Receipts
    • IRM 8.20.16, Collection Closing Procedures

     

8.20.5.2 (08-05-2026)

General Statute Responsibility for Account and Processing Support (APS)

  1. IRM 8.21.2, Account and Processing Support (APS) Statute Responsibility, is the primary source for APS policy and procedure when verifying, updating, and monitoring statute dates on Appeals cases.
  2. APS is responsible for verifying and monitoring the statute date on all tax periods or returns under Appeals’ and/or Counsel’s jurisdiction from receipt of the case in APS until receipt of the acknowledged Form 3210 or E3210, from the next function acquiring custody of the case via receipt and acknowledgement of Form 3210. Upon receipt of acknowledgement of the Form 3210, primary jurisdiction and statute responsibility transfers from APS to the recipient as of the date of acknowledgement.

  3. APS has primary jurisdiction of a case under the following circumstances:

    • Case is stamped "Received" by APS but is not yet carded on ACMS
    • Case is received by Appeals in the Appeals Shared Programs Hub Electronic Case Receipts SharePoint (ECR) site
    • Electronic case has been carded on ACMS; however, the case validation/routing action has not yet taken place

    • Case is carded into ACMS and is in transit to the next (non-APS) function (Appeals team manager (ATM), Counsel, IRS function, etc.) and has not yet been acknowledged as received

      Note:

      Form 3210 acknowledgement formally transfers primary jurisdiction for statute control of all listed items to the receiving office.

       

     

8.20.5.3 (08-05-2026)

General Carding Rules

  1. General carding rules apply to all cases received in Appeals.
  2. APS is responsible for researching ACMS for existing cases before carding a new case.
  3. Before carding a new receipt, the APS tax examiner (TE) will search both the open and closed databases to determine whether the taxpayer has a previous case on ACMS and, if so, whether the new receipt is part of another appeal number.

  4. Adherence to the general carding rules supports database accuracy and promotes efficiency by eliminating the need for additional case updates such as:

    1. Changing the appeal number.
    2. Adding a taxpayer name and taxpayer identification number (TIN).
    3. Adding or changing a tax period.
    4. Duplicating cases that are already on ACMS.

     

  5. When the taxpayer has a designated representative or Power of Attorney (POA), the official representative’s name and address is generally available on CFINK. APS must also review the file for a Form 2848, Power of Attorney and Declaration of Representative, or other valid written authorization, because CFINK may not reflect the most up-to-date information. If the Form 2848 or other valid written authorization and CFINK information don’t match, input the POA information with the most recent taxpayer signature date.

  6. Input up to two POAs in the ACMS “Participants” section as the “Primary POA” and “Secondary POA.” Determine the order of inputting the representatives per the instructions below:

    1. First, input the representatives, if any, designated to receive notices and communications from CFINK or Form 2848, whichever has the most recent taxpayer signature date, in the order they appear on CFINK or Form 2848.
    2. If only one representative is designated to receive notices and communications, add the next remaining representative not designated to receive notices and communications. Use the order listed on CFINK or, as applicable, on the Form 2848 with the most recent taxpayer signature date, in the order they appear.
    3. If no representatives are designated to receive notices and communications, use the order listed on CFINK, or, as applicable, on the Form 2848 with the most recent taxpayer signature date, in the order they appear.
    4. If the order on CFINK and Form 2848 does not match, and the taxpayer signature date is the same, use the order shown on Form 2848.

     

  7. If more than one Form 2848 has the same taxpayer signature date, use the order of the Form 2848 as presented in the administrative file.

  8. Do not enter POA information on ACMS for new receipts when:

    • CFINK, Form 2848, or other written authorization (if provided) doesn’t cover all the tax periods included on the appeal,
    • There are joint taxpayers who each have a different POA, or
    • There are joint taxpayers, and one has a POA, and the other doesn’t.

     

  9. For cases meeting the criteria in IRM 8.20.5.3 (8) above, APS will remove any pre-populated POA data and enter in the “APS Notes” field:

    • “POA information is available, but doesn’t match the tax periods included with the appeal” when the tax periods do not match,
    • “Joint taxpayers have different POAs” when there are joint taxpayers with different authorized representatives, or
    • “POA is for primary or secondary taxpayer only.”

     

  10. APS will enter POA information in ACMS in all other circumstances.

    Reminder:

    Treasury Department Circular No. 230, section 10.3, limits who may practice before the IRS and Appeals. Some roles listed on Form 2848 are not authorized to represent taxpayers in Appeals or otherwise are limited to representation with respect to issues. Examples include Level H and Form 8821, Tax Information Authorization, designees. Since they are not authorized to represent the taxpayer before Appeals, their information should not be added to ACMS with the participant role “Primary POA” or “Secondary POA.” If the taxpayer designates a Level H or Form 8821 designee to receive notices and communications, input the designee’s information with the participant role “TIA.”

     

  11. Links to online resources for the CFINK command code (CC) are provided below. Additional information for input on ACMS is available in IRM 8.20.13.3.19, Participants.

    • CFINK Job Aid
    • IRM 2.3.31.2, Centralized Authorization File Inquiry Command Codes CFINK and RPINK - General Description
    • IRM 2.3.31.3, Command Code CFINK - Description and Use
    • IRM 21.3.7, Taxpayer Contacts, Processing Third Party Authorizations onto the Centralized Authorization File (CAF)

     

8.20.5.3.1 (08-05-2026)

Contents of the Administrative File

  1. Depending on the type of case, the administrative file may contain the returns of the taxpayer, consent to extend the statute, if needed, examining officer's report, and other documents relating to the taxpayer's liability for the year or years involved, such as protests or petitions, claims for refund or abatement, and other pertinent documents or papers.

  2. Generally, Examination-sourced administrative files are transmitted to Appeals with an AMDISA print for each return reflecting a current AIMS status of 81, and/or an IDRS CC AMCLS print for each return. The following case types are exceptions:

    • Campus claim cases
    • Penalty Abatement Request (PENAP) cases

    Note:

    When a docketed case is received and the originating function has not taken steps to establish AIMS controls, APS will use AIMS CC AM424A to initiate the request for AIMS controls and, on the same day, use AIMS CC AMSTUA to update the AIMS controls from AIMS status 81 to AIMS status 82 docketed. This action will generate a transaction code (TC) 520 closing code (cc) 72. APS must monitor the account weekly for posting of the TC 420, indicating the AIMS control is fully established, and ensure the AIMS status is updated to docketed AIMS status 82. For additional information see:
    • IRM 8.20.5.3.1.3, AIMS Controls and AIMS Status 
    • IRM 8.20.5.5.2.2, Premature Assessments and Command Code AMSTUR

    Caution:

    The update of AIMS into status 82 via CC AMSTU will generate a TC 520 cc 72. If the TC 520 cc 72 is input manually via CC REQ77, and there are no open AIMS controls at the time of closing, then the TC 520 must be reversed manually.

     

  3. When the taxpayer electronically files their tax return, the IRS neither maintains, nor creates, a paper copy of the return; however, for docketed cases, a print of the electronically filed return must be included in the administrative file provided to Counsel for answer to the petition. APS must verify the return was electronically filed by checking the file location code (FLC) in the TC 150 document locator number (DLN). The FLC is the first and second digit of the TC 150 DLN.

    Reminder:

    APS is responsible for recognizing if the print of the electronically filed return is included in the docketed case file or not. If the print of the electronically filed return is not included in the docketed case file, the APS TE must use the appropriate system to print the electronically filed return and include it in the case file submitted to Counsel.

     

  4. The administrative file for an electronically filed tax return must include a print of the electronically filed return from one of the following sources/systems:

    • IDRS TRPRT
    • Corporate Files Online (CFOL) RTVUE
    • Modernized E-File (MEF) return due date (RDD)
    • Issue Management System (IMS)
    • (This list may not be all-inclusive as a result of changes to existing systems or implementation of new systems)

     

  5. For additional resources specific to electronically filed returns see:

    • IRM 2.3.11, Command Codes TXMOD and SUMRY
    • Document Locator Number for Individual Master File (IMF) electronically filed returns
    • Document 6209, IRS Processing Codes and Information, Section 4 - Document Locator Number, Subsection 5 - Individual Master File (IMF) Electronically Filed Returns General
    • Transcript Return Database (TRDB) information

     

8.20.5.3.1.1 (08-05-2026)
Verifying Administrative File Contents
  1. APS will verify the contents of the administrative file to determine if all documents, returns, and other items listed on the transmittal are present in the file upon receipt in Appeals.

  2. If the administrative file doesn’t contain the letter granting appeal rights and the taxpayer’s protest or appeal, return the case to the originating function with a clear explanation of the information needed to card the case.

    Note:

    Once the originating function submits the completed administrative file, the "Appeal Received Date" should be entered on ACMS as the date the complete administrative file was received.

     

  3. APS will review and determine the statute date on all tax periods received in Appeals, and will verify that there are at least 365 days remaining on the assessment statute before accepting the case. If there are less than 365 days remaining on the assessment statute expiration date (ASED), the APS TE will generally not accept the administrative file in Appeals unless one of the exceptions applies.

    Exception:

     

    Exceptions to the 365-Day ASED Requirement
    ♦ A petitioning/non-petitioning spouse (PS/NPS) docketed case cannot be returned to the originating function; however, IRM 8.20.5.5.3, Docketed Case Carding (Compliance-Issued Statutory Notice of Deficiency (SND)), provides guidance for carding the case on ACMS and verifying that the originating function is controlling the NPS ASED under their jurisdiction.
    ♦ A premature referral case previously returned to Compliance must have at least 180 days remaining on the ASED when Compliance returns the case to Appeals.
    ♦ An estate tax case (Form 706, U.S. Estate Tax Return) must have at least 270 days remaining on the ASED when received in Appeals.
    ♦ An IRC 6206 excise tax case (Form 720, Quarterly Federal Excise Tax Return) must have at least 270 days remaining on the ASED when received in Appeals.
    ♦ A claim case may not have 365 days remaining on the ASED, but if there are open AIMS Controls, the AIMS ASED should include an Alpha Code "AA" in the "DD" field of the numeric ASED. See the Example below.
    ♦ Post-assessment PENAP cases do not require an open ASED and will not have open AIMS Controls.
    ♦ Campus-sourced claims are generally not controlled on AIMS and will not have open AIMS Controls.

     

    Example:

    ASED in a MM-DD-YYYY format would be 04-AA-2016. For other AIMS Alpha Statutes, see Statute of Limitations Alpha Codes for the complete list of AIMS Alpha Statute Codes.

     

  4. For additional guidance see:

    • IRM 8.21.2.4, Cases Not Accepted by Appeals
    • IRM 8.21.2.5, Actions When Statute Date is Uncertain
    • IRM 8.20.5.3.1.2, Cases Not Accepted by Appeals
    • IRM 8.20.5.5.2, Docketed Cases Received in Appeals
    • IRM 8.20.5.5.3, Docketed Case Carding (Compliance-Issued Statutory Notice of Deficiency (SND))
    • IRM 8.20.6.9.2, Petitioning/Non-Petitioning Taxpayer, or Non-Petitioned Year(s) in Multiple Year Compliance-Issued SND, for instructions on docketed cases received in Appeals and processing information for NPS cases. Docketed cases and NPS cases should NOT be returned to the originating function.

     

  5. The APS TE will alert their Processing Team Manager (PTM) when cases with less than 365 days remaining on the assessment statute are received in Appeals.

  6. If a paper case file was received, once the contents of the administrative file and the statute date are verified, date stamp the Form 3210, sign the acknowledgment copy of the Form 3210, and return it to the originator. Place a copy of the date stamped Form 3210 in the administrative file.

    Exception:

    If the E3210 was generated by the initiator using the Transmittal Database, and you also have access to the Transmittal Database, perform the receipt and acknowledgement actions electronically, whenever possible, to avoid unnecessary creation of a paper record. As the IRS continues to progress towards a paperless process for the future state, E3210 generated using the Transmittal Database will gradually replace the current paper Form 3210 to track the transfer of custody of taxpayer records and other tracked documents.

     

  7. Electronic case files received by APS with less than 365 days remaining on the assessment statute not meeting the criteria in (3) above will be returned by APS via encrypted email to the originating business unit. See Technical Services Directory for Technical Services group manager and alternate information. Do not attach the entire electronic case file to the encrypted email. Instead, APS will:

    • State "Short Statute Case - Returned to Technical Services" in the subject line and body of the email
    • List electronic case file identifying information (name, TIN, Master File Tax (MFT), tax year(s), etc.)
    • Follow normal case procedures per IRM 8.20.7.52.1, Jurisdiction Released on Premature or Improper Referrals. Specifically:
      - Return AIMS controls to originating function using CC AMSTUB
      - Attach Form 3210 identifying the earliest ASED for each tax period being returned to originating function
    • Request that the Technical Services manager, or alternate, sign, date, and return Form 3210 to APS

    Note:

    Follow IRM 10.5.1.6.8.3, Emails to IRS Accounts, policy for encrypting all internal email messages that contain Sensitive but Unclassified (SBU) data (including personally identifiable information (PII) and tax information) with IT-approved encryption.

     

8.20.5.3.1.2 (08-05-2026)
Cases Not Accepted by Appeals

  1. Appeals will not accept the following cases:
    Compliance Examination-Source Case Parameters:

    • Compliance Examination case on which the ASED, or extended ASED, has expired on a tax period that is not suspended due to a timely issued SND and also does not include a properly executed Form 10498-B, Joint Investigations Intent to Solicit Consent to Extend Statute, for the expired ASED tax period.
    • Compliance Examination case received with less than 365 days remaining on the ASED unless one of the exceptions identified in IRM 8.20.5.3.1.1 (3), Verifying Administrative File Contents, applies.
    • Compliance Examination case received with an unassessed agreement in the administrative file.
    • Compliance Examination case in 90-day status, but also with Form 8626, Agreement to Rescind Notice of Deficiency, signed by both the taxpayer and/or representative, and the designated official of the IRS and less than 365 days remain on the statute when the case is received in Appeals. If at least 365 days remain on the statute, accept the case and card it on ACMS.
    • Compliance Examination jeopardy or termination assessment unless an SND has been issued and the taxpayer has filed a petition with the U.S. Tax Court (USTC). The only exception for this case type is when the case is received in Appeals for administrative review, pursuant to IRC 7429.

    Reminder:

    In determining the timeliness of the protest, the guidelines in IRC 7503 should be followed, which state, in part: "When the last day prescribed under authority of the Internal Revenue laws for performing any act falls on Saturday, Sunday, or a legal holiday, the performance of such act shall be considered timely if it is performed on the next succeeding day which is not a Saturday, Sunday, or a legal holiday."

     

  2. If an APS employee receives any of the cases listed above for carding in, alert the PTM prior to returning the case to the originating function for direction on how to proceed.

    Note:

    See IRM 8.21.2, Account and Processing Support (APS) Statute Responsibility, for additional information.

     

8.20.5.3.1.3 (08-05-2026)
AIMS Control and AIMS Status

  1. Cases including one or more tax period(s) with open AIMS controls are received in Appeals in AIMS status 81, Not Assigned Appeals. Each tax period’s AIMS control must be updated to status 80, Non-Docketed, or status 82, Docketed, at the time the case is carded on ACMS. The Bipartisan Budget Act (BBA) (formerly Tax Equity and Fiscal Responsibility Act (TEFRA)) cases are updated to Appeals in status 71 and must be updated to status 70, if non-docketed, status 72, if docketed, or status 73, if the case is BBA modification.

    1. Use CC: AMSTUA to update AIMS to status 80, if the return is non-docketed, or to status 82, if the return is docketed.
      For BBA cases, use CC: AMSTUA to update AIMS to status 70, if the return is non-docketed, or to status 72, if the return is docketed.
    2. Use CC: AMSTUB to update the ASED when appropriate and necessary.
      For docketed BBA cases, use CC: AMSTUB to update the statute to XXQQXXXX.

     

  2. See IRM 8.20.5.3.1.1 (3), Verifying Administrative File Contents, for several examples of case types that will not have AIMS controls. The list is not all-inclusive.
  3. APS must input the AIMS Activity Code on ACMS when carding cases with AIMS controls. This three-digit code is found on AMDISA and/or the ECR checksheet.

  4. Input feature code "LC" for cases with all the following criteria:

    • Originating Function: Large Business and International (LB&I)
    • AMDISA Line 3 shows indicators Coordinated Industry Case (CIC) or Large Corporate Case (LCC)
    • Feature code is not EQ (Equitable Relief Cases) or SD (Spousal Defense)
    • Case is not under the category “Collection Due Process” or “OIC (Offer in Compromise)”
    • Case is not under the subcategory “Penalty Appeal (PENAP)”

     

  5. Input feature code "MC" for cases with all the following criteria:

    • Case does not meet the criteria for feature code "LC"
    • Feature code is not EQ (Equitable Relief Cases) or SD (Spousal Defense)
    • Primary Business Code (PBC) first digit is 3 (LB&I) that does not have feature code LC, or PBC first digit is 2 (Small Business/Self-Employed (SB/SE)) and the activity codes are between 219-231, or 241, 259, 263, 265, or 290
    • Case is not under the category “Collection Due Process (CDP)” or “OIC (Offer in Compromise)”
    • Case is not under the subcategory “Penalty Appeal (PENAP)”

     

  6. Carefully review CC AMDISA to identify certain types of cases that need to be identified by specific ACMS entries:

    1. TEFRA key cases are identified by a Partnership Information Control File (PICF) code "1" and an "H" freeze.
    2. BBA indicators and the Audit Control Number (ACN) number can be found on CC AMDISA.

     

8.20.5.3.1.4 (08-05-2026)
Case Routed to an Incorrect Appeals Office
  1. If APS receives a new case for carding, and it should have been routed to another Appeals office, the receiving APS office must card the case on ACMS and validate it. Carding the case will ensure the statute is protected.
  2. If the case is identified as paper, ship the case to the appropriate Appeals office by using the “File Shipment” functionality located in the Documents section of the appeal. See IRM 8.20.13.6.8, Documents, and IRM 8.20.13.6.9, File Shipments, for more information.
8.20.5.3.1.5 (08-05-2026)
Appeal Number

  1. Appeal numbers are established on ACMS as follows:

    1. Non-docketed - generally cases that have returns with the same TIN and MFT code received at the same time (that are included in a Revenue Agent Report (RAR) or other tax computation document) will be one appeal number.
    2. Docketed - every docket number is carded as a separate appeal number. See IRM 8.20.5.3.1.5 (2) below for more specific carding guidance on NPS or Non-Petitioning Year (NPY) cases.

     

  2. The Compliance Examination functions issue separate SNDs to each taxpayer on a jointly filed tax return, and may occasionally issue a separate SND for each tax period for examinations involving multiple years. Separate appeal numbers are required for each docket number. For guidance on carding a Petitioning/NPS case or a Petitioned/NPY case type, see:

    • IRM 8.20.5.5.5, Non-Petitioning Spouse (NPS) Cases
    • IRM 8.20.5.5.7, Non-Petitioned Year (NPY) Case Carding



    The table below provides several different docketed appeal number scenarios and how the respective case(s) are carded:
     

    If...And...Then...
    separate notices of deficiency were issued on a jointly filed tax returntaxpayers file a petition together (jointly)establish one appeal number. 
    Both taxpayers on the joint return have the same docket number as a result of their jointly filed petition.
    separate notices of deficiency were issued on a jointly filed tax returntaxpayers file separate petitions and have separate docket numbersestablish each docket number as a separate appeal, and enter the primary Social Security Number (SSN) from the key case in the APS Notes field. See IRM 8.20.5.5.6 for guidance.
    the examination involved multiple tax periodstaxpayer’s petition includes all tax periods shown on the notice of deficiencyestablish one appeal number.
    the examination involved multiple tax periodstaxpayer files one petition for a jointly filed tax period and a separately filed tax periodestablish one appeal number if the primary SSN is the same, or separate appeal numbers if the primary SSN is not the same.
    the examination involved multiple tax periodstaxpayer’s petition does not include all the tax periods shown on the notice of deficiency and the administrative file only includes the petitioned tax period return(s)

    establish one appeal number for the petitioned year(s).

    Reminder:

    Any non-petitioned tax period remains in the originating function’s jurisdiction and, as a result, the AIMS control and AIMS status for the non-petitioned tax period are not closed to Appeals status.

    See IRM 8.20.6.9.2 (10), Petitioning/Non-Petitioning Taxpayer, or Non-Petitioned Year(s) in Multiple Year Compliance-Issued SND, for additional guidance.

    the examination involved multiple tax periodstaxpayer’s petition does not include all the tax periods shown on the notice of deficiency, but the administrative file includes both the petitioned tax period return(s) as well as the non-petitioned tax period return(s)

    establish one appeal number for the petitioned year(s).

    Reminder:

    Any non-petitioned tax period remains in the originating function’s jurisdiction and as a result, the AIMS control and AIMS status for the non-petitioned tax period are not closed to Appeals status.

    See IRM 8.20.6.9.2 (10) for additional guidance.
    ✓ Notify your PTM to request Counsel involvement and verification of the tax periods in Counsel’s jurisdiction.

     

  3. Special procedures will apply for docketed or non-docketed cases covered later in this IRM.

  4. In situations where multiple cases are related, the following rules apply:

    1. One appeal number is designated as the "key case."
    2. The APS TE will enter the key case first and the related cases last, and will link the cases using the ACMS relationship functionality.
    3. See IRM 8.20.5.4.1.3.2, Related/Reference Cases on ACMS, for additional information.

     

8.20.5.3.2 (08-05-2026)

ACMS Case Validation

  1. The APS TE will be required to validate the data upon creation of the case. Validation is required to move the case to the appropriate queue for assignment to an Appeals Technical Employee (ATE). Refer to IRM 8.10.3, Appeals Inventory Validation Process, for additional information regarding validation.

  2. The ACMS critical data fields (CDFs) that the APS TE has responsibility for in the Create Case Validation are indicated below:

    SectionACMS CDF
    Related Taxpayer Validation
    • Name
    • Role
    • TIN
    • Address
    Appeal Validation
    • Taxpayer Request Date
    • Category
    • Subcategory
    Tax Period Validation
    • MFT Code
    • Tax Period
    • Statute Code
    • Statute Date
    Time Entry
    • Enter Hours Worked

     

  3. Docketed cases should be linked to the applicable public matter and docket number. See IRM 8.20.13.5.10, Docketed Information, and IRM 8.20.13.5.10.1, Appeal Public Matters, for more information.
  4. When validating a docketed case linked to a public matter and docket number, an additional field titled, “Counsel Jurisdiction,” appears, with a yes or no option to move the appeal to Counsel’s jurisdiction with a suspense reason.
  5. If an error is encountered during validation, return to the appeal and make the applicable corrections before validating the appeal number.
8.20.5.3.3 (08-05-2026)

Issue Management System (IMS)

  1. IMS is LB&I’s case management system. Appeals’ use of IMS is mandatory for working cases from the following IRS sources:

    • LB&I
    • SB/SE Employment Tax
    • SB/SE Estate and Gift Tax
    • SB/SE Excise Tax

     

  2. ACMS will remain the Appeals system of record for case management and recording time on cases. For step-by-step instructions for IMS, refer to Integrated Talent Management (ITM) Course 39821, Issue Management System for Appeals Processing Employees.
  3. The primary role of the APS employee in IMS is to assign a case, re-assign a case, or re-open a closed case. The APS employee has permissions to view Appeals cases to be assigned, opened (currently assigned), and closed on the Appeals portal. An APS employee may assign an Appeals case to an ATM, re-assign an open Appeals case, or re-open a closed Appeals case on the web portal.
  4. A Business Entitlement Access Request System (BEARS) access request is required to gain access to IMS. Each user should request the “IMS-PRODUCTION-LMSB USER ACCESS” application and add a statement indicating “An Examination Returns Control System (ERCS) ID is not required.”
8.20.5.4 (08-05-2026)

General Carding Information for Non-Docketed Cases

  1. Appeals’ responsibility includes, but is not limited to, cases that involve a tax liability. In most cases, a 30- or 60-day letter has been issued to the taxpayer by the Compliance Examination function, in either the Field or a Campus operation. Taxpayers request an Appeals conference and, when required, file a protest against the proposed deficiency, overassessment, or NOD. A non-docketed case is a protested case in which the taxpayer has not been issued an SND and has not filed a petition with the USTC.

  2. The APS TE carding the case on ACMS will take the following actions upon receipt and verification of the case contents:

    StepAction
    1.Enter items on ACMS, as applicable. See IRM 8.20.13.3, Establishing Appeals Cases on ACMS, for additional information.
    2.Verify the data is correct and submit the validation. See IRM 8.20.13.4, Validating and Routing the Appeal, for additional information.
    3.For paper cases, check the Paper box when carding the case. See IRM 8.20.13.3.14, Paper, for additional information.
    4.If the case is identified as paper, ship the case to the appropriate Appeals office by using the “File Shipment” functionality located in the Documents section of the appeal. See IRM 8.20.13.6.8, Documents, and IRM 8.20.13.6.9, File Shipments, for more information. The ATE makes a preliminary review of the case and validates data on ACMS. If corrections are required, the ATE will update the case information, if able, or send a support request to APS to update the data fields.

     

8.20.5.4.1 (08-05-2026)

Non-Docketed Receipts

  1. The APS TE verifies the administrative file contents. This verification is mandatory for all documents, returns, etc. listed on the Form 3210 prior to entering their signature and date in the Received and Verified block.

  2. The administrative file may contain the following items:

    • Original or copy of one or more examined tax returns - determines the tax period(s) entered.
    • Valid consents extending the statute (if needed) - determines the statute date and statute code entered for each tax period.
    • Examining officer's report - identifies the proposed tax and proposed penalty amount entered for each tax period.
    • Other documents relating to the taxpayer's liability for the year or years involved, such as protests, claims for refund or abatement, and other pertinent documents or papers - determines the category and subcategory.

     

  3. Depending on the type of case, the administrative file may also contain the following documents:

    • History
    • Correspondence
    • Financial Information

     

  4. The APS TE will determine the statute date and ensure there are at least 365 days remaining on the statute before accepting the case. For additional information see:

    • IRM 8.20.5.3.1.2, Cases Not Accepted by Appeals
    • IRM 8.21.2, Account and Processing Support (APS) Statute Responsibility

     

  5. If a paper copy of the file was received, once the contents of the administrative file and the statute date are verified, the APS TE will sign the acknowledgment copy of the Form 3210, return it to the originator, and place a copy in the case file.

    Exception:

    If the Form 3210 was generated by the initiator using the E3210 Transmittal Database, and you also have E3210 Transmittal database access, perform the receipt and acknowledgement actions electronically whenever possible to avoid unnecessary creation of a paper record. As the IRS continues to progress towards a paperless process under the future state, E3210s will gradually replace the current paper Form 3210 for taxpayer records transfer of custody purposes.

     

8.20.5.4.1.1 (08-05-2026)
Non-Docketed Case Types Requiring an Original Return

  1. Original returns must be received in the following situations:

    • Fraud case
    • Delinquent return
    • Jeopardy assessment

     

  2. The cases referred to in (1) above may be accepted without the original return if the case file contains an unfilled requisition, a print of the electronically filed return, or a copy of the return. However, fraud cases are only accepted under this paragraph if the missing original returns do not seriously weaken the government’s position. The ATE will make this decision.
  3. If it becomes necessary for Appeals to issue an SND, or if the case develops into one of the other exceptions in (1) above, the ATE may request the original return through a support request.
8.20.5.4.1.2 (07-01-2017)
AIMS Status Updates

  1. Administrative files closed to Appeals via CC: AMCLSE are transmitted to Appeals, along with an AMDISA print, for each return reflecting a current AIMS status of 81, or an AMCLS print reflecting each return on AIMS.

    1. Update AIMS to status 80 if the return is non-docketed.
    2. Verify the statute date on AIMS and, if necessary, update the statute date on AIMS using AIMS CC: AMSTUB.

    Note:

    When a non-docketed case is received, and the originating function has not taken steps to establish AIMS controls, APS will use AIMS CC: AM424A to initiate the request for AIMS controls and on the same day, input AIMS CC: AMSTUA to update the AIMS status from 81 to 80 for non-docketed or 82 for docketed cases. For additional information see:
    • IRM 8.20.5.3.1.3, AIMS Controls and AIMS Status
    • IRM 8.20.5.5.2.2, Premature Assessments and Command Code AMSTUR

     

  2. When the taxpayer electronically files their tax return, the IRS neither maintains, nor creates, a "paper copy" of the return; however, for a physical (non-electronic) administrative file submitted to Appeals, a print of the electronically filed return must be included. The administrative file for an electronically filed tax return will include a print of the electronically filed return from one of the following sources/systems:

    • IDRS TRPRT
    • CFOL RTVUE
    • MEF RDD
    • IMS
    • (This list may not be all-inclusive as a result of changes to existing systems or implementation of new systems)



    APS must verify the return was electronically filed by checking the FLC in the TC 150 DLN.

    Reminder:

    The FLC is the first and second digit in the TC 150 DLN.



    For additional resources specific to electronically filed returns see:

     

8.20.5.4.1.3 (08-05-2026)
Non-Docketed Case Carding

  1. Establish appeal numbers on ACMS as follows:

    1. Non-docketed - generally cases that have returns with the same TIN and MFT received at the same time and that are included in an RAR or other tax computation documents are one appeal number.
    2. Non-docketed Non-TEFRA Flow-Through Entity (FTE) Returns - carded per procedures provided in IRM 8.20.5.4.1.4.1, Non-Docketed Non-TEFRA FTE Returns Carding.

     

  2. In situations where multiple cases are assigned, the following rules apply:

    1. An appeal number must have one case designated as the "Key Case"

    2. A Key Case appeal number must have one or more cases designated as the "related case(s)"

      Note:

      See IRM 8.20.5.4.1.3.2, Related/Reference Cases on ACMS, for more information.

       

     

  3. The APS TE will validate data fields after establishing the case on ACMS. See IRM 8.20.13.4, Validating and Routing the Appeal, for additional information.

    Reminder:

    APS must input the AIMS Activity Code on ACMS for all cases with AIMS controls. This three-digit code is found on AMDISA and/or the ECR checksheet.

     

8.20.5.4.1.3.1 (08-05-2026)
Multiple Filer Form 1040 Cases
  1. A multiple filer condition occurs when an SSN is used as a primary taxpayer on one return for a given tax period, and as a secondary taxpayer on a different return for the same tax period.
  2. When a taxpayer electronically files an MFJ Form 1040, U.S. Individual Income Tax Return (with only their signature), and the other taxpayer whose SSN was included on the MFJ Form 1040 files a Married Filing Separate (MFS), Head of Household or Single Form 1040, as a separate electronic return or separate paper return, Master File (MF) will post the second return as outlined in IRM 21.6.7.4.5 (2), Multiple Uses of Taxpayer Identification Numbers - (DUPTIN Filing Condition), and a CP 36F, DUPTIN Filing Condition, is generated. These types of cases are only worked in Brookhaven (IMF) and Philadelphia (International) Accounts Management. If the case cannot be resolved, it is routed to Examination Classification. See IRM 4.19.15.37, Multiple Filers, for additional information.

  3. APS will card non-docketed and docketed case receipts following the respective applicable guidance:

    • IRM 8.20.5.4, General Carding Information for Non-Docketed Cases
    • IRM 8.20.5.5, General Carding Information for Docketed Cases

     

  4. APS will also card the protested or petitioned case as the key case and the associated return as a related reference return using guidance provided in IRM 8.20.5.4.1.3.2, Related/Reference Cases on ACMS.
8.20.5.4.1.3.2 (08-05-2026)
Related/Reference Cases on ACMS
  1. APS will use the ACMS "relationship" functionality to link related appeal numbers.

  2. See the following IRM sections for additional information:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeal Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

  3. See the following subsections for additional information:

    • IRM 8.20.5.4.1.3.3, Reference Returns Non-Taxable Carding
    • IRM 8.20.5.4.1.4.1, Non-Docketed Non-TEFRA FTE Returns Related to Non-Docketed Case Carding

     

8.20.5.4.1.3.3 (08-05-2026)
Reference Returns Non-Taxable Carding
  1. Non-Taxable reference returns are controlled on ACMS with the subcategory "Reference Return."

  2. Include the following information:

    • Statute Date - Enter the actual assessment statute date if still open
    • Statute Code - Enter RFRTN if the assessment statute is not open
    • Docket Number - For any reference returns related to a docketed case, enter the docket number

    Note:

    If the statute date expires within 60 days from carding, email the technical advisor for the Area queue to which the case is assigned to advise of the imminent statute. Visit Appeals Leadership for a listing.

     

  3. Update AIMS to status 80, if the case is on AIMS when it is received in Appeals. In general, reference returns are non-docketed, and should be updated to status 80 even if they are related to a docketed case that is in AIMS status 82.

    Exception:

    Non-docketed non-TEFRA FTEs related to a docketed investor case are carded on ACMS, as provided in IRM 8.20.5.4.1.4.2.1, Additional Instructions for the Non-Docketed Non-TEFRA FTE ACMS Record, when related to a Docketed or Non-Docketed Investor Key Case.

     

  4. APS will use the ACMS "relationship" functionality to link related appeal numbers.
8.20.5.4.1.3.4 (08-05-2026)
Sending the New Case to the Appeals Team Manager (ATM)
  1. When carding in a new receipt on ACMS, the APS TE will also complete validation, confirming that all information input to ACMS matches the source documents PRIOR to validating the case, which sends the case to a queue for assignment. See IRM 8.20.13.4, Validating and Routing the Appeal, for additional information.
  2. When a paper file is received, and the ATM is not co-located with APS, the APS TE must prepare an E3210 to send a case to the ATM for assignment. Ship the case to the appropriate Appeals office by using the “File Shipment” functionality located in the Documents section of the appeal. See IRM 8.20.13.6.8, Documents, and IRM 8.20.13.6.9, File Shipments, for more information.
  3. The ATM will review the case in Correspondence Examination Automation Support (CEAS) View and will assign the case in ACMS to the ATE.
  4. APS TEs must monitor every case that leaves APS whether for assignment, rework, etc. regardless of whether or not they are physically located in the same office until they receive acknowledgement or can verify the case reached the ATM or intended recipient.

  5. APS TEs must follow up on all unacknowledged Form 3210(s) within 10 business days. The APS TE will prepare Form 10946, Follow-up on Acknowledgment of Forms 3210, and transmit it along with a copy of the unacknowledged Form 3210(s), to the function or recipient identified in the unacknowledged Form 3210 To block.

    Exception:

    If the Form 3210 transmitting the case to the ATM was generated by the APS TE using the E3210 Transmittal Database, and the ATM/recipient does not have access to the E3210 Transmittal Database for their receipting process, the APS TE will self-acknowledge the E3210 upon verification of receipt by the ATM or their designee. APS will perform the receipt and acknowledgement actions electronically whenever possible to avoid unnecessary creation of a paper record. As the IRS continues to progress towards the future state, E3210s will gradually replace the current paper Form 3210 for taxpayer records transfer of custody purposes.

     

  6. For information on what the ATM does with the case upon receipt for assignment, see IRM 1.4.28.4, Assignment and Control of Work.
8.20.5.4.1.4 (08-05-2026)
Non-Docketed Non-TEFRA Flow-Through Entity Case Carding Background and History Overview
  1. Prior to January 1, 2002, the non-TEFRA FTE returns were carded as reference returns and linked to the investor key case in the same “work unit number,” the term used before ACMS appeal number terminology.
  2. From January 1, 2002, to February 29, 2016, the non-TEFRA FTE returns were established as a separate work unit number, which allowed the ATE to apply time to each return/entity rather than applying all the hours to only the investor key case (MFT 30).
  3. From March 1, 2016, through June 30, 2017, the non-TEFRA FTE returns were established as a reference return and linked to the investor key case in the same work unit number per an Appeals process improvement team.
  4. Beginning on July 1, 2017, the carding procedures established on March 1, 2016, are repealed to resolve unforeseen database and reporting problems created by the change established per (3) above.
  5. Beginning August 10, 2026, the non-TEFRA FTE returns are established as a separate appeal number, which allows the ATE to apply time to each return/entity. The appeal numbers are linked using ACMS relationship functionality.
8.20.5.4.1.4.1 (08-05-2026)
Non-Docketed Non-TEFRA Flow-Through Entity Returns Related to Non-Docketed Case Carding
  1. A non-TEFRA FTE may be a partnership return 1065 (MFT 06), an S Corporation 1120-S (MFT 02), or a Trust 1041 (MFT 05).
  2. If the return is linked on the Pass-Through Control System (PCS), there will be a PICF code 2 on the AMDISA print.

  3. APS will enter the following on ACMS:

    • Category / Subcategory - Enter the code that represents the type of tax or penalty for the investor key case

     

  4. Link the related appeal numbers with ACMS relationship functionality. For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

  5. Follow carding procedures in IRM 8.20.13, Establishing Appeals Cases on ACMS, except for the following:

    • Category / Subcategory - Enter the code that represents the type of tax or penalty for the investor key case

    • Statute Date - Enter the actual statute date

      Exception:

      If AMDISA shows an alpha statute code of GG, leave statute date blank.

       

    • Statute Code - Enter "RFRTN"
    • When the ATE validates the case upon receipt, they will verify the ASED and update the statute date and/or statute code, as appropriate.

    Note:

    For Examination’s AIMS and ASED requirements when submitting a case to Appeals, see IRM 25.6.23.4.5, Responsibility for Investor Returns - Investor Level Statute Control, and for detailed information applicable to AIMS alpha statute codes, see IRM 25.6.23-3 Exhibit (4), Instructions for Updating the Statute on AIMS.

     

  6. The APS TE will validate all CDFs after establishing the case on ACMS. See IRM 8.20.5.3.2, ACMS Case Validation, for the create case validation CDFs.

  7. Appeals will receive and accept certain non-TEFRA FTE returns with less than 365 days on the ASED reflected on AIMS as long as the related investor return has at least 365 days remaining on the ASED when received in Appeals. The ASED for assessments flowing from a non-TEFRA FTE return is determined and controlled by the ASED of the partner or shareholder return.

    Reminder:

    AIMS programming does not allow a statute update from a date to an alpha code until there are less than 210 days on the statute. As a general rule, Examination does not update the AIMS statute date on a non-TEFRA FTE return to alpha code "GG" (or other appropriate alpha code) until 180 days prior to the ASED.

     

8.20.5.4.1.4.2 (08-05-2026)
Non-Docketed Non-TEFRA Flow-Through Entity Related to a Docketed Case Carding

  1. When a non-docketed non-TEFRA FTE is related to a docketed case, APS will also enter the docket number of the related case, if available.

    Note:

    Whenever the related case is docketed in Small Tax Court, the docket number will include a definer "S" .

     

8.20.5.4.1.4.2.1 (08-05-2026)
Additional Instructions for the Non-Docketed Non-TEFRA Flow-Through Entity ACMS Record when related to a Docketed or Non-Docketed Investor Key Case
  1. The process outlined below, although not purely carding guidance, is required to demonstrate the intended effect of the related case movement throughout the dispute resolution process.

  2. The non-docketed non-TEFRA FTE case will remain with the related investor key case throughout the following stages of the Appeals dispute resolution process:

    • Submission to the ATM for assignment to an ATE
    • Assignment to an ATE
    • Assignment to APS for issuance of an SND on the unagreed key case

    Note:

    * The ATE provides closing instructions and information for the non-docketed non-TEFRA FTE appeal number at the time the related investor key case is approved for closure for issuance of the SND. APS will not close the non-docketed non-TEFRA FTE appeal number until the investor key case is ready to be closed.

     

  3. Potential outcomes once Appeals issues an SND:

    • Taxpayer agrees and the investor case and non-docketed non-TEFRA FTE are closed per applicable procedures
    • Taxpayer defaults and the investor case and non-docketed non-TEFRA FTE are closed per applicable procedures
    • Taxpayer petitions and the docketed investor case along with the non-docketed non-TEFRA FTE case are updated to Counsel’s jurisdiction. See IRM 8.20.5.4.1.4.2.1 (4) below.

     

  4. When Appeals issues an SND on an investor key case that is related to the non-TEFRA key case, and the unagreed issues include those raised for the non-TEFRA key case, the non-TEFRA key case should be moved to Counsel’s jurisdiction if there is a petition filed in the USTC. The docket number of the investor case should be entered on the non-TEFRA key case in ACMS in the docket number field. See IRM 8.20.5.4.1.4.2 (1) for instructions and examples. The non-TEFRA key case should not be closed from either ACMS or AIMS, and instead should be sent to Counsel for answer along with the investor case.
  5. All ACMS updates which change the jurisdiction for the docketed key case also apply to the non-docketed non-TEFRA FTE case.
8.20.5.5 (08-05-2026)

General Carding Information for Docketed Cases

  1. This section includes guidance for APS on the following topics:

    • Docket list
    • Docketed cases received in Appeals
    • Docketed case carding (Compliance-issued SND)
    • Docketed case not received timely in Appeals
    • Joint return - separate petitions
    • Joint petition - separate returns
    • NPS cases
    • NPY
    • Premature petitions

     

8.20.5.5.1 (08-05-2026)

Docket List

  1. Counsel transmits the list to employees in the functions that issue SNDs and NODs. The list helps these functions determine if a case is docketed so that they can process the case appropriately. The docket list is a list of cases docketed by the USTC. The list is prepared by Counsel after the USTC serves the taxpayer's petition(s) to the Commissioner of Internal Revenue. The list is used as a tool to help source functions determine if a case is docketed.
8.20.5.5.1.1 (01-30-2026)
Docket List Responsibilities

  1. Business units that issue notices which include the right to file a petition with the USTC, are responsible for monitoring the docket list to determine if a petition is filed in response to a letter or notice they’ve issued. The following list identifies two general (but not all-inclusive) categories of notices, which may include the right to file a petition with the USTC:

    • SND
    • NOD

     

  2. If a petition is filed, the business unit that issued the notice is responsible for locating the case and processing it to Appeals using disposal code 11, within 10 calendar days from receipt of the docket list.

    Caution:

    When an SND is issued on an MFT 30 MFJ tax period, and the petition to the USTC is signed by one spouse but not the other, the business unit that issued the SND must follow their respective IRM guidance to prepare a Dummy File for their continued suspense of the NPS to await the closing action for the NPS SND. Examples of the eventual closing action for the NPS can be:
    • A waiver of agreement signed by the NPS;
    • A separate petition filed on a later date by the NPS;
    • Or default of the SND for the NPS. 

    The PS case must be identified by the originating business unit as a PS/NPS case, and transmitted to Appeals within 10 calendar days from receipt of the docket list to ensure Counsel has adequate time to file an answer to the petition.

     

  3. The USTC requires the filing of an "answer" by the Commissioner of Internal Revenue in all docketed tax cases.
  4. Employees responsible for monitoring the docket list must be aware of and take all necessary actions to ensure Counsel receives docketed administrative files with sufficient time remaining to meet the due date established by the USTC to answer the petition.
  5. The answer due date, or the time within which the petition must be answered, is set by the USTC at 60 days from the date the petition is served on the IRS.
  6. Counsel needs time to prepare the answer; therefore, APS must make every effort to card the administrative file and send it to Counsel to ensure it is received in Counsel no later than 20 days prior to the answer due date.

  7. In the instance where a taxpayer provides supporting documentation to a business unit in response to an SND issued by that business unit, it is possible for that business unit to accept the information and formally "no change" the case. Whenever this occurs, the function receiving and accepting the taxpayer’s documentation as fully resolving the proposed adjustments included on the SND they issued, must certify in writing that they have reviewed the documentation and determined that no changes are needed to the taxpayer’s return as filed. The function will prepare and sign a Form 14121, No Change Certification, which must then be transmitted to the Field Counsel attorney assigned the petitioned case, as well as to the APS docketed team. For no change certifications from SB/SE, IMF Automated Underreporter (AUR), TS, and SB/SE Correspondence Exam groups, the Form 14121 must be transmitted to APS via the ECR SharePoint site and identified as being of "Type of Case" "DKT No-Change F14121". Upon receipt of Form 14121, the APS TE must coordinate the disposition of the newly no change case with the respective Counsel attorney. This "Docketed No Change Certification" procedure:

    1. Enables the business units to close their case and avoid retrieving and sending the administrative file to Appeals/Counsel
    2. Notifies APS that the administrative file is not needed, stops additional efforts to retrieve the file
    3. Provides Counsel with sufficient information to concede the case on answer

     

  8. See IRM 8.20.5.5.3.1, Compliance Function No-Changes the Statutory Notice of Deficiency (SND), for additional information.
8.20.5.5.1.2 (08-05-2026)
Timeline From Date Petition Served to Answer Due Date

  1. The following table provides a timeline for various actions required, beginning on the day the petition is served on the IRS.

    DAYACTION REQUIRED
    1Petition served on IRS.
    1 - 3Docket list prepared and distributed.
    1 - 19Business units monitor docket lists to identify, locate, close, and transmit docketed files to Appeals.
    20 - docketed administrative file received in Appeals

    The docketed team creates a skeletal ACMS record and APS perfects the ACMS record when appropriate.
    Business units continue process to identify, locate, close, and transmit docketed files to Appeals.
    APS begins searching for docketed files not yet received 20 calendar days from the petition served date. If the administrative file is not received by 20 calendar days from the petition served date, APS will:

    • Create an appeal number from the public matter folder, and
    • Follow-up with the originator of the administrative file.

    Note:

    Within two business days of receipt, APS acknowledges, cards, and transmits the file to Counsel for answer.

    35Second follow-up with the originating office.
    Perfect the “docketed pending” appeal record and validate the appeal number.
    60Answer due date.

     

8.20.5.5.1.3 (08-05-2026)
APS Docketed Case Responsibilities

  1. APS follows these steps upon receipt of a paper or paperless case:

    • Establish/update the case on ACMS by linking the public matter record with the appeal number.
    • Update AIMS/IDRS.
    • Determine if the appeal number should be updated to Counsel’s jurisdiction or sent to an ATM for assignment:
      If Electronic Counsel Inventory Tracking Environment (eCITE) shows Appeals’ jurisdiction and the answer is uploaded to the public matter record, forward or update the case to the ATM. 
      For any other eCITE status, forward the file to Counsel.

     

  2. The PTM, lead, or assigned TE will take the steps shown in the following table:

    APS Tax Examiner Actions Based on the ACMS Record

    IF...THEN...
    If the case is controlled and open on ACMS
    • Link the case to the public matter via the “Docketed Information” tab. Select “Yes” to place the case in Counsel’s jurisdiction, with suspense reason - trial preparation.
    • Update the case action record (CAR) with clear and concise notes.
    If the case is closed on ACMS
    • Coordinate with the PTM and ATM in the controlling office to request they reopen the ACMS record and link the case to the public matter via the “Docketed Information” tab. Select “Yes” to place the case in Counsel’s jurisdiction, with suspense reason - trial preparation.
    • If the case was processed as paper, request the refile DLN from files, inform Counsel it has been ordered, and forward to Counsel when received.

    Note:

    If the case was previously worked and closed by Appeals, and the petition is late filed greater than 30 days after default/closure date, APS will not request the case be reopened on ACMS. APS will create a new skeletal record and monitor the case for dismissal and closure.

    If the case is not controlled on ACMS
    • Card in a new appeal number by selecting “Docketed” from the ACMS home page “Card In an Appeal” section.
    • Using the Electronic Tax Court System (eTCS) site, retrieve a copy of the petition and upload it to ACMS as an attachment.
    • If AIMS is in status 24, input CC AMFRZQ to generate a Q freeze on each period petitioned.
    • If AIMS is in status 51-55, input CC AMFRZQ to generate a Q freeze on each period petitioned. Email Centralized Case Processing (CCP) to forward the administrative file to Technical Services and include the contact from that issuing office.
    • If AIMS is in status is 81 for Examination cases, the case is already in transit to Appeals.
    • Create an action record with clear and concise notes and to complete the appropriate milestone.


     

     

  3. Use the table below to determine if an SND has been issued:

    Compliance FunctionSND Issuance IndicatorIdentify the Manager
    Automated Questionable Credit (AQC) 
    Return Integrity and Compliance Services (RICS)
    • IDRS - TC 971 AC 140
    • IDRS - TC 971 AC 122
    • Identify the five-digit IDRS unit from IDRS Case Control
    • Research IDRS and Unit Security Representative (USR) Database (IUUD) to identify the IDRS unit manager
    • IDRS Unit & USR Database
    Automated Substitute for Return (ASFR)
    • IDRS - TC 494
    • AIMS - ST 24
    • AIMS - PBC
    • Campus ASFR - Appeals Liaisons
    AUR IMF
    • IDRS - TC 922 Reason Code 75
    • AUR Coordinators
    AUR Business Master File (BMF)
    • IDRS - TC 925 Case Control Category = BURS
    • AUR Coordinators
    Correspondence Examination
    • AIMS Status
    • PBC
    • EGC
    • CEAS
    • RGS
    • Examination contacts
    Field Examination
    • AIMS Status
    • PBC
    • Employee Group Code (EGC)
    • Report Generation Software (RGS)
    • Examination contacts
    INNSP
    • IDRS - ISTSRA Stage 12
    • ISTS

     

  4. For cases with a follow up date of 20 days or more, research AMDISA, create the appropriate action record to record that the step was completed, and note the AIMS status and status date on ACMS according to the If/Then Table below:

    APS Tax Examiner Actions Based on the AIMS Status

    IF...THEN...
    The AIMS status is 81/82
    • Contact the PTM for the Examination Card-in team and verify receipt of the administrative file.
    • Once verification is received, perfect the ACMS record and validate the case. During validation, select if the case should be placed in Counsel’s jurisdiction.
    The AIMS status indicates that the case is open in Compliance or a Campus
    • Contact the source of the notice and request the administrative file be uploaded to the Appeals Shared Programs Hub.
    • Create Action Records - select Research & Follow-up (35D) and Enter Action Comments with the name of the contact person in the CAR.
    The AIMS status is 90 or Non-AIMS Default Assessment Made
    • Research TXMOD to determine if the case is a paper file or a paperless Campus file.
    • If case is a paper file, order the applicable TC 290 or TC 421 refile DLN.
    • Use the special search to order the DLNs and request the documents be forwarded to the applicable office in Appeals.
    • Create Action Records – select Research & Follow-up (35D) and Enter Action Comments – notate the DLN number that was ordered from Files.
    • For paperless cases, contact AUR, Business Master File (BMF) AUR, Automated Substitute for Return (ASFR), or other business unit for copies of the case file.
    • See IRM 8.20.5.3.1.3, AIMS Controls and AIMS Status, for guidance on use of AIMS CC: AM424A to request AIMS controls.
    • See IRM 8.20.5.5.2.2, Premature Assessments and Command Code AMSTUR.
    The return is closed on AIMS or there is a Default Assessment

    Perform further research using TXMODA/ IMFOLT/BMFOLT:

    • See IRM 8.20.5.3.1.3, AIMS Controls and AIMS Status, for guidance on use of AIMS CC: AM424A to request AIMS controls.
    • See IRM 8.20.5.5.2.2, Premature Assessments and Command Code AMSTUR.


     

     

  5. Any petition filed with the USTC prior to the IRS issuance of an SND (Examination), NOD (Collection), or CDP/EH decision letter is premature and will be “dismissed for lack of jurisdiction” via an order to dismiss. When such a case appears on the docket listing, APS must take additional actions to ensure the ACMS record accurately reflects the true status/condition of this case type. The following factors must be considered:

    • AIMS controls if open, will be open in Examination status because the audit has not been concluded and an SND has not been issued.
    • IDRS History or TC 922 indicates there is an open AUR exam.
    • APS will not be able to locate a copy of the SND because one has not been issued.
    • Petition will not include a copy of the SND but may instead include a pre-SND letter (15-day / 30-day / 60-day) which does not confer Tax Court rights to the taxpayer.
    • Petitioner’s administrative file will be physically in the respective auditor’s/examiner’s inventory, not in Technical Services inventory.
    • ASED jurisdiction remains with Examination, and the ASED is not suspended as a result of a prematurely filed petition.
    • Once the petition is verified as premature, APS follows carding procedures in IRM 8.20.5.5.1.6.1, Premature Petition Carding and Certification Procedure.

     

  6. For any petitioned case with a follow up date of 35 days:

    • Create Action Records – select Research & Follow-up (35D) and Enter Action Comments – Dummy file created, and complete dummy file procedures by updating the “Docketed Pending” record via the “Resume Card-In” button, make corrections, as necessary, and validate the appeal.
    • Review eCITE and compare it with the filing status on IDRS.
    • Create MFT 31 related appeal number(s) for possible NPS cases controlling the statute date on ACMS.
    • Contact the Counsel attorney (via email) and request notification if an NPS assessment is required.

     

  7. APS is responsible for securing administrative files for Appeals.

  8. Within two business days of receipt, the APS office that receives the file will:

    1. If the case is paper, acknowledge receipt of the case via Form 3210.
    2. Verify the information in the case file.
    3. Review the petition and, if appropriate, perfect the account information on:
      • ACMS
      • AIMS
      • IDRS
    4. Transmit the file to Counsel for answer.

     

8.20.5.5.1.4 (08-05-2026)
APS Docketed Case Procedures

  1. APS is responsible for:

    1. Creating skeletal records on ACMS for every docket number on a docket list
    2. Uploading USTC petitions to ACMS as a case file attachment within two business days of receipt of the docket list
    3. Preparing dummy files for answer
    4. Promptly sending files to Counsel by fax or overnight mail
    5. Carding, monitoring, and closing premature petition cases

     

  2. The skeletal record must be established within two business days from receipt of the docket list.

  3. When a case is received by an APS office, the PTM or designee will:

    1. Analyze the information in the administrative file
    2. Update ACMS received date to the actual date received in their office and update AIMS, as appropriate

     

  4. If an administrative file hasn’t been received within 35 days, APS will create a dummy file for answer.
  5. The dummy file consists of copies of all available information obtained from a variety of sources. Most IRS Campus Examination-sourced cases are controlled on the CEAS. In Appeals, designated APS employees have research only permission to access CEAS, RGS, and Account Management System (AMS).

  6. A "dummy" administrative file contains all available information related to the case. The dummy file for answer purposes should contain, at a minimum:

    • CEAS information, if available, or if not, a clearly visible statement that no CEAS is available
    • RTVUE print from IDRS
    • Transcript of account, TXMOD, MFTRA, IMFOL, etc.

    Note:

    If the taxpayer has erroneously filed a petition when no SND was issued by Compliance Examination, see IRM 8.20.5.5.1.6.1, Premature Petition Carding and Certification Procedure, and IRM 8.20.6.17.1, Entered Order to Dismiss for Lack of Jurisdiction.

     

8.20.5.5.1.5 (08-05-2026)
Working Docketed Inventory
  1. Appeals-issued SNDs and NODs are worked as priority.

  2. The following table details timeframes for required APS TE actions:

    TimingTE Actions Required
    1 dayUpon receipt of a docket list, identify Appeals-issued notices, SNDs, and NODs. Email the assigned PTM that a petition is filed. PTMs process TE requests within five days of receipt by pulling the case and updating/forwarding it to Counsel for trial preparation, per IRM 8.20.6, Interim Actions.
    20 days

    Research ACMS to determine if the case is established. If no case is established, take the following actions:

    • For closed CDP/EH cases, or Appeals notices with a statutory notice expiration date more than 90 days prior to the list date (late filed petition), do not request ACMS to be reopened.
    • Using IDRS and the petition, control the case on ACMS with information entered in each field, including MFTs, type codes, source, counsel of record, tax periods, and tax and penalty amounts, if available.

    For Compliance-issued SNDs, perform IDRS research. Review the petition and IDRS to determine who issued the notice and identify any NPS/NPY. Update ACMS, as appropriate.

    • Email Compliance for cases still open on AIMS/IDRS where no default assessment has been made and request the administrative file be immediately sent to Appeals.
    • For cases open on AIMS and not in status 81, input CC AMFRZQ to generate a Q freeze on each period petitioned.
    • Cases defaulted by Compliance:
      - Document the CAR with the date Form 2275, Records Request, Charge and Recharge, was sent to files.
      - Complete Form 2275 to retrieve the case from files. Refer to Special Search Contact Information.
      - If closed/defaulted by Campus or Field as a paperless process, request an electronic copy of the case be submitted to the Appeals ECR SharePoint site. Refer to Blocking Series Chart.


    Update the CAR with clear and concise notes.

    35 days
    • If an administrative file is not received within 35 days, proceed with routing the case to the ATM or to Counsel’s jurisdiction.
    • Cases are moved to Counsel’s jurisdiction during validation. See IRM 8.20.13.4, Validating and Routing the Appeal, for more information.
    • When a case is moved to Counsel’s jurisdiction during validation, the status will be updated to “In Suspense” with suspense reason “Awaiting Counsel Prep of Answer (E/DC).” The ACMS jurisdiction indicator will be set to the orange courthouse icon indicating Counsel’s jurisdiction.
    • An appeal can be moved to Counsel’s jurisdiction manually by creating a SU/PI action record with one of the following suspense reasons:
      - Awaiting Counsel Prep of Answer (E/DC)
      - To District Counsel for Trial Prep
      - Awaiting Decision Entry in Tax Court
      The ACMS jurisdiction indicator will then be set to the orange courthouse icon indicating Counsel’s jurisdiction.

     

8.20.5.5.1.6 (08-05-2026)
Docketed Case Carding (Docketed Pending)

  1. Using eCITE and the documents in the case file, update ACMS by selecting the “Resume Card-In” button, as needed, and complete the validation process.

    • If an “answer” is uploaded to the “Docketed Pending” appeal – Select “No” to move the appeal to Counsel’s jurisdiction.
    • If an “Answer” is not uploaded to Docketed Pending Appeal – Select “Yes” to move the appeal to Counsel’s jurisdiction, and select Suspense Reason – Awaiting Counsel Prep Of Answer (E/DC).

    • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.

      Caution:

      APS should only update AIMS controls to status 82 when the administrative file is received. Updating AIMS to status 82 is the responsibility of the APS employee who processes receipt of the original administrative file. Premature update of status 82 causes APS to stop searching for the original administrative file before it has been received in appeals.

       

     

  2. Upon receipt of the original administrative file, update the AIMS status for the docketed TIN and tax period(s) to 82 using IDRS CC AMSTUA.
8.20.5.5.1.6.1 (08-05-2026)
Premature Petition Carding and Certification Procedure
  1. When a taxpayer files a petition with the USTC, the document is assigned a docket number, and the information entered by the docket room employee will appear on the docket listing. This docket number assignment takes place even when the IRS has not yet issued an SND to the taxpayer.

  2. APS will take the following actions for a docketed case when the petition was filed prior to the SND being issued:

    1. Create an ACMS skeletal record following carding procedures. The table below provides exceptions for specific ACMS fields and these exceptions are only applicable to docketed premature petition cases. See the table below for ACMS field entry exceptions:

      ACMS Skeletal Record for a Premature Petition

      ACMS FieldACMS Field Entry Exceptions
      Notice TypeLeave blank
      Notice DateLeave blank
      Statute DateLeave blank
      Statute CodeEnter EXAM
      Proposed DeficiencyLeave blank
      Proposed PenaltyLeave blank
      CAR
      • Enter the date the ACMS skeletal record is created.
      • Prepare Form 15022, IRS Certification - Income/Gift/Estate Tax Statutory Notice of Deficiency NOT Issued
      • Send docketed notification email to the compliance contact to certify an SND has not been issued.
      • Enter the date the Compliance contact provides the email response confirming the SND has not been issued.


       

       

     

  3. The premature petition ACMS appeal number will remain in APS control throughout the entire time the case is docketed and until it is dismissed for Lack of Jurisdiction. The APS TE will identify the Examination function with current control of the taxpayer’s case using the applicable database(s):

    1. AIMS
    2. AMS
    3. CEAS
    4. IDRS
    5. ISTS
    6. RGS
    7. Other applicable database

     

  4. APS will:

    1. Identify the appropriate Compliance Manager.
    2. Complete Part A and Part B of Form 15022.
    3. Use encrypted email to alert Compliance of the premature petition.
    4. Request the Compliance manager complete Part C and Part D of Form 15022.
    5. Set the premature petition IRC Certification reply by due date.

    The following information must be included within the email:

    Premature Petition Encrypted Email Notification to Compliance

    Email Item:Required Information:
    Subject Line"Reply By: MM-DD-YYYY (10 business days from current date) Request for Certification - Notice of Deficiency/Determination NOT Issued. Docket Number - NNNN-YY"
    Attachment
    • Premature Petition Certification Form (Parts A and B completed by APS)
    Body
    • Please complete Parts C and D of Form 15022 and follow the routing instructions.
    Verify
    • Encryption is activated
    • Click Send
    Update CAR
    • Document your action in the CAR via Create Action Records – Select Action Type: No NOD/SND Issued (NS) – Enter Action Comments, with actions taken to retrieve the Form 15022
    • Establish the follow-up date


     

     

  5. Upon receipt of completed Form 15022, take the following actions:

    1. Create a premature petition confirmation email to send to the Counsel attorney assigned to answer the premature petition (see table below)

    2. Attach the completed and signed Form 15022 to the ACMS record

      Premature Petition Confirmation Email and Attachment for the Counsel Attorney

      Email Item:Required Information:
      Subject Line"Premature Petition Certification Docket Number NNNN-YY"
      Attachment
      • Completed Premature Petition Certification Form
      Body
      • Docket Number: NNNN-YY
      • TXPD: YYYYMM
      • Premature Petition IRS Certification Form attached.
      Verify
      • Encryption is activated
      • Click Send
      Update ACMS
      • Document your actions in the CAR
      • Monitor for order entered action on ACMS
      • Forward signed order to dismiss for lack of jurisdiction to the appropriate Compliance contact
      • Close ACMS with cc 21


       

       

     

8.20.5.5.1.7 (08-05-2026)
Dummy File Creation

  1. The ACMS record is created based on all available information, such as the petition, notice of deficiency (if available), eCITE, IDRS, AIMS, and CFINK information.

    Note:

    ACMS must be researched for all docketed cases to avoid creating a duplicate record. If, however, a duplicate record is found, the appeal number created first should be kept and any later appeal number should be deleted.

     

  2. APS must promptly and accurately identify and act upon NPS, NPY, and potential dismissals on all dummy file cases (e.g., premature petitions). APS must:

    • Compare eCITE data and if the MFT 30 filing status is MFJ, determine if the petition was signed by both taxpayers or only one of the joint taxpayers.
    • Read the petition contents to further determine if the petition creates a PS/NPS condition for one or more tax periods, or if the petition is filed for one or more, but not all of the tax periods listed on the SND (NPY).

    • Follow established procedures in IRM 8.20.5.5.5.1, Non-Petitioning Spouse Case Carding Requirements.

      Reminder:

      After validating the appeal number, notify APS Examination to continue monitoring IDRS until the NPS assessment fully posts.

       

    • Follow established procedures in IRM 8.20.5.5.7, Non-Petitioned Year(s) Case Carding, to create the ACMS record, as appropriate.
    • Notify Counsel when transmitting the dummy file if an assessment has already been made to alert Counsel of the potential need for abatement actions if the petition was filed timely.

    Reminder:

    APS will abate premature assessments when directed to do so by Counsel.

     

  3. On ACMS, select “Resume Card-In” and update the docketed pending record. Select Create Action Record – Research & Follow UP (35D), Enter Action Comments: Dummy File, and Follow up has been completed, and Validate the Appeals to update the CAR.

    Note:

    When the original administrative file is received, the APS TE will enter the date the file is received in the CAR via Create Action Records – Miscellaneous (MS), and Enter Action Comments: Admin File Received.

     

  4. In addition, enter the following ACMS information:

    • Appeal Received Date - date dummy file created
    • Taxpayer Request Date - date petition filed

     

  5. Validate the appeal and:

    • If an answer is uploaded to ACMS, select “No” to move the case to Counsel’s jurisdiction.
    • If an answer is not uploaded to ACMS, select “Yes” to move the case to Counsel’s jurisdiction and enter suspense reason “Awaiting Counsel Prep Of Answer (E/DC).”
    • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.

     

8.20.5.5.2 (08-05-2026)

Docketed Cases Received in Appeals

  1. Upon receipt of a new docketed administrative file, the APS PTM will promptly assign the case for carding.

  2. The assigned APS employee will:

    • Verify the contents of the administrative file to determine whether all documents, returns, etc., listed on the Form 3210 are present in the file.

      Note:

      When the source function is a TS or SB/SE AUR unit, and the file is missing a Control-D generated notice of deficiency, refer to the AUR Control-D Coordinators to obtain a copy of the AUR issued notice of deficiency.

       

    • Sign the acknowledgment copy of the Form 3210, return it to the originator, and place a copy of the Form 3210 in the case file.
    • Take the actions listed below within two business days after receipt of the file in APS (and no later than 40 days after the petition was served, to prevent the unnecessary preparation and processing of "dummy" files):

    Required actions upon receipt of a docketed administrative file:

    1. APS employees must timely validate and update ACMS upon receipt of the administrative file(s).
    2. Use eCITE and the documents in the administrative file to verify the information on the case summary card and make corrections, as necessary. If any critical data elements were corrected, validation must be completed.

    3. Verify and act upon all NPYs and NPS.

      Reminder:

      Whenever necessary, take immediate and appropriate steps to process the assessment and avoid a barred ASED. Upon receipt of the case file from the Campus, examine eCITE and the notice of deficiency to determine whether all of the parties named in, and all the years and quarters (for quarterly filed returns) covered by, the notice of deficiency are included in the petition. If any of the parties or years or quarters shown in the statutory notice are not listed on eCITE, see IRM 8.20.5.5.5, Non-Petitioning Spouse (NPS) Cases, or IRM 8.20.5.5.7, Non-Petitioned Year(s) Case Carding. For additional interim actions and processing procedures, see IRM 8.20.6.9.2, Petitioning/Non-Petitioning Taxpayer, or Non-Petitioned Year(s) in Multiple Year Compliance-Issued SND.

       

    4. If the file is paper and an answer is filed, validate the appeal and ship the file using the “File Shipments” section in the “Documents” tab.

    5. Validate the appeal and:

       

      • If an answer is uploaded to ACMS, select “No” to move the case to Counsel’s jurisdiction.
      • If an answer is not uploaded to ACMS, select “Yes” to move the case to Counsel’s jurisdiction and enter suspense reason “Awaiting Counsel Prep Of Answer (E/DC).”
      • If the file is paper, ship to the appropriate Counsel office for answer, as identified on eCITE.
      • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.

       

       

     

     

8.20.5.5.2.1 (08-05-2026)
Docketed Case Carding - Power of Attorney or Attorney of Record
  1. Whenever the taxpayer has an active POA, APS adheres to the procedures provided in IRM 8.20.5.3, General Carding Rules; however, if the taxpayer’s petition identifies an attorney of record, which is different from the POA information on the taxpayer’s CAF, enter the attorney of record’s name and address information in the POA fields on ACMS. In the "APS Notes" field, enter "Attorney of Record does not match CAF."
  2. When the taxpayer does not have an active POA, but the taxpayer’s petition identifies an attorney of record, always enter the attorney of record information in ACMS. Enter the attorney of record’s information in Appeal Participants with the Counsel of Record role.
8.20.5.5.2.2 (08-05-2026)
Premature Assessments and Command Code AMSTUR

  1. Source functions are required to monitor the electronic docket list (EDL) and timely forward docketed cases to Appeals. Occasionally, a docketed administrative file is not received in Appeals timely. The most common cause is when the taxpayer files a petition within close proximity to the SND expiration date; and during the timeframe between when the petition is added to the EDL and the EDL is researched by the respective source function, the case is defaulted by the source function and shipped to their processing function for assessment. If the SND tax period(s) was assessed as a defaulted SND, and the taxpayer has also filed a petition, additional action is required by both the source function and by APS. 

    The source function must follow their respective IRM guidance to:

    • Re-open AIMS controls using CC: AMSTUR
    • Prepare a dummy file and forward it to the appropriate Appeals office
    • Locate the original administrative file
    • Update the AIMS control to Appeals Status via AIMS CC: AMSTUA
    • Transmit the original administrative file to the appropriate Appeals office


    APS must:

    • Receive the dummy file and forward it to Counsel.
    • If Compliance does not provide a dummy file, then APS creates the dummy file and forwards it to Counsel.
    • Include a Note on the ACMS record to identify that the SND has been defaulted and timeliness of the petition is under review.
    • Alert the PTM and Counsel Attorney, in writing, that the SND was defaulted and also provide a description of the applicable account condition for each respective tax period: 
      ⇒ The assessment has NOT been input for MFT NN and tax period YYYYMM by the source function (this means the ASED is not protected on a late filed petition), or
      ⇒ The assessment has been input for MFT NN and tax period YYYYMM by the source function and is pending, or
      ⇒ The assessment has been input for MFT NN and tax period YYYYMM by the source function and is posted 23C date = MM-DD-YYYY.
    • Request written verification as to if the petition was filed timely or late.
    • If the petition was filed timely, the APS office for the respective Counsel office has the responsibility to abate the premature assessment(s).
    • If the petition was filed late, then the default assessment:
      ⇒ 23C date must be prior to the ASED.
      ⇒ A pending assessment must be monitored until posted.
      ⇒ A posted assessment MUST not be abated because the abatement can jeopardize the IRS’s authority to reassess due to an expired ASED.
    • If an abatement is processed in error, and the ASED is expired for correction of the abatement, immediately notify your PTM. See IRM 25.6.1.10.2, Erroneous Abatement, for additional information.
    • If an abatement is processed in error, and the ASED is NOT expired, take immediate action to reassess the correct tax and penalty using quick assessment procedures (ASED ≤ 60 days) or AMCLSF (ASED > 60 days). Always ensure the corrective assessment will post with a 23C date prior to the ASED, and use the appropriate priority code to avoid the unpostable caused when attempting to post an amount that is within $10.00 of a previously posted amount.

    Caution:

    Coordination between the source function, APS, and Counsel is of critical importance to ensure that if the petition is not timely filed, the default assessment is processed with a 23C date prior to the ASED. If the case is defaulted and released by the SND issuing office, but still in transit or yet to be assigned to a TE within the case processing operation, APS serves as the coordination point between the source function and the Counsel office, to ensure a late filed petition does not result in an expired ASED for a defaulted SND assessment, and a timely petition does not result in a premature SND default assessment and issuance of a billing notice for the taxpayer.

     

  2. After receipt of the written verification and/or approval of the ATE/ATM/Counsel Attorney to authorize the abatement of a premature assessment, the APS TE will refer to IRM 8.20.6.19, Interim Adjustment and Interim Account Update Processing, and IRM 8.20.6.20, Interim Account Adjustments - Assessment or Abatement Prior to Final Determination, for account update and correction procedures.
8.20.5.5.2.3 (08-05-2026)
Original Return Required on Docketed Cases

  1. Although the source function is expected to provide the original return as part of the administrative file, there are instances when a paper original return is neither available, nor able to be secured, prior to the date the administrative file must be submitted to Appeals. If the original return is not readily available, the source function will transmit the administrative file for the docketed case to Appeals with verification they’ve initiated a requisition for the return, and also include a transcript of account, and a copy of the return in the case file. APS will accept docketed administrative files without the original return(s) in order to immediately provide all available information to Counsel for preparing an answer to the petition.

    Note:

    APS will not reject docketed administrative files to the originator when the original return is missing.

     

  2. If the docketed case file does not contain the original return, APS must verify if the return requisition was initiated by the source function. If the source function has not already requisitioned the original return, APS will take the following actions:

    • Use CC: ESTAB to request the original return or use the Employee User Portal (EUP). See IRM 4.21.1.32, Employee User Portal (EUP), for additional information.
    • Follow up on unfilled requests.
    • Document the CAR to record the date the administrative file is received by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: Admin file received.

    Note:

    #1 APS is responsible for verifying the administrative file is complete prior to transmitting the case to Counsel. When the source function did not include a print of an electronically filed tax return in the administrative file, see Contents of the Administrative File, IRM 8.20.5.3.1 (3) for instructions, print the electronic return record, and associate the print in the administrative file.

    Note:

    #2 A docketed Substitute for Return (SFR) case will include the SFR return package prepared by the Compliance examiner, but will not include an original tax return when the taxpayer has not filed a return for the respective tax period. If the taxpayer has also filed a delinquent return with the Compliance examiner prior to the issuance of the SND, the delinquent return must have been processed by Compliance and the RAR used as the basis for the SND must include the tax per return or as previously adjusted amount on Line 12 based on the updated taxpayer account.

    IRM Part 4 References for SFR and Delinquent Return Examination Procedures

    IRM SectionSection Title
    IRM 4.4.9.5.3
    • SFR Posted - Prepare Case for Closing
    IRM 4.4.9.5.3.1.2
    • Forward Case to CCP or Technical Services
    IRM 4.4.9.6
    • Delinquent Return Received After SFR TC 150 Posted at MF
    IRM 4.4.9.6.5.2
    • Additional Adjustments Required/Prepare RAR and Form 5344, Examination Closing Record


     

     

     

8.20.5.5.3 (08-05-2026)

Docketed Case Carding (Compliance-Issued Statutory Notice of Deficiency (SND))

  1. If the SND was issued by Compliance Examination, review the administrative file, acknowledge receipt, and establish the case on ACMS.
  2. Review eCITE to verify that all tax periods and both taxpayers (for an MFJ MFT 30 account), which are included on the SND, are also included in the petition filed with Tax Court. See IRM 8.20.5.5.5, Non-Petitioning Spouse (NPS) Cases, or IRM 8.20.5.5.7, Non-Petitioned Year(s) Case Carding, when a docketed case involves an NPS or an NPY.

  3. When only one spouse (for an MFJ MFT 30 SND) is identified as the petitioner, take immediate action to review the administrative file received from the source function to verify if the NPS case is properly controlled by the originator. When one spouse files a petition, and the other spouse does not, the jurisdiction of the NPS spouse remains with the originating function for continued suspense, awaiting one of the following actions:

    • Notification of a separate petition filed by the NPS
    • Default of the NPS SND
    • Receipt of a signed agreement from the NPS
    • Receipt of new information from the NPS. See IRM 8.20.5.5.3.1, Compliance Function No-Changes the SND, for procedures on recognizing when the Compliance function has “no changed” the SND.

     

  4. Any time only one spouse files a petition to the Tax Court, the source function is required to input a TC 971 Action Code (AC) 103 to establish an MFT 31 account for the NPS prior to updating AIMS to status 81 and transmitting the administrative file to Appeals. Jurisdiction of the NPS SND, including responsibility for control and protection of the NPS ASED, remains with the function that issued the SND.
  5. When APS cannot verify that the originating function has properly retained the NPS dummy file and input TC 971 AC 103 to establish the NPS MFT 31 account, use encrypted email to contact the originating function’s 90-day contact to ascertain the suspense status and ASED control for the NPS SND. Always include both your PTM and the 90-day contact’s manager in the email Cc line. Include "NPS Inquiry Response Due By MM-DD-YYYY) ASED = MM-DD-YYYY" in the email subject line. Determine the response due by date by adding five business days from the date you send the email.
  6. To locate the correct 90-day contact for the applicable PBC, use the AIMS / ERCS contacts site. This will open an Excel spreadsheet with Area and Campus contacts for each PBC. Click on the hyperlink for the applicable PBC and when the spreadsheet opens, locate the name identified as the 90-day contact. This listing is maintained by SB/SE and is updated every seven business days.

  7. To locate the 90-day contact’s manager, use Discovery Directory, or follow the steps below to use Outlook Properties:

    1. Locate the 90-day contact’s name in the Outlook Directory
    2. Right click on the target name
    3. Left click on properties
    4. Left click on the organization tab and the manager’s name will populate in the manager field

    Reminder:

    Upon receipt of the email response from the 90-day contact, convert the email to a PDF and attach the PDF to the ACMS record. Completion of this verification and ACMS attachment process provides an electronic recordation of the verification actions taken by the APS TE.

     

  8. If you identify that the NPS ASED is within 60 days of expiring and you cannot secure written verification (via email) that the originating function is controlling the NPS SND and the NPS ASED, notify your PTM and prepare an MFT 31 quick assessment for the NPS TIN using the tax and penalty amounts included on the SND RAR. This "protective assessment" measure should only be taken when the NPS ASED is within 60 days of expiring.

  9. If the NPS is deceased and has never filed a return as a primary taxpayer, APS must check CC: ENMOD or CC: INOLE to determine if the IRS has an entity established for the deceased NPS.

    1. If an entity is present, the NPS assessment can be processed using MFT 31 procedures.
    2. If an entity is not available for the deceased NPS, additional consideration and action is required (see (10) below).

     

  10. APS has detailed procedures for managing the scenario identified in (9) b) above in IRM 8.20.6.8.10.2, Deceased Spouse on a Married Filing Joint MFT 30 Statutory Notice of Deficiency - New MFT 31 Split Account Process. The APS TE must alert their PTM whenever the Compliance Examination source function has not taken action to initiate the ASED protection and assessment actions required for the deceased NPS remaining under their jurisdiction. The PTM, or their designee, will use encrypted email to confer with the Counsel attorney assigned to the PS case in order to determine if the PS has fiduciary authority to amend or "perfect" the petition by adding the deceased spouse as a second petitioner.

    • If Counsel verifies in writing that the surviving spouse can and will "perfect" the petition, then a Non-Master File (NMF) assessment for the deceased spouse will not be initiated.

    • If Counsel verifies in writing that the surviving spouse either cannot or will not "perfect" the petition, then the PTM will advise the APS TE to use the procedures provided in IRM 8.20.6, Interim Actions, for appropriate action.

      Reminder:

      The communication with the Counsel attorney must be in writing via encrypted email. The APS TE will convert the email response to a PDF and upload it as an attachment to the ACMS record.

       

     

  11. Failure by the originating function to correctly retain control of the NPS SND and to control/protect the NPS ASED under their jurisdiction causes an undue shift of administrative burden onto Appeals. For this reason, your PTM must be aware of all such instances, and the PTM must also elevate the email inquiry to each successive management level, as needed, until a written response is received from the originating function.
  12. If the originating function replies to the email and verifies they are controlling the NPS SND and the NPS ASED, save the email response as a PDF file and attach the email PDF file to the ACMS record for statute protection verification and any future inquiries.
  13. The APS TE who is responsible for monitoring the NPS taxpayer’s account remaining in Compliance’s jurisdiction will input a CAR entry to document the monitoring action(s) for the NPS account.

  14. Modify the procedures provided in this section, as appropriate and necessary, for an NPY.

    Exception:

    MFT 31 procedures do not apply for an NPY (tax period) because the assessment is made to the existing MFT (30, 02, etc.) and tax period; however, the normal ASED protection procedures still apply, based on the ASED for the respective tax period.

     

  15. Enter the notice date in ACMS on all cases in which an SND or a determination letter was issued, including 90-day cases received from Field Compliance or a Campus function. Use the appropriate entry as follows:

    • 090F - Compliance issued notice of deficiency
    • 150F - Compliance issued notice of deficiency to taxpayer residing outside the United States
    • 090C - Campus issued notice of deficiency
    • 150C - Campus issued notice of deficiency to taxpayer residing outside the United States
    • FPAF - TEFRA (Compliance issued Final Partnership Administrative Adjustment (FPAA))

     

  16. Statute policy and procedure is provided in IRM 8.21, Appeals Statute Responsibility.
8.20.5.5.3.1 (08-05-2026)
Compliance Function "No Changes" the Statutory Notice of Deficiency (SND)
  1. After the SND is issued by Compliance, the taxpayer may submit additional information which fully resolves the tax issue in dispute. If Compliance accepts the information, they may "no change" the case before one or both of the taxpayers file a petition with the USTC. Appeals will not be involved in this type of case.

  2. When the Compliance function’s "no change" process takes place after one of the taxpayers on an MFJ account has already filed a petition with the USTC, the appropriate APS Carding or Interim Action IRM sections must be followed to ensure ACMS and AIMS are properly updated and to ensure the Counsel attorney is notified of the "no change" action by Compliance.

    Example:

    IMF AUR issues an SND on an MFJ return. The primary taxpayer files a timely petition but does not pay the filing fee. Tax Court orders the petitioner to pay the filing fee. The secondary taxpayer does not file a petition, but instead provides IMF AUR with additional information which, when reviewed, fully resolves the tax and penalty included on the SND. IMF AUR had created an MFT 31 account for the NPS at the time they submitted the PS case to Appeals, but then posts a "no change" adjustment for the NPS on their MFT 31 account. IMF AUR also prepares a Form 14121, No Change Certification, and forwards it to the Counsel attorney for the primary taxpayer’s petitioned case, and provides a copy to the applicable APS office. APS will not take action to create an MFT 31 account for either taxpayer, but instead will await the Counsel attorney’s resolution of the docketed case. The primary taxpayer withdraws their petition once they’ve received the "no change" letter from AUR, and does not pay the filing fee. Tax Court will dismiss the primary taxpayer’s petition for lack of jurisdiction based upon the request to withdraw, and also for failure to pay the filing fee.

     

  3. When the Compliance function "no changes" an SND after the taxpayer has already filed their petition, the case is a docketed case, despite the subsequent no change determination. The Compliance function must provide Appeals with Form 14121 in accordance with their respective IRM procedures. The table below provides APS with references for the Compliance function’s post-SND issuance "no change" procedures:

    Compliance FunctionIRM Section NumberIRM Section Title
    BMF AURIRM 4.119.1.5.10Docketed Appeals Cases (see (4))
    IMF AUR
    1. IRM 4.19.2.3.14
    2. IRM 4.19.3.22.1.8.1
    1. Docketed Appeals Cases (see (3) instructions for AUR cases closed with Process Code (PC) 92)
    2. Docketed Cases (see (3))
    Correspondence ExaminationIRM 4.19.13.18.1Docketed Cases - No-Change (see (1))
    Field Examination Technical ServicesIRM 4.8.9.25.2.5Information Results in No Deficiency
    Field Examination Technical ServicesIRM 4.8.9.30.1Criteria for Rescinding

    Note:

    When the Compliance function does not provide the completed Form 14121 to Counsel and APS, a written "no change statement" from Compliance can be accepted as the "no change verification" in place of the formal certification Form 14121.

     

  4. For cases originating from SB/SE IMF AUR and Correspondence Examination groups in SB/SE and TS, the originating function will send Form 14121 to Appeals via the ECR SharePoint site, identifying the "Type of Case" as "DKT No-Change F14121" . Upon receipt, Appeals will take the following actions:

    1. Assign the request to a TE.
    2. When validating the case, check the box for Counsel Jurisdiction.
    3. Enter a CAR entry for no change, if not already entered, by selecting Create Action Records, Action Type: No Change (NC), and Enter Action Comments: Form 14121 received and processed to Counsel.
    4. Upload a copy of the Form 14121 to ACMS using naming convention "No-Change Form 14121."
    5. Send a copy of the Form 14121 to Counsel via the Chief Counsel Portal SharePoint site identifying the "Request For" as "To Counsel - No-Change Certificate."
    6. Await Counsel’s response. Counsel will work to prepare and enter a decision with the Tax Court, and change the status to closed. The case will be listed on a decision report list provided to APS. They will then submit the closure request to APS.

    7. APS will close ACMS only and verify no open AIMS controls. No adjustment will be needed.

      Exception:

      If AIMS is still open in Appeals status, it must be closed with TC 300 for $0.00.

       

     

8.20.5.5.4 (08-05-2026)

Docketed Case Not Received Timely in Appeals

  1. If a case appears on the docket list, but has not been received in Appeals within 35 days after the date the petition is served on the IRS, APS will follow procedures in IRM 8.20.5.5.1.7, Dummy File Creation.
8.20.5.5.4.1 (08-05-2026)
Administrative File Received After Dummy File Created

  1. When the original paper administrative file is received after a dummy file for answer was created and carded on ACMS, APS must perform research to determine the location of the dummy file, so that the original administrative file can be associated.

    • If the dummy file is currently assigned to an ATE, the APS TE will prepare a Form 3210 and send the original administrative file to the ATE to associate it with the dummy file.
    • If the dummy file is currently in Counsel, the APS TE will prepare a Form 3210 and send the original administrative file to Counsel, to associate it with the dummy file. If the dummy file location is unclear on eCITE, the APS TE will call Counsel to verify the dummy file location.
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “Original administrative file sent for association with the dummy file”.

     

  2. When the original administrative file is received as paperless after a dummy file for answer was created and carded on ACMS, APS must upload the paperless file to ACMS by going to the "Documents" field and select "Upload File(s)."

    • If the dummy file is currently assigned to an ATE, the APS TE will notify the ATE of the paperless file uploaded to ACMS.
    • If the dummy file location is in Counsel’s jurisdiction on ACMS, the APS TE will notify Counsel of the paperless file uploaded to ACMS.
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “Original administrative file received, notified ATE,” or “Original administrative file received, notified Counsel attorney.”

     

8.20.5.5.5 (08-05-2026)

Non-Petitioning Spouse (NPS) Cases

  1. When an SND is issued on an MFT 30 MFJ account, the primary taxpayer and secondary taxpayer are treated individually for the purpose of legally signing a waiver of agreement, legally petitioning the USTC, or taking no action prior to the SND default date.
  2. When an SND is issued to both a husband and wife who filed a joint return, and only one spouse petitions the USTC while the other spouse either agrees to the proposed deficiency or does not also file a petition to the USTC, the case is considered an NPS case.
  3. The APS TE will verify the address of both taxpayers on all NPS cases. Use IDRS command code SPARQ to determine if the last known address of both taxpayers is the same as the address on the notice of deficiency.

  4. If separate residences were established and it is not clear from the administrative file that both taxpayers received the notice of deficiency, APS will:

    1. Immediately card the case on ACMS following the procedures shown below to control the statute date for the taxpayer who may not have received the notice of deficiency.
    2. Enter "Spouse at different address" in the CAR.
    3. Immediately alert the PTM to request verification via communication with Counsel.

    4. The PTM may need to immediately transmit the case to Counsel to determine the appropriate action to take on the case.

      Note:

      An SND mailed to an address other than the last known address is NOT valid. An invalid SND cannot result in a legal default assessment and a default assessment of an invalid SND cannot be used to substantiate an account adjustment. Counsel may request that APS process a "protective assessment" while they conclude whether or not the SND was in fact mailed to a proper address. Until the validity of the SND can be determined by Counsel, the ASED for the taxpayer(s) is the normal or extended statute associated with the account pre-SND issuance.

       

    5. If Counsel concludes the SND is invalid and the normal or extended assessment statute is still open, a new notice of deficiency must be issued at the direction of Counsel or the ATM. Refer the case to the appropriate ATM. The Lead ATM will determine whether to return the case to Compliance or if Appeals will issue a new SND.
    6. If the assessment statute is not open, follow established procedures from IRM 8.21.7, Barred Statute Procedures, for preparing Form 3999, Statute Expiration Report. The Compliance function which incorrectly issued the SND is the office responsible for the barred statute and the person preparing the Form 3999 must clearly identify the appropriate Compliance function to facilitate correct routing of the Form 3999.

     

  5. If the Counsel Attorney or the ATM requested that APS make a "protective assessment" based upon the SND, as described in d) note above, the Counsel attorney or ATM will provide APS with written instructions to finalize the account based upon the determination made in e) or f) above. APS will attach the written instructions from Counsel or the ATM to the ACMS record to provide justification for the account actions taken.
8.20.5.5.5.1 (08-05-2026)
Non-Petitioning Spouse Case Carding Requirements

  1. An NPS case requires special ACMS procedures to create an appeal that includes a key case (the joint return) and two related cases, one for each spouse.

    • Joint return (key case)
    • PS (related case record)
    • NPS (related case record)

     

  2. Link the related appeals by using the ACMS relationship functionality. For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

8.20.5.5.5.1.1 (08-05-2026)
Non-Petitioning Spouse Joint Return Key Case Carding

  1. Since the docketed team creates a skeletal card from the docket list, the petitioner's card will already be on ACMS. This case should be updated to become the joint "key" case. Send the administrative file to the appropriate Counsel office for answer, as identified in eCITE. Follow carding procedures in IRM 8.20.13 , Establishing Appeals Cases on ACMS, and:

    1. Taxpayer Name - Change to joint name line information
    2. Feature Code - Enter NS, if available, to identify an NPS case
    3. Taxpayer Request Date - After the docket number is entered, this field is systemically populated with the petition served date. If the date does not automatically appear, manually enter the petition served date in this field.
    4. Docket Number - Enter the docket number as it appears on the petition or docket list
    5. Statute Date - Leave blank
    6. Statute Code - Enter DOCKT
    7. Proposed Deficiency and Proposed Penalty - Enter the tax deficiency and penalty(s) amounts shown on the notice of deficiency

     

8.20.5.5.5.1.2 (08-05-2026)
Petitioning Spouse Case Carding

  1. Establish a separate record for the PS. Follow ACMS carding procedures in IRM 8.20.13, Establishing Appeals Cases on ACMS, and:

    1. Taxpayer Name - Enter the name of the PS
    2. Address - Enter the address of the PS
    3. TIN - Enter the PS TIN
    4. MFT - Enter MFT 31
    5. Taxpayer Request Date - Enter the date the petition was filed by the PS
    6. Docket Number - Enter docket number as it appears on the petition
    7. Notice Type - Enter the statutory notice type
    8. Notice Date - Enter the statutory notice date
    9. APS Notes - Enter "Petitioning Spouse"

     

  2. On the return level information screen, follow the normal procedures and:

    1. Statute Date - Leave blank
    2. Statute Code - Enter DOCKT
    3. Proposed Deficiency and Proposed Penalty - Leave these fields blank

     

8.20.5.5.5.1.3 (08-05-2026)
Non-Petitioning Spouse Case Carding

  1. Establish a separate case for the NPS. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter:

    1. Taxpayer Name - Enter the name of the NPS
    2. Address - Enter the address of the NPS
    3. TIN - Enter the TIN of the NPS
    4. MFT - Enter MFT 31
    5. Feature Code - Enter NS to identify an NPS case
    6. Taxpayer Request Date - Leave blank
    7. Docket Number - Enter the docket number of the PS as it appears on the petition or docket list
    8. Notice Type - Enter the statutory notice type
    9. Notice Date - Enter the statutory notice date
    10. APS Notes - Enter "Non-Petitioning Spouse"


     

    Reminder:

    Always verify that the originating function is controlling the NPS SND and NPS ASED. See IRM 8.20.5.5.3, Docketed Case Carding (Compliance-Issued Statutory Notice of Deficiency (SND)), (2) - (9) for guidance on contacting the originating function to verify their continued suspense of the NPS SND and ASED. See IRM 8.20.6.9.2, Petitioning/Non-Petitioning Taxpayer, or Non-Petitioned Year(s) in Multiple Year Compliance-Issued SND, for additional guidance.

     

  2. On the return level information screen enter:

    1. Statute Date - Enter the normal or extended assessment statute date
    2. Statute Code - Leave blank
    3. Proposed Deficiency and Proposed Penalty - Leave these fields blank

     

  3. Validate and link the related appeals, and follow the steps below:

    • If an answer is uploaded to ACMS, select “No” to move the case to Counsel’s jurisdiction.

      Note:

      If the file is paper, ship the file by using the “File Shipment” functionality located in the Documents section of the appeal. See IRM 8.20.13.6.8, Documents, and IRM 8.20.13.6.9, File Shipments, for more information.

       

    • If an answer is not uploaded to ACMS, select “Yes” to move the case to Counsel’s jurisdiction and enter suspense reason “Awaiting Counsel Prep Of Answer (E/DC).”

      Note:

      If the file is paper, ship the file to the appropriate Counsel office for answer, as identified on eCITE.

       

    • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “Original Administrative File processed as NPS on all three records.”

     

  4. See IRM 8.20.6.9.2, Petitioning/Non-Petitioning Taxpayer, or Non-Petitioned Year(s) in Multiple Year Compliance-Issued SND, for additional information.
8.20.5.5.6 (08-05-2026)

Joint Return - Separate Petitions

  1. When an SND is issued to both the primary and secondary taxpayer who filed a joint return, and each files a separate petition with the USTC, each docket number is established on ACMS as a separate appeal number. Follow the procedures in the subsections below to card the docketed cases on ACMS.
8.20.5.5.6.1 (08-05-2026)
Joint Return Separate Petitions - Carding the Primary Taxpayer Identification Number (TIN)

  1. Establish an appeal number for the primary TIN of a joint return. The APS TE will follow ACMS carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter the following:

    1. Taxpayer Name - Enter the name of the taxpayer with the primary TIN on the joint return
    2. Address - Enter the address of the taxpayer with the primary TIN on the joint return
    3. TIN - Enter the primary TIN of the joint return
    4. MFT - Enter MFT 31
    5. Taxpayer Request Date - Enter the date the primary taxpayer filed the petition
    6. Docket Number - Enter the primary taxpayer’s docket number as it appears on the petition or docket list
    7. APS Notes - Enter "Joint Return Separate Petitions - Related docket number (enter the docket number of the other spouse)"

     

  2. On the return level information screen enter:

    1. Statute Date - Leave blank
    2. Statute Code - Enter DOCKT
    3. Proposed Deficiency and Proposed Penalty - Enter the tax deficiency and penalty(s) for each year as shown on the SND

     

  3. The APS TE will send the administrative file to the Counsel office identified in eCITE.
8.20.5.5.6.2 (08-05-2026)
Joint Return Separate Petitions - Carding the Secondary TIN

  1. Establish a separate appeal number for the secondary TIN of a joint return. This is a related case record. Follow ACMS procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter:

    1. Taxpayer Name - Enter the name of the taxpayer with the secondary TIN on the joint return.
    2. Address - Enter the address of the taxpayer with the secondary TIN on the joint return
    3. TIN - Enter the secondary TIN of the joint return
    4. MFT - Enter MFT 31
    5. Taxpayer Request Date - Enter the date of the petition of the secondary taxpayer
    6. Docket Number - Enter the secondary taxpayer’s docket number as it appears on the petition or docket list
    7. APS Notes - Enter "Joint Return Separate Petitions - Related docket number (enter the docket number of the other spouse)"

     

  2. On the return level information screen, enter:

    1. Statute Date - Leave blank
    2. Statute Code - Enter DOCKT
    3. Proposed Deficiency and Proposed Penalty - Enter the tax deficiency and penalty(s) for each year as shown on the SND

     

  3. Validate and link the related appeals, and follow the steps below:

    • If an answer is uploaded to ACMS, select “No” to move the case to Counsel’s jurisdiction.

      Note:

      If the file is paper, ship the file by using the “File Shipment” functionality located in the Documents section of the appeal. See IRM 8.20.13.6.8, Documents, and IRM 8.20.13.6.9, File Shipments, for more information.

       

    • If an answer is not uploaded to ACMS, select “Yes” to move the case to Counsel’s jurisdiction and enter suspense reason “Awaiting Counsel Prep Of Answer (E/DC).”

      Note:

      If the file is paper, ship the file to the appropriate Counsel office for answer, as identified on eCITE.

       

    • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “Original Administrative File processed as Joint Return Separate Petitions.”

     

8.20.5.5.6.3 (08-05-2026)
Joint Petition Separate Returns Case Carding
  1. A married taxpayer may file a joint petition with their spouse even though their SND was issued based upon a MFS filing status.
  2. If one or both spouses filed a MFS return, see IRM 8.20.5.4.1.3.1, Multiple Filer Form 1040 Cases, for carding guidance.

  3. If neither spouse filed a MFS income tax return, compliance may have:

    • Posted an SFR TC 150 to the MFT 30 MFS account for one or both spouses, and
    • Established AIMS controls for one or both spouses

     

  4. Because the married taxpayers filed a joint petition, there will be only one docket number for the petitioners.

  5. Establish the docketed case on ACMS following normal docketed procedures using the primary taxpayer SSN. For the purposes of this case type, the first taxpayer listed on the joint petition is the primary taxpayer and the other is the secondary taxpayer unless only one of the spouses was issued an SND.

    • If both spouses were issued an SND, enter both names in the taxpayer name field, the spouse who is listed first on the petition is the primary taxpayer.
    • If only one spouse was issued an SND, enter only that name in the taxpayer name field. The other spouse’s name will be entered in the APS Notes field.

     

  6. Always enter the secondary taxpayer SSN in the TIN2 field.

  7. Additional ACMS entries:

    • MFT - 30
    • Taxpayer Request Date - Enter the date the joint petition was filed
    • Docket Number - Enter the docket number as it appears on the petition or docket list
    • Notice Type - Enter type of SND issued
    • Notice Date - Enter date SND was issued
    • APS Notes - Enter "Joint Petition Separate Return(s)" (if only one taxpayer has an SFR account there is no need to enter the (s)). Also enter the secondary taxpayer’s name when an SND was not issued for the secondary taxpayer’s SSN.

     

  8. On the return level information screen, follow the normal procedures and:

    • Statute Date - Leave blank
    • Statute Code - Enter DOCKT
    • Proposed Deficiency and Proposed Penalty - Enter the proposed deficiency/proposed penalty, rounded to whole dollars, for each tax period included on the petition

     

  9. Validate and link the related appeals, and follow the steps below:

    • If an answer is uploaded to ACMS, select “No” to move the case to Counsel’s jurisdiction.

      Note:

      If the file is paper, ship the file by using the “File Shipment” functionality located in the Documents section of the appeal. See IRM 8.20.13.6.8, Documents, and IRM 8.20.13.6.9, File Shipments, for more information.

       

    • If an answer is not uploaded to ACMS, select “Yes” to move the case to Counsel’s jurisdiction and enter suspense reason “Awaiting Counsel Prep Of Answer (E/DC).”

      Note:

      If the file is paper, ship the file to the appropriate Counsel office for answer, as identified on eCITE.

       

    • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “Original Administrative File processed as Joint Petition Separate Returns.”

     

8.20.5.5.7 (08-05-2026)

Non-Petitioned Year(s) Case Carding

  1. When Compliance issues an SND for multiple tax periods and one or more of the tax periods are omitted from the petition, only the tax periods included on the petition are considered petitioned and the tax period(s) omitted are considered NPYs. The function which issued the SND retains jurisdiction for the NPY(s) and separates the petitioned year(s) administrative file(s) from the NPY administrative file(s) in order to timely transmit the petitioned years to Appeals for carding and submission to Counsel for preparation of an answer to the petition.

  2. APS cards the petitioned case with all tax periods originally included on the SND, (this includes both the petitioned and the NPYs). APS will identify the NPY(s) and email Counsel to determine if they want the NPY associated with the docketed case once it is closed by Compliance or not. APS serves as the liaison between the Compliance function and the Counsel attorney to establish if the NPY should be re-charged to the Counsel attorney for association with the docketed case, once it has been closed by Compliance, or if the NPY can be sent to Campus files by Compliance. The NPY(s) will have the following information entered in the ACMS return level to differentiate it from the petitioned tax periods until Counsel identifies if they do or do not also want the NPY(s) once they are closed by Compliance:

    ACMS FieldEntry
    Feature CodeNY
    AIMSY (AIMS control remains in Compliance status)
    Tax PeriodYYYYMM
    Statute DateASED per AIMS
    Statute CodeEXAM (This will change based upon next action)

    Reminder:

    The disposition of the NPY(s) will be changed by the following taxpayer actions:

    Taxpayer ActionChange to NPY
    Taxpayer perfects the petition to include the NPY(s)
    • NPY becomes a petitioned year
    • Remove Feature Code NY
    • APS notifies Compliance function
    • Administrative file is submitted to APS via Form 5344, Examination Closing Record, disposal code 11 for association with the petitioned case
    • APS updates the ACMS record to correct the return level entries for the newly petitioned tax period to match the other petitioned years
    Taxpayer submits an agreement to the Compliance function for the NPY
    • NPY is assessed by Compliance function
    • If the Counsel attorney wants the agreed tax period to be associated with the petitioned tax periods, then follow steps in the (4) table below. APS must update the return level AIMS code to "N" , statute date to blank, and Statute Code to ASESD once the Compliance assessment action(s) are posted.
    • If the Counsel attorney does not want the agreed tax period to be associated with the petitioned tax periods, then Compliance will close their case and APS will delete the NPY from the ACMS record.
    Taxpayer defaults on the NPY
    • NPY is assessed by Compliance function
    • If the Counsel attorney wants the defaulted tax period to be associated with the petitioned tax periods, then follow steps in the (4) table below. APS must update the return level AIMS code to "N" , statute date to blank, and Statute Code to ASESD once the Compliance assessment action(s) are posted.
    • If the Counsel attorney does not want the defaulted tax period to be associated with the petitioned tax periods, then Compliance will close their case and APS will delete the NPY from the ACMS record.

     

     

  3. Upon conclusion of the NPY suspense, the initiating function must process the defaulted or agreed adjustment(s) and associate the assessment verification with the NPY administrative file.

    Note:

    In the same way as with all other types of docketed Compliance SND cases, APS serves as the Appeals control point monitor between the Compliance function and the Counsel attorney for the purpose of identifying if the NPY, remaining in Compliance’s jurisdiction, will be re-charged to the Counsel attorney, or will be sent to Campus files function after Compliance completes their closing action(s). APS involvement in this process will ensure that the ACMS and AIMS databases accurately reflect the proper case controls and status while the petitioned tax periods are in Counsel’s or Appeals’ jurisdiction.

     

  4. APS will follow the process provided below based upon Counsel’s decision to associate or to not associate the NPY with the docketed years:

    Counsel’s Response to APS Inquiry:APS Actions:
    Counsel needs the NPY for association with the docketed case

    APS prepares encrypted email to alert the Compliance function to "re-charge" the NPY(s) to Counsel at closing. 
    Encrypted email information:

    • To: Compliance contact and their manager
    • Cc: APS TE and their PTM

    • Email Subject Line: "Re-charge request for Non-Petitioned Year(s) when closed"

      Body of the email:

       

    • TIN, Name Control, MFT and Tax Period of the NPY(s)
    • "Please "re-charge" tax period(s) YYYYMM to the Counsel Attorney identified below upon completion of your closing action(s)."
    • "Provide the Re-Charge" information in one of the three ways described below within the body of the email by:
      ✓ Typing information required for Form 2275, Records Request, Charge and Recharge, items 11 and 12, or
      ✓ Pasting a screen shot of the Outlook Properties for the Counsel Attorney, or
      ✓ Pasting a screen shot of the Discovery Directory page for the Counsel Attorney
    • Save the completed email as a PDF and upload it as an attachment to the ACMS record
    • Send the request for the NPY(s) to be re-charged and associated with the docketed case to the Compliance function via encrypted email
    • Enter a brief CAR to describe the actions taken
      ▸ Place the case in suspense for monitoring until the Compliance adjustment posts
    • Update the ACMS return level Statute Date and Statute Code, as appropriate, once the Compliance adjustment posts
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “Original Administrative File processed” and briefly describe NPY actions taken
    Counsel does NOT need the NPY(s) for association with the docketed case
    • Convert the email from Counsel to a PDF and upload it as an attachment to the ACMS record
    • Delete return level entries for NPY(s)

     

8.20.5.5.8 (08-05-2026)

Carding Paperless Docketed Cases

  1. APS will follow procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, for carding cases, but will access the documentation from the ECR link on the Appeals Shared Programs Hub instead of looking through a physical case file for the necessary information. The APS PTM will access the ECR SharePoint site and assign the case to an APS TE on the ECR site. The tables below provide specific guidance based on whether the case is going to an ATM for assignment or to Counsel when the administrative file is requested.

    • For docketed cases to ATM for assignment:
    StepAPS Action - for docketed cases (to ATM for assignment)
    1.The TE will perfect the ACMS record by making sure all fields contain accurate information (including codes, statutes, etc.).
    2.If there are case-related documents attached to ECR, the TE will attach them on ACMS.
    3.

    The TE will validate the appeal and:

    • Select “No” to move the appeal to Counsel’s jurisdiction
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “PL case has been processed.”

    .

    • For docketed cases when answer is not attached to ACMS:
    StepAPS Action: For docketed cases - when answer is not attached to ACMS
    1.Upon receipt of a case, the TE will identify in the CAR if Counsel has requested the administrative file for answer or delayed/no consideration by Appeals.
    2.The TE will perfect the ACMS record by making sure all fields contain accurate information (including type codes, statutes, etc.).
    3.

    The TE will validate the appeal and:

    • Select “Yes” to move the appeal to Counsel’s jurisdiction with suspense reason “Awaiting Counsel Prep Of Answer (E/DC).”
    • Update the CAR by selecting Create Action Records, Action Type: Miscellaneous (MS), and Enter Action Comments: “PL case has been processed.”
    • Verify the appeal’s status has changed to “In Suspense” and the jurisdiction indicator has changed to the orange courthouse icon to indicate Counsel’s jurisdiction.

     

8.20.5.6 (08-05-2026)

Abatement of Interest (ABINT) Case Carding

  1. Abatement of interest claims are carded as a separate appeal number, even if received with another type of case (i.e., income tax).

  2. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter:

    • Record Type: Exam Appeal / SEPR
    • MFT Code: Enter the applicable MFT code
    • Category: Enter the applicable category. ACMS auto-populates some categories and subcategories based on the MFT code input, but this field can be manually edited, as applicable.
    • Subcategory: Abatement of Interest
    • Date of Claim
    • Earliest 105/106C Letter Issued Date (if known)

    • Tax Period level information screen:

      ACMS Return FieldEntry Information
      Tax PeriodEnter the tax period for which the claim is filed
      Amount ClaimedAmount of the claim shown on Form 843, Claim for Refund and Request for Abatement
      Amount Disallowed (Compliance)Amount of the claim disallowed by Compliance
      Amount Allowed (Compliance)Amount of the claim allowed by Compliance
      Statute DateLeave blank
      Statute CodeABINT

       

     

  3. Generally, these cases come to Appeals in "proposed disallowance status" so the assessment statute is not an issue. However, the "interest abatement case" could arrive in Appeals after a statutory disallowance letter has been mailed to disallow the claim for abatement. The following situations might occur, which impact the "statute expiration date" entered on ACMS for the case:

    1. If the formal disallowance letter was issued, the 180-day period (for petitioning the Tax Court) is running and Appeals may not have time to work the case.
    2. Reconsideration of disallowed interest claims in respect to IRC 6404(e)(1) - received with less than 120 days remaining on the 180-day period - Acceptance of this type case is subject to the approval of the Appeals Area Director. If Appeals accepts the case for reconsideration (during the 180-day period), the ATE informs the taxpayer that the period for filing suit is not extended and that no additional final determination letter will be issued.

     

8.20.5.7 (08-05-2026)

Administrative and Litigation Cost Case Carding

  1. IRC 7430 provides for the recovery of reasonable administrative costs and litigation costs. The procedures for recovering administrative costs require that a written request be filed with the IRS personnel that considered the underlying substantive claim. When these cases are received in Appeals, it is important to remember the following:

    1. An award of litigation costs, attorney fees, or court costs may be appropriate for docketed cases tried by the Tax Court or settled whether in Appeals or by Counsel. These cases require approval by Counsel and will be forwarded to them for action. These cases will not be carded on ACMS.
    2. An award of administrative costs (including attorney fees) may also be appropriate for non-docketed cases. Appeals has sole jurisdiction in deciding these cases and they will be carded on ACMS. (See Note below.)
    3. Any decision on administrative costs may be appealed to the Tax Court by the taxpayer, or their authorized representative.

    Note:

    If a petition is filed, they become litigation costs, and jurisdiction is then transferred to Counsel.

     

  2. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter:

    • Record Type: Exam Appeal / SEPR
    • MFT Code: Enter the MFT code of the initial case
    • Category: Enter the applicable category. ACMS auto-populates some categories and subcategories based on the MFT code input, but this field can be manually edited, as applicable.
    • Subcategory: Claim
    • Tax Period - Enter the tax period involved in the original case
    • Statute Date - Enter the assessment statute date, if it has not expired; if the statute has expired, leave blank.
    • Statute Code - Enter CLAIM
    • Amount Claimed - Enter the total claim amount

     

8.20.5.8 (08-05-2026)

Audit Reconsideration Case Carding

  1. An audit reconsideration case is the reevaluation of the results of a prior audit when a taxpayer disagrees with the original determination by providing information that was not previously considered during the original examination. Or, it is the process the IRS uses when the taxpayer contests an ASFR or SFR determination by filing an original delinquent return, and the assessment remains unpaid or, as a result of the assessment, the tax credit is reversed.

  2. There are two types of audit reconsideration cases:

    1. Type 1 is a case that has already been closed by Appeals.
    2. Type 2 is a case that has not been to Appeals (e.g., a reconsideration of a Campus claim, an underreporter, examination or correspondence examination case, a non-filer, ASFR, or SFR case).

     

  3. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS.

    Note:

    If the case has Employee Retention Credits (ERC), add feature code RC.

    • Statute Date: Leave blank
    • Statute Code: Enter ASESD
    • Amount Appealed: Enter the amount appealed
    • If on AIMS when received, update to the applicable AIMS status and notate ACMS, as appropriate.

     

8.20.5.9 (07-01-2017)

Introduction to Appeals Consideration of Claim and Overassessment Cases

  1. Appeals considers claim and overassessment cases on any taxes or other matters that the IRS considers. Exceptions to this general authority are provided in IRM 1.2.2.9.8, Delegation Order 8-8 (Rev. 1) (formerly DO-66, Rev. 15), Authority of Appeals in Protested and Tax Court Cases.

  2. Claims can be:

    1. Part of a case file received by Appeals, or
    2. Filed by the taxpayer during Appeals’ consideration.

     

  3. An overassessment case becomes an overpayment case when there is a refund indicated.
  4. An Appeals overassessment case is not a claim for refund. Instead it is an overassessment determined by the SB/SE Area Director or the Director, Field Operations.
  5. Claims for abatement that are filed with reasons acceptable to an SB/SE Area Director, the Director, Field Operations, SB/SE or TS Campus Director, or the Compliance Area Director, SB/SE, Compliance Area 15 - are considered by Appeals on their merits, if protested.
  6. Field-sourced claim cases are routed to Appeals based on the taxpayer’s address. Campus-sourced claims are routed to Appeals based on the business unit that issued the Letter 105-C, Claim Disallowed, or 106-C, Claim Partially Disallowed. Campus claims are assigned to the Appeals location identified on the Campus Examination case routing instructions provided on the Appeals Case Routing From External Sources site.
8.20.5.9.1 (07-01-2017)

Receipt of Claim Cases, Overassessment Cases, or Net Rate Netting Claims/Requests

  1. APS will determine if the items listed on the Form 3210 were received and then sign the acknowledgment copy of the Form 3210, and return it to the originator by mail or fax. APS will retain a copy of the Form 3210 in the case file.
  2. Taxpayers can file a claim on Form 843, Form 1040-X, Amended U.S. Individual Income Tax Return, Form 1120-X, Amended U.S. Corporation Income Tax Return, or Form 941-X, Adjusted Employer's Quarterly Federal Tax Return or Claim for Refund. Correspondence from the taxpayer may constitute an informal claim; however, this determination is made by the ATE.
8.20.5.9.1.1 (08-05-2026)
Claim Case Carding

  1. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, except for the following ACMS fields:

    • Statute Date - Enter the assessment statute date, if it has not expired; if the statute has expired, leave blank.
    • Statute Code - Enter CLAIM
    • Amount Claimed - Enter the total claim amount

    • Amount Disallowed (Compliance) - Enter the amount that was disallowed on AMDISA page 2, or the Letter 105-C or Letter 106-C, if the claim is received from a Campus. Campus-sourced claims are not controlled on AIMS, so page 2 of an AMDISA will not be available.

      Reminder:

      If the front page of the Letter 105-C/106-C is missing, enter the following comment in the APS Notes field: "Unable to determine claim amount."

       

    • Amount Allowed (Compliance) - Enter the amount allowed by Compliance
    • Feature Code - Enter RC for ERC claims, or TC for timeliness claims
    • Earliest 105/106C Letter Issued Date - Enter the earliest date of issuance for Letter 105-C and/or Letter 106-C

     

  2. Letter 105-C/106-C claims involving ERC should arrive from Compliance after merits of the claim have been considered. Claims that arrive from TS Accounts Management (AM) should be rejected back to the originating function.

    Exception:

    Claim cases that fall under the purview of Section 70605(d) of the One Big Beautiful Bill Act will arrive from TS AM and should not be rejected back to the originating function. Section 70605(d) prevents the IRS from allowing or refunding ERCs after July 4, 2025, for the third and fourth quarters of 2021, if those claims were filed after January 31, 2024. Those cases will be identified as either (i) AM ERC Claim Timeliness, merits considered, or (ii) AM ERC Claim Timeliness, merits not considered. These cases should be carded in like any other case and assigned to an ATE for a timeliness determination.

     

8.20.5.9.1.2 (08-05-2026)
Net Rate Netting (NRN) Claim/Request Case Carding

  1. All taxpayer requests for Net Rate Netting (NRN) under IRC 6621(d) and/or Rev. Proc. 2000-26 must be in writing and include all pertinent information in compliance with Rev. Proc. 2000-26 guidelines. Taxpayers can use either of the two methods provided below for preparing their NRN claim:

    1. Form 843
    2. If a return is pending with the IRS or a court, a written request or letter in which the taxpayer furnishes all of the information required per Rev. Proc. 2000-26

     

  2. APS can further identify an NRN claim by additional information noted in the document provided (e.g. "Request for Net Rate Netting under Rev. Proc. 2000-26," or "Net Rate Netting Claim IRC 6621(d)" ).

  3. Appeals can receive IRC 6621(d) NRN claims/requests in several ways:

    1. Associated with a docketed or non-docketed tax case from Compliance (see carding guidance in IRM 8.20.5.9.1.2 (4) below);
    2. Submitted to Appeals as a full disallowance Letter 105C or a partial disallowance Letter 106C from Ogden Campus (see carding guidance in IRM 8.20.5.9.1.2 (5) below);
    3. Submitted by the taxpayer or taxpayer representative directly to the ATE working the tax case in dispute (see carding guidance in IRM 8.20.5.9.1.2 (6) below); or
    4. Forwarded from the Ogden Campus AM Complex Interest Unit (CIU) for processing with an open Appeals case that will be closed by the ATE within 30 days (see carding guidance in IRM 8.20.5.9.1.2 (7) below).

     

  4. APS will card an NRN request that is received with a docketed or non-docketed case as a related appeal number following claim carding procedures along with the following items:

    • APS Notes - Enter related case appeal number and "Net Rate Netting"
    • Enter return level information for the earliest tax period identified on the NRN claim/request
    • Statute Date - Blank
    • Statute Code - N/A

     

  5. APS will card an NRN claim/request submitted to Appeals as a partially or fully disallowed claim following claim carding procedures along with the following items:

    • APS Notes - Enter "Net Rate Netting"
    • Statute Date - Blank
    • Statute Code - N/A

     

  6. APS will card an NRN request submitted by the taxpayer or taxpayer representative directly to the ATE working the tax case in dispute per the ATE’s written direction to ensure the NRN claim/request is identified as part of the ATE’s ACMS inventory.

  7. When the Ogden Campus AM CIU receives an NRN claim/request which includes a tax period(s) with an unresolved tax liability case open in Appeals, the AM CIU will research AIMS to determine if any of the tax periods included in the NRN claim/request are open in AIMS status "80," "81," or "82." Once the AIMS controls are identified as open in Appeals, the Ogden CIU will contact Appeals following procedures described in IRM 8.7.19.2.1, Accepting a Net Rate Netting Request for IRS Ogden Campus. The following procedures identify the steps for the Ogden CIU to contact Appeals for potential transfer of the NRN claim/request:

    1. Ogden CIU sends an encrypted email to APS CIT with the subject line "Open AIMS Netting Case"

    2. The encrypted email will include the taxpayer’s name, TIN, MFT(s), and all tax periods included in the NRN claim/request

      Caution:

      NRN claims/requests can include more than one TIN, so all TINs and taxpayer names must be included within the email.

       

    3. The encrypted email will also specify which tax period(s) is/are "Open" on AIMS
    4. APS CIT lead assigned to monitor the "*AP Complex Interest" mailbox will contact the ATE who is assigned the "Open" AIMS case to determine if the case will be closed within 30 calendar days.
    5. If the case will not be closed within 30 calendar days, then APS CIT will respond to the Ogden CIU via encrypted email that Appeals will not accept the NRN claim/request.
    6. If the case will be closed within 30 calendar days, then APS CIT will follow the procedures in IRM 8.20.5.9.1.2 (8) and IRM 8.20.5.9.1.2 (9) below.

     

  8. If the Appeals CIT lead determines the NRN claim/request will be accepted, the following information will be provided in response to the Ogden CIU via secure email:

    1. Acknowledgement that Appeals will accept the NRN claim/request
    2. Notification to send the NRN claim/request to the APS CIT lead
    3. The APS CIT lead’s name and complete address

     

  9. After advising the Ogden CIU that Appeals will accept the NRN claim/request, the APS CIT lead will assign the case to the applicable CIT queue.
8.20.5.9.1.3 (08-05-2026)
Deficiency / Over-Assessment Case Carding

  1. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, except for the following ACMS fields:

    • Statute Date - Enter the assessment statute date, if it has not expired; if the statute has expired, leave blank.
    • Statute Code - See IRM 8.21.2-1, ACMS Statute Codes, for the applicable statute code
    • Proposed Deficiency - Enter the proposed deficiency per tax period
    • Proposed Penalty - Enter the proposed penalty per tax period

     

8.20.5.10 (08-05-2026)

Delegation Order (DO) 4-25 Case Carding

  1. IRM 1.2.2.5.21, Delegation Order 4-25 (Rev. 2), [Supplements Delegation Order No. 97] Settlement Offers, Closing Agreements, and Settlement Agreements under Section 6224(c) in Cases with Technical Advisor (TA) Program Issues and Appeals Technical Guidance Program (Compliance Coordinated and Appeals Coordinated) Issues, provides settlement authority to Examination, following approved Appeals settlement guidelines with the concurrence of Appeals Technical Guidance (TG).
  2. These cases will be received electronically from the TG Coordinator by the local PTM. AIMS controls will remain in Compliance’s status.
  3. These cases are high priority and APS should card them on ACMS ideally within one to two business days following receipt of Delegation Order 4-25.

  4. The case will be carded following general procedures and enter the following:

    • Taxpayer Request Date - As shown on Section I of the Form
    • Appeal Received Date - As shown on Section IV of the Form
    • Feature Code - D5
    • Statute Date - Leave blank
    • PBC - Check AMDISA (Page 1)
    • Statute Code - Enter EXAM
    • Proposed Tax - Leave blank initially; the TG Coordinator will provide at closing

     

8.20.5.11 (08-05-2026)

Early Referral Issue Case Carding

  1. Compliance submits Early Referral (ER) issues to Appeals through ECR and attaches a completed ECR Checksheet.

  2. The APS TE will follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and will enter these fields:

    • Taxpayer Request Date - Date ER request accepted by Compliance
    • Appeal Received Date - Date ER package was received in Appeals
    • Statute Date - Statute date shown on the AMDISA
    • Statute Code - EXAM
    • PBC - PBC shown on the AMDISA
    • Proposed Tax - The ATM will provide the proposed deficiency dollar amount
    • Alternative Dispute Resolution field - select Early Referral

     

8.20.5.12 (08-05-2026)

Earned Income Tax Credit (EITC) Recertification Program Case Carding

  1. Under IRC 32(k), Restrictions On Taxpayers Who Improperly Claimed Credit In Prior Year, taxpayers may be denied the EITC, in part or in full, for a one-year, two-year, or 10-year period, depending on the Examination or Campus determination. When the EITC is denied, the examiner determines if there is reckless, intentional, or fraudulent disregard of the earned income credit rules and regulations, and places an EITC recertification indicator on the National Account Profile (NAP) part of MF. Additional information can be obtained from Form 8862, Information To Claim Earned Income Credit After Disallowance, and the Instructions for Form 8862.

  2. EITC recertification dispute issues can be:

    • EITC and other related credits, such as:
      ▸ Child and Dependent Care Credit
      ▸ Adoption Credit, and
      ▸ Education Credit
    • Dependent exemption(s)
    • Filing status
    • Accuracy-related and/or other penalties
    • Recertification requirement of one, two, or 10 years

     

  3. EITC recertification cases are on AIMS when received by Appeals.

  4. Secure current IDRS command codes ENMOD or IMFOLE to determine if an EITC recertification indicator is present. The recertification indicators are:

    1. 0 (or blank) = Recertification is not required
    2. 1 = EITC is denied for one year after the disallowed year
    3. 2 = EITC is denied for two years after the disallowed year
    4. 4 = EITC is denied for 10 years after the disallowed year
    5. 8 = Reserved

     

  5. When EITC recertification indicator 1, 2, or 4 is present, establish the case following normal procedures, and input feature code EI.
8.20.5.13 (08-05-2026)

e-file Cases

  1. Appeals receives all cases from the Director, Electronic Products & Services Support (EPSS), in Andover, via the Appeals ECR intake site.

    Note:

    Cases originating from SB/SE Field may continue to use the procedure for sending a case to Fresno Appeals for card in. See IRM 8.20.5.13 (5) below.

     

  2. The e-file sanction appeal case file received through the ECR site will contain the information needed to identify and card the case on ACMS. The file may include:

    • All correspondence
    • Protest
    • Related EIN(s) and tax year(s)
    • Copy of e-file application screen from the Third Party Data Store (TPDS)
    • History sheet
    • Suitability recommendation
    • First appeal suitability recommendation worksheet and appeal rights suitability recommendation worksheet (if applicable)
    • POA (if applicable)
    • Compliance memoranda (if applicable)
    • Copies of tax returns secured by Andover e-Help (if applicable)
    • For SB/SE Compliance cases only, copies of SB/SE visitation worksheets and rebuttals (if applicable)

    Note:

    IDRS prints are no longer necessary or required to be included in the appeal case file.

     

  3. Upon receipt of the electronic file, new receipts are assigned to an APS TE to card on ACMS. See IRM 8.20.5.13.1, e-file Case Carding, below for carding guidance.
  4. After carding the e-file case, the APS TE will attach the electronic file received from EPSS to the ACMS record with a description such as EPSS case file.

  5. e-file cases originating from the field will be worked at:

    IRS Independent Office of Appeals

    Attn: APS Carding Team

    3211 S. Northpointe Drive

    Mail Stop 55205

    Fresno, CA 93725

     

  6. For SB/SE Compliance cases only, copies of the SB/SE visitation worksheets and rebuttals.
8.20.5.13.1 (08-05-2026)

e-file Case Carding

  1. Upon receipt of the case in Appeals, APS will card the case by reviewing the e-file application information for the name, address, and electronic filing identification number (EFIN) or Incident Management (IM) number(s).

    Note:

    The EFIN and IM numbers will always be 00 followed by a six-digit number.

    ACMS Field NameDescription
    Taxpayer NameThe taxpayer name of the EFIN applicant
    Taxpayer AddressThe taxpayer address of the EFIN applicant
    RepresentativeThe representative of the EFIN applicant
    Appeal NumberNote: For each EFIN the taxpayer has, there will be a separate appeal number created
    Source
    • Field
    • Campus cases received from EPSS
    Business FunctionEnter the applicable business function
    CategoryOther
    SubcategoryDirector of Practice (E-FILE)
    Taxpayer Request DateThe date the EFIN applicant requested an appeal
    Appeal Received DateThe date the case was received in Appeals

    Note:

    No return level information is entered (e.g., tax period, statute code).

     

  2. If the IM number is used, input the literal "IM number" in the APS Notes field.
8.20.5.14 (08-05-2026)

Employee Tax Compliance (ETC) Case Carding

  1. All Employee Tax Compliance (ETC) cases are routed from the originating Compliance function to the APS team in Holtsville at the address below using Form 3210 and identifying it as an employee audit on Form 3198, Special Handling Notice for Examination Case Processing.

    IRS Independent Office of Appeals

    Attn: APS Carding Team

    1040 Waverly Ave Stop 915

    Holtsville, NY 11742

  2. Upon receipt of the case, APS will:

    • Acknowledge receipt of the case by returning a signed Form 3210 to Compliance
    • Card the case on ACMS
    • Assign the case based on the pre-approved ETC assignment list

    • Send an encrypted message to the ATM, the ATE, and designated Policy senior program analyst notifying them of the case assignment

      Note:

      These cases may not be assigned to ATEs that are not on the pre-approved list without prior clearance, due to their sensitive nature.

       

    • Send the case file directly to the ATE assigned to work the case

     

  3. The Policy ETC senior program analyst updates ACMS using the A1 feature code.
8.20.5.15 (08-05-2026)

Employment Tax Case Carding

  1. When an employment tax case is received, follow the general procedures to acknowledge receipt of the case and verify the contents of the file.
  2. Use the general carding procedures for establishing controls on ACMS and updating AIMS.
  3. Use the AIMS record, tax computation, and other relevant information to identify protested periods.

  4. When carding the case:

    • Category - Employment Tax
    • Subcategory - Select the applicable field
    • MFTs include the following:
      Form CT-1, Employer's Annual Railroad Retirement Tax Return - MFT 09
      Form 940, Employer's Annual Federal Unemployment (FUTA) Tax Return - MFT 10
      Form 941, Employer's QUARTERLY Federal Tax Return - MFT 01
      Form 943, Employer's Annual Tax Return for Agricultural Employees - MFT 11
      Form 944, Employer's ANNUAL Federal Tax Return - MFT 14
      Form 945, Annual Return of Withheld Federal Income Tax - MFT 16
    • Statute date (IRM 8.7.16.3.1, Verifying the Statutory Period of Limitations)
      Forms 941, 943, 944, and 945 - three years from April 15th of the following year for which the return is due or date return received, whichever is later.
      Form 940 - three years from due date of return or date received, whichever is later.
      Statute can be extended by Form SS-10, Consent to Extend the Time to Assess Employment Taxes.
    • Statute Code - Refer to IRM 8.21.2-1, ACMS Statute Codes, for the applicable statute code
    • Input required fields based on the subcategory selected (e.g., Proposed Deficiency, Proposed Penalty)

     

  5. Once the case is established, send it to the ATM.
8.20.5.16 (08-05-2026)

Estate Tax Case Carding

  1. Estate tax cases are received from the Compliance function with AIMS established. The tax period is controlled on AIMS as 000000.
  2. APS will follow the general carding procedures and transmit the case to the ATM.

  3. Enter the unique modifier added to TIN - V for estate tax cases. Select the category "Estate Tax" and enter the applicable subcategory. Also enter:

    • MFT - 52
    • Date of Death
    • Tax Period - Enter the year and month of death (e.g., 202501 for January 2025)
    • Statute Date - Shown on the AMDISA print, which is three years from the due date of the return or three years from the IRS received date, whichever is later. See IRM 8.21, Appeals Statute Responsibility, or Document 6209 for additional information regarding statutes.
    • Statute Code - Refer to IRM 8.21.2-1, ACMS Statute Codes, for statute codes

    Note:

    It is extremely important to verify the statute to ensure there is sufficient time for Appeals to take action. There must be 270 days remaining on the assessment statute upon receipt of estate tax cases in Appeals.

     

8.20.5.17 (08-05-2026)

Estate Tax IRC 6161 and IRC 6166 Case Carding

  1. Taxpayers who are denied the extension of time for paying estate tax provided under IRC 6161 or IRC 6166 can appeal the denial. These cases are not controlled on AIMS.

  2. These cases come to Appeals from Technical Services Advisory. Enter the unique modifier added to TIN - V for estate tax cases. Select the category Estate Tax and enter the applicable subcategory. Also enter:

    1. MFT Code - 52
    2. Date of Death
    3. Statute Code - Enter ASESD

     

8.20.5.18 (08-05-2026)

Excise Tax Case Carding

  1. APS follows the general carding in procedures for excise tax cases. Enter category Excise for excise tax cases.
  2. APS may also receive excise tax claim cases that will show MFT 40 on the Form 3210. APS will follow the general carding procedures for these cases and will select MFT 40 from the drop-down menu.
  3. Form 8849, Claim for Refund of Excise Taxes, is carded as MFT 40.
  4. Other MFT codes associated with excise tax cases include MFT 03, 40, 43, 60, 63, 64, and 66.
8.20.5.18.1 (07-01-2017)

Excise Case Routing and Assignment from SB/SE to the Appeals Officer Cadre

  1. Excise cases originating from SB/SE Excise (PBC 214) are routed and assigned to a trained cadre of AOs. The cadre members responsible for working excise tax cases for the specific areas are shown on the Appeals Case Routing site. The cases will be routed from SB/SE Excise to Appeals and assigned as follows:

    StepAction
    1.SB/SE Excise prepares Form 3198 and Form 3210 for the protested case and sends it to Appeals through SB/SE Technical Services
    2.SB/SE Technical Services sends case to the APS office based on the taxpayer's address
    3.APS cards the case
    4.APS delivers case to ATM for assignment to excise cadre member

    Note:

    A misrouted case from SB/SE Excise (PBC 214) must be carded by the receiving APS office before it is sent to another APS office for assignment by the ATM.

     

8.20.5.19 (08-05-2026)

Fast Track Settlement (FTS) Case Carding

  1. Compliance submits Fast Track Settlement (FTS) requests to Appeals through ECR and attaches a copy of the FTS Package to the ECR submission. The FTS Package includes Form 14017, Application for Fast Track Settlement, and related documents. APS will use information from Form 14017 to card in the FTS request.
  2. FTS cases are carded as a priority case instead of incorporating them into current receipts for carding. APS will attempt to card in FTS requests within two business days of receiving the ECR submission.

  3. APS will follow the general carding procedures for these cases along with the specific procedures for the following fields:

    • Record Type – Enter Exam Appeal/SEPR
    • Category – Enter the issue type listed on Form 14017
    • Subcategory – If not specified in Issue Type from Form 14017, use Deficiency/Overassessment
    • Alternative Dispute Resolution Field – Select "Fast Track Settlement"
    • Taxpayer Request Date – Enter the date Form 14017 is signed by the taxpayer or LB&I Territory Manager, whichever is later
    • Appeal Received Date – Enter the date the FTS package was received in Appeals
    • Source – Generally, Field. However, for LB&I cases, check AMDISA for Aging Reason Code (ARC) 04. If present, Source is Campus. For Campus cases, check AMDISA for AIMS status 15 with ARC 23. If these codes are present, enter “15-23” in the “APS Notes” field on ACMS.
    • PBC – Found on Form 14017. For requests submitted by LB&I, check AMDISA for the correct PBC.
    • Activity Code – Enter Activity code shown on Form 14017, if any
    • Penalty Reference Number (PRN) – Enter PRN shown on Form 14017, if any

     

  4. Add the following return level information:

    • Tax Period – Found on Form 14017
    • Statute Date – Leave blank
    • Statute Code – Select "EXAM"
    • Amounts – Leave all dollar amounts blank during carding

     

8.20.5.20 (08-05-2026)

Foreign Bank Account Report (FBAR) Penalty Case Carding

  1. All Foreign Bank Account Report (FBAR) penalty cases are carded on ACMS with category Reports of Foreign Bank and Financial Accounts and subcategory of either FBAR Post-Assessed or FBAR Pre-Assessed.

  2. The taxpayer name is the U.S. person subject to the FBAR penalty and could include:

    • an individual citizen or resident of the United States
    • a domestic partnership
    • a domestic corporation
    • a domestic estate or trust
    • a person in, and doing business in, the United States (except for a foreign subsidiary of a U.S. person)

     

  3. FBAR penalty cases are carded on ACMS with:

    • MFT - 00
    • Feature Code - AI, IC

    • Statute Date or Statute Code are input as follows, depending on whether the case is pre-assessment or post-assessment:

      If FBAR Penalty is:Then enter the Statute DateStatute Code
      Not assessedEnter a date six years from the date of the violation, either the due date of the FBAR report or date on which records requestedLeave blank
      Assessed with more than 30 days before the expiration of the two-year Civil Action Expiry Date (CASED)Enter a date two years from the date of assessmentLeave blank

       

    • Amount Appealed - Enter the total amount appealed per period

     

  4. Forward the case to the ATM for assignment to an ATE.
8.20.5.21 (08-05-2026)

Generation-Skipping Transfer Tax Case Carding

  1. APS will follow the general carding procedures. These cases are carded with either category “Generation-Skipping Transfer Tax Terminations” for MFT 77 or “Generation-Skipping Transfer Tax Distributions” for MFT 78.
  2. The available subcategories are “Deficiency / Over-Assessment” and “Penalty Abatement Request (PENAP).”
8.20.5.22 (08-05-2026)

Freedom of Information Act (FOIA) Administrative Appeal Case Carding

  1. FOIA cases are carded with category Other and subcategory Freedom of Information Act (FOIA) Appeal. The table below provides ACMS carding guidance for FOIA cases:

    ACMS FieldFOIA Case Entry
    Taxpayer NameRequestor Name
    AddressAddress
    TIN/TIN2

    If a TIN is not supplied, enter 999-99-9999 for individuals or 99-9999999 for business returns to correspond with the MFT entered during carding

    • 999-99-9999 for IMF
    • 99-9999999 for BMF
    MFT
    • Form 1040 - 30
    • Form 1120 - 02
    SourceCampus
    Business FunctionEPSS
    FOIA NumberEnter the FOIA number provided in case; start the FOIA number with F
    PBC193
    Taxpayer Request DateDate of appeal request
    Appeal Received DateDate stamped by APS when the request for appeal was received

    Note:

    No return level information is entered (e.g., tax period, statute code).

     

  2. Forward the case to the FOIA ATM for assignment.

    Note:

    The turnaround timeframe for the case file to be sent from APS to the ATM will be within 48 hours or two business days.

     

8.20.5.23 (08-05-2026)

Gift Tax Case Carding

  1. APS will follow the general carding procedures for gift tax cases and will enter:

    • Category - Gift Tax
    • Statute Date - Shown on the AMDISA print, which is three years from the due date of the return or three years from the IRS received date, whichever is later. See IRM 8.21.2, Account and Processing Support (APS) Statute Responsibility, for additional information regarding statute dates.

     

8.20.5.24 (07-01-2017)

Innocent Spouse Case Overview

  1. This section covers the processes and procedures for handling appeals of determinations made in response to requests for relief from joint and several liability pursuant to IRC 6015"INNSP" appeals. Appeals makes a determination on these requests for relief when appropriate.
  2. Joint and Several Liability: Married taxpayers may elect to file joint returns with their spouse. See IRC 6013(a). Under IRC 6013(d)(3), each spouse filing a joint return is jointly and severally liable for the tax; that is, each spouse is responsible for the entire income tax liability even though all or part of the liability arises from income earned by or a deduction attributable to the other spouse.
  3. An election to file a joint return may only be revoked before the due date of the return, including extensions. However, an executor or administrator may revoke a joint return election made by a surviving spouse within one year of the due date of the surviving spouse’s return, including extensions (time for filing such return).

  4. IRC 6015 provides relief in certain circumstances from the joint and several liability imposed by IRC 6013(d)(3). ATEs make the final determination under the following provisions:

    • IRC 6015(b) - Innocent Spouse Relief - provides an election for relief from a deficiency/understatement of tax liability.
    • IRC 6015(c) - Separation of Liability - provides an election to allocate a deficiency/understatement.
    • IRC 6015(f) - Equitable Relief - provides IRS with discretion to grant equitable relief from deficiencies and underpayments if the relief provisions under 6015(b) or 6015(c) do not apply.

     

  5. IRC 6015 is effective for:

    • Unpaid balances as of July 22, 1998; and
    • Liabilities arising after July 22, 1998.

     

  6. Under IRC 66(c), married taxpayers filing separate returns in community property states may request relief from the operation of state community property laws. This is also considered INNSP relief.
8.20.5.24.1 (07-01-2017)

Common Terms Applicable to Innocent Spouse Cases

  1. The following commonly used terms apply to INNSP cases:

    1. Requesting spouse (RS) - The person who files the request for INNSP relief (Form 8857, Request for Innocent Spouse Relief), or otherwise properly raises the issue of INNSP relief. Sometimes this person is also referred to as the "electing spouse."

    2. Non-requesting spouse (NRS) - The current or former spouse of the person who files the request for INNSP relief. Sometimes this person is also referred to as the "non-electing spouse."

      Note:

      Both spouses may request INNSP relief for the same tax period. Therefore, you could have two cases where one spouse is the RS on his/her claim and the NRS on their spouse’s claim.

       

    3. Appellant spouse - The taxpayer who requested Appeals’ consideration. This can be the RS, the NRS, or both.

     

8.20.5.24.2 (07-01-2017)

Types of Innocent Spouse Cases

  1. There are many different types of cases that can result in an appealed INNSP case. INNSP cases are non-docketed or docketed, and post-assessment or pre-assessment. Appeals considers an INNSP issue as part of an appeal of any of the following types of cases (not all-inclusive):

    • Non-docketed denial of an INNSP request (post-assessment)
    • Non-docketed open examination (pre-assessment proposed deficiency case)
    • Docketed denial of an INNSP request (post-assessment)
    • Docketed proposed deficiency case with request for INNSP relief raised in the petition (pre-assessment)
    • INNSP request in connection with a CDP case (typically post-assessment)

     

  2. Married or formerly married taxpayers who file joint (or separate returns while married in community property states) may be relieved of income tax liability under certain conditions.
  3. If the RS is relieved of the income tax liability under IRC 6015, related penalties, additions to tax, additional amounts, and interest are relieved.
  4. If relief is denied, in whole or in part, to the RS, he/she may appeal the preliminary determination. The NRS may not appeal a decision to deny relief to the RS.
  5. If relief is granted, in whole or in part, to the RS, the NRS may appeal the preliminary determination to the extent relief is granted to the RS.
  6. Both spouses might appeal a partial-relief preliminary determination.
8.20.5.24.3 (07-01-2017)

Innocent Spouse Disclosure Guidance

  1. Do not disclose the following information:

    • The other spouse's new last name, location, or telephone number
    • Any information about the other spouse's employment, income, or assets

     

  2. Do not disclose the RS’s personal information to the NRS. Similarly, do not disclose the NRS’s personal information to the RS.
  3. Information with respect to the joint return account, such as the balance due, can be disclosed to either spouse. See IRM 11.3.2.4.1, Individuals, for additional information regarding disclosure of collection activities with respect to joint returns.
  4. Request for information concerning divorced or separated spouses beyond that provided in IRC 6103(e)(8) should be referred to the Disclosure Office. See IRM 25.15.1.9.2, Authorized Disclosure Rules, for additional information regarding disclosure rules.
8.20.5.24.4 (01-30-2026)

Innocent Spouse References

  1. Appeals employees are responsible for researching and using information contained in all reference materials.
  2. ATEs follow the IRC and Regulations, Rev. Proc. 2003-19, 2003-1 C.B. 371, Rev. Proc. 2013-34, and IRM 8.7.12, Appeals Innocent Spouse Case Procedures.
  3. Additional resources regarding INNSP Appeals cases are posted on the Appeals Innocent Spouse page.
8.20.5.24.5 (08-05-2026)

Innocent Spouse Case Carding

  1. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter the following:

    • Category - Individual
    • Subcategory - Innocent Spouse
    • Taxpayer Request Date - Enter the date of the request for appeal. Usually, for non-docketed cases, the date of the protest is used, if the request is written. 
      ▸ For docketed cases, use the date the petition is filed
      ▸ See IRM 8.20.13, Taxpayer Request Date, for additional information on the rules regarding the appropriate date to use for this field
    • Statute Date/Statute Code - See Exhibit 8.20.5-1, Innocent Spouse - ACMS Statute Date/Statute Code Tables
    • Feature Code - Enter SD for Spousal Defense (INNSP) 
      ▸ Enter any other applicable feature code
    • Docket Number - If docketed, enter the docket number as it appears on the petition or docket list
    • Participants - Identify the RS and NRS by editing the appeal participants. For each spouse, select either "Requesting" or "Non-Requesting" under the "Requesting Spouse" section.

     

  2. If both spouses file a request for relief, even if the same tax year(s), control each case with a separate appeal number on ACMS. The ISTS also keeps separate records according to the primary/secondary (P/S) indicator.

  3. Link the related appeals by using the ACMS relationship functionality. For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

  4. Refer to Exhibit 8.20.5-1, Innocent Spouse - ACMS Statute Date/Statute Code Tables, for additional information on ACMS statute dates and statute codes. Exhibit 8.20.5-1 table titles are provided in order of appearance below:

    • Non-Docketed Pre-Assessment
    • Non-Docketed Post-Assessment
    • Docketed Pre-Assessment
    • RS Petitions, NRS is an NPS
    • RS Petitions NOD - Assessment Posted
    • MFS Returns ACMS Statute Date/Statute Code Entries (For Married Taxpayers Who Filed Separate Returns in Community Property States (IRC 66(c))

     

8.20.5.24.5.1 (08-05-2026)
IS/AUR Case Carding
  1. Source functions route non-docketed AUR/INNSP cases to Florence APS and docketed INNSP cases to the Appeals office indicated on the docket list.
  2. Most INNSP cases are routed to Florence APS for carding. Florence APS usually receives the CCISO INNSP case first, due to the close proximity of the Florence Appeals office to CCISO.

  3. APS will card the case following the INNSP procedures provided in IRM 8.20.5.24.5, Innocent Spouse Case Carding. Because it is typical to receive the CCISO file first, pending receipt of the AUR file, APS will:

    1. Enter in APS Notes, "Awaiting AUR information/response."
    2. Print a copy of the E-5402 (Printable View) and place in a follow-up folder that is manually maintained by each APS TE.
    3. Forward the administrative file to the ATM for assignment.
    4. The APS TE will set a follow-up date equal to 10 calendar days from the received date. If the AUR file is not received by the follow-up date, contact AUR to determine the reason for the delay and initiate appropriate action to resolve the problem.
    5. When the AUR file is received, the APS TE will card in the AUR case following general carding procedures, and send it to ATE who was assigned the case and update ACMS that information was received.
    6. If the case is docketed, immediately after carding, the APS TE will forward the CCISO file to Counsel for answer. Upon receipt of the AUR file, update ACMS, if needed, and associate the AUR file with the CCISO file. The case might be in Counsel’s jurisdiction or Appeals’ jurisdiction, depending upon when the AUR file is received.

    Caution:

    A TC 130 will not post if there is no balance due at the time TC 971 AC 065 post. The APS TE will manually input a TC 130 using the IAT Tool for IDRS Command Code REQ77/FRM77.

     

8.20.5.24.6 (08-05-2026)

Innocent Spouse Reconsideration Case Carding

  1. APS will follow INNSP carding procedures in IRM 8.20.5.24.5 on a reconsideration case.
  2. In addition to carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, APS will enter RECON in APS Notes.
  3. Do not input TC 971 AC 065.
8.20.5.24.7 (07-01-2017)

IDRS/ISTS Controls

  1. The APS office initially receiving the Form 8857 is responsible for inputting the following TCs. Normally these codes are already input on INNSP cases received in Appeals. Upon receipt of an INNSP case, the APS TE will verify if these TCs were input, and if not, take steps to input them.

    • TC 971 with AC 065 - this TC identifies a processable INNSP claim. The input of TC 971 AC 065 stops all potential collection action and generates an MF "L-" Freeze Code that prohibits offsets and prevents notices from being issued except for CP 521, Monthly Reminder on Installment Agreements, and CP 71, Annual Reminder Notice of Balance Due.

      Note:

      The TC 971 with AC 065 requires the following: The taxpayer’s TIN who filed for relief (RS). A cross-reference entry is not required (leave blank) if the primary taxpayer is the RS. If the secondary taxpayer is the RS, enter the TIN of the secondary spouse and the date the Form 8857 or equivalent was filed with IRS. See IRM 25.15.2.4.2, Innocent Spouse Indicator Transaction Code (TC) 971/972, for additional information regarding TC 971 AC 065.

       

    • TC 130 - Verify that this TC is on ENMOD for the NRS. It prevents an erroneous refund by freezing the entire account. The system automatically generates this TC when the proper TC 971 AC 065 and cross-reference is input on any MFT 30 account. If both spouses request relief, a TC 131 should be input to reverse the automatic TC 130(s). See IRM 25.15.2.4.3, TC 130 Entire Account Frozen From Refunding, for additional information regarding TC 130 and TC 131.

    Caution:

    A TC 130 will not post if there is no balance due at the time TC 971 AC 065 posts. Therefore, if there is no balance due, you will have to manually input a TC 130.

     

  2. ISTS - This is a mandatory, nationwide, cross-functional system developed to track and monitor the various stages of an INNSP case. The system is used to provide claim status information and statistical information. Appeals is responsible for updating the system. See IRM 25.15.14, Innocent Spouse Tracking System, which describes the procedures for updating ISTS.
8.20.5.25 (08-05-2026)

Jeopardy Assessment Case Carding

  1. Use this subsection only for administrative reviews of jeopardy assessments. For jeopardy or termination assessment cases that are not accepted by Appeals unless an SND has been issued and the taxpayer has petitioned the USTC, see IRM 8.20.5.3.1.2, Cases Not Accepted by Appeals.

  2. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter the following:

    • Category - Other
    • Subcategory - Administrative Review of Jeopardy Assessments

     

8.20.5.26 (08-05-2026)

Offer in Compromise (OIC) DATL Case Carding

  1. This section provides instructions for APS TEs to establish new Doubt as to Liability (DATL) OIC receipts. These procedures apply to the following case types:

    • Exam originated DATL
    • Non-Exam originated DATL

     

  2. When APS receives systemic email notification that Specialty Collection Offers in Compromise (SCOIC) or Field Examination uploaded a paperless OIC case to Appeals via the Appeals Electronic Case Receipts (ECR) SharePoint intake site, APS will:

    1. Access ECR via the APS Shared Programs Hub.
    2. Card the case to ACMS and create an appeal number using the information in the electronic attachments.
    3. Attach the electronic documents received from the originating function to ACMS.

     

  3. Follow procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and:

    1. Subcategory - Enter "OIC DATL (Non-CDP)"
    2. Taxpayer Request Date - Enter the date of the postmark of the taxpayer's request for appeal. If the envelope is not in the file, use the date the protest letter was received by the IRS.
    3. Appeal Received Date - Use the date that the case was received in Appeals
    4. Offer Number - Enter the offer number
    5. Offer Amount - Leave blank
    6. Proposed Offer Amount - Enter the amount of offer as shown on the latest Form 656-L signed by the taxpayer in the case file. If the original offer has been amended, use the amended offer amount for the Proposed Offer Amount. This information can also be found on the Form 1271, Rejection Memorandum.
    7. Feature Code - See IRM 8.20.5.26.1, ACMS OIC Feature Codes
    8. PBC / Business Function - Determined by the business unit supplying the case to Appeals

     

  4. On the return information screen, enter the following:

    1. Tax Periods - Enter all tax periods associated with the case
    2. Statute Date - Leave blank
    3. Statute Code - Enter SUSP
    4. Source - Use "Field" for an offer worked by a:
      - Field Collection OIC unit
      - Field Examination unit that works DATL cases (including Specialty Exam)
      Use "Campus" for an offer worked by a:
      - Centralized Offer in Compromise (COIC) unit
      - Brookhaven DATL unit

     

  5. In cases where an individual owes income tax under the SSN and employment tax as a sole proprietor under an EIN, the OIC will be carded in as two appeal numbers with the same offer number. Use the Appeals Related to / Appeals Related From functionality to enter the applicable relationship, ensuring the SSN case is the “Primary Appeal” and the EIN case is the “Secondary Appeal.” For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

  6. If the tax periods are open on AIMS in status 81, update to status 80 upon receipt in Appeals when carding in.
8.20.5.26.1 (08-05-2026)

ACMS DATL OIC Feature Codes

  1. To more accurately identify OIC cases, the following ACMS feature codes should be used when applicable:

    • DO - OIC default
    • ET - Effective tax administration
    • LI - DATL
    • SP - OIC with special circumstances
    • T1 - Economic hardship - TAS (see note and example below)
    • T5 - Systemic hardship - TAS (see note and example below)

    Note:

    APS is responsible for entering the appropriate feature code(s) when carding the case and the ATE is responsible for verifying the ACMS feature code(s) are correct during their initial review of the case. If an Operations Assistance Request (OAR) is received during the appeal process, the applicable TAS feature code must be added to the ACMS record. If the file contains an OAR issued to another business unit, the TAS feature codes should not be used. See the example below for guidance on determining the appropriate TAS feature code.

    Example:

    Feature code "T1" is used when Form 12412 is addressed to Appeals, and Item 4 of Section 1 contains number 1 through 4. Feature code "T5" is used when Form 12412, Operations Assistance Request (OAR), is addressed to Appeals, and Item 4 of Section 1 contains number 5 through 7.

     

8.20.5.26.2 (08-05-2026)

Previously Accepted OIC (Potential Default) Cases Returned to Appeals

  1. The APS TE will establish the case on ACMS as a new receipt.

    1. Card the case in as an OIC case. Locate the original OIC case on ACMS and use this card as a template to establish the new card for the defaulted offer.
    2. Identify the case as a potential default case by using feature code DO.
    3. Include all MFT, periods, and original dollar amounts that were associated with the original OIC appeal number.
    4. Use original OIC card as a template with the following exceptions:
      Taxpayer Request Date - Enter the date the Form 2209, Courtesy Investigation, was prepared by Monitoring Offers in Compromise (MOIC)
      Appeal Received Date - Enter the date APS received the Form 2209 from MOIC
    5. Statute Date - Enter the Collection Statute Expiration Date (CSED) reflected on TXMODA
    6. Statute Code - Enter CSED on all periods
    7. Offer Number - Enter the original offer number
    8. APS Notes - "Potential Default."
    9. Once the case is added to ACMS, assign it to the ATM with responsibility for working feature code "DO" cases
    10. The ATM is responsible for assigning the case and providing the Form 2209 and any attachments to the ATE who accepted the offer, or their successor

     

8.20.5.27 (08-05-2026)

Penalty Case Receipts

  1. Appeals penalty case receipts include a wide variety of penalty categories, penalty types, and assessment statute control conditions.

    • Pre-Assessment appeal Civil Penalty Form 8278, Assessment and Abatement of Miscellaneous Civil Penalties
    • Pre-Assessment appeal Return Preparer Penalty IRC 6694(a) and IRC 6695, ASED must have at least 365 days remaining
    • Post-Assessment Civil Penalty assessed on MFT 13 or MFT 55 (PENAP)
    • Post-Assessment Return Related Penalty (PENAP)

     

  2. Pre-assessed penalty cases may have an open ASED and are either:

    1. Associated with an unagreed non-docketed income tax case, or
    2. submitted as a standalone appeal of the penalty assertion.

     

  3. Certain penalties have "pre-assessment" appeal rights (this list is not all-inclusive):

    • "Stand-alone" penalties not subject to deficiency procedures
    • IRC 6694(a), Understatement of taxpayer’s liability by tax return preparer
    • IRC 6695, Other Assessable Penalties with Respect to the Preparation of Tax Returns for Other Persons
    • IRC 6700, Promoting abusive tax shelters
    • IRC 6701, Aiding and abetting
    • IRC 6702, Frivolous tax submission

    Reminder:

    Whenever a pre-assessment civil penalty (CVPN) also carries an ASED, the Form 8278 Block 6 statute date (mandatory) (mmddyyyy) entry will be completed by the Compliance function. When carding a pre-assessment CVPN case, APS must recognize when the ASED is included on the Form 8278 Block 6 and enter the numeric ASED in the ACMS Statute Date field MM/DD/YYYY and leave the Statute Code blank to ensure the statute date is controlled and monitored.

     

  4. If the ASED for the pre-assessed PENAP case will expire in less than 365 days, notify your PTM for guidance prior to accepting and carding the case.
8.20.5.27.1 (08-05-2026)

Civil Penalty (MFT 13, 42, & 55) Case Carding

  1. APS will follow the general guidelines for carding civil penalty cases unless an exception is noted in the instructions below for a specific type of penalty case.
  2. When used to adjust an existing penalty, Form 8278 may contain post-assessed miscellaneous civil penalty information. Each post-assessment Form 8278 includes a PRN and reflects the assessed penalty amount.

  3. More than one type of penalty may be assessed on a Form 8278. Additional penalties listed on the same Form 8278 must be for the:

    • Same calendar year or period
    • Same entity

     

  4. Selecting the applicable codes in the "MFT Code" and "PRN Code" fields will sometimes auto-populate the category and subcategory.

  5. Return Level Entries:

    • Statute Date - Enter the numeric ASED for a pre-assessed CVPN or leave blank for a post-assessed CVPN
    • Statute Code - Leave blank for a pre-assessed CVPN or enter ASESD for a post-assessed CVPN
    • Amount Appealed - Enter the amount appealed per period

     

  6. MFT - The following MFT codes are used to control civil penalties:

    • MFT 13 for assessments against business entities (BMF taxpayer)
    • MFT 42 for assessments against trusts (BMF taxpayer)
    • MFT 55 for assessments against individuals (IMF taxpayer)

     

8.20.5.27.1.1 (08-05-2026)
Excise Penalty / Other Penalty Case Carding

  1. These cases are identified with reference to the following IRC sections:

    • 6653 - Failure to Pay Stamp Tax - PRN 574
    • 6673 - Sanctions and costs awarded by courts - PRN 643, 644
    • 6675 - Excessive Claims With Respect To The Use Of Certain Fuels - PRN 661
    • 6676 - Erroneous Claim for Refund or Credit - PRN 565
    • 6715 - Dyed Fuel Sold For Use Or Used In Taxable Use; Etc. - PRN 656
    • 6715A ((a)(1) or (a)(2)) - Tampering With Or Failing To Maintain Security Requirements For Mechanical Dye Injection Systems - PRN 665
    • 6717 - Refusal Of Entry Or Inspection - PRN 655
    • 6718 - Failure To Display Tax Registration on Vessels - PRN 657
    • 6719 - Failure To Register/Reregister - PRN 670
    • 6720A - Penalty With Respect To Certain Adulterated Fuels - PRN 673
    • 6725 - Failure To Report Information Under 4101 - PRN 667

     

  2. On the card-in screen, the APS TE will enter the MFT and PRN code shown on the Form 8278.
  3. After entering the MFT code and PRN code, ACMS will auto-populate the category to "Civil Penalty" and the subcategory to "Excise Penalty / Other Penalty."
8.20.5.27.1.2 (08-05-2026)
Information Return Penalty Carding

  1. These cases are identified with reference to the following IRC sections:

    • 6721, Failure to file correct information returns
    • 6722, Failure to file correct payee statements
    • 6723, Failure to comply with other information reporting requirements

     

  2. APS will create a separate appeal number for the penalty case. If Appeals also receives the related unagreed underlying income tax case, create a separate appeal number for that case. Link the related appeal numbers by using the ACMS relationship functionality. For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

  3. This table provides additional guidance for carding an information penalty appeal number:

    ACMS FieldInformation Penalty Case
    CategoryCivil Penalty
    SubcategoryInformation Return Penalty
    MFT13
    PRN Code537, 600, 612, 621, 637, 638, 642, 651, 652, 672, 674
    • Statute Date
    • Statute Code

    If penalty has not been assessed:

    • Statute Date - ASED of the related income tax return
    • Statute Code - Blank


    If penalty has already been assessed:

    • Statute Date - Blank
    • Statute Code - ASESD
    Amount AppealedEnter the amount shown on Form 8278
8.20.5.27.1.3 (08-05-2026)
International Penalty Case Carding

  1. APS will follow general carding instructions for these cases and follow the table below for instructions for specific ACMS field entries:

    ACMS FieldsInternational Penalty
    CategoryCivil Penalty
    MFT
    • MFT 55 for all IMF entities
    • MFT 13 for all BMF entities
    • MFT 42 for trusts
    PRN Code570, 599, 603, 605, 613, 619, 623, 625, 659, 660, 664, 668, 669, 671, 676, 677, 679, 700, 701, 702, 703, 704, 705, 706, 710, 711, 712
    Feature Code
    • AI for Appeal Coordinated Issue
    • IC for International Case
    Appeal Received Date

    Enter the earlier of the date of the email sent to the:

    • Technical Specialist; or
    • Date received by APS
    Taxpayer Request DateDate of the appeal hearing request
    APS NotesEnter the following statement: Intl Penalty Case IRC *
    * Enter the applicable code section(s)
    • Statute Date
    • Statute Code
    • If the penalty was already assessed, leave the Statute Date blank and enter Statute Code "ASESD"
    • If the penalty was not assessed, enter the numeric ASED of the return which generated the penalty in the Statute Date and leave the Statute Code blank
    Amount AppealedEnter the penalty amount shown on Form 8278

     

  2. Applicable IRC sections for international penalties include:

    • IRC 6038(c) – Penalty of Reducing Foreign Tax Credit Plus Continuation Penalty
    • IRC 6038A(e) – Noncompliance Penalty for Failure to Authorize an Agent or Failure to Produce Records
    • IRC 6038C(d) – Noncompliance Penalty for Foreign Related Party Failing to Authorize the Reporting Corporation to Act as its Limited Agent
    • IRC 6039F(c)(1)(A) – Taxability of Gift from Foreign Persons as determined by the Secretary
    • IRC 6686 – Information Returns for DISCs or Former FSCs IRC 6688 – Reporting for Residents of U.S. Possessions

     

8.20.5.27.1.4 (08-05-2026)
Return Preparer / Promoter / Appraiser Penalty Case Carding

  1. Return preparer, promoter, and appraiser penalty cases are carded on ACMS with:

    • Category - Civil Penalty
    • Subcategory - Return Preparer / Promoter / Appraiser Penalty
    • PRN - Will be identified on the Form 8278 under column (b))
    • MFT - 55 for individual, 13 for business (also found on Form 8278)

    • Statute Date or Statute Code - If the penalty is assessed, enter Statute Code ASESD. If the penalty is not assessed, see the table below.

      Penalty Code SectionPenalty Reference NumberStatute DateStatute Code
      6694(a)645
      • Three years from the statutory due date of the underlying return or, if filed late, or on extension, three years from the filing of the return.
      • Use the earliest ASED if there are more than one applicable statute date.
      		Leave blank
      6694(b)650Leave blankEnter 6694B - Penalties under IRC 6694(b) do not have an assessment statute of limitations.
      6695624, 714, 715, 716, 717, 718, 626, 627
      • Three years from the statutory due date of the underlying return or, if filed late, or on extension, three years from the filing of the return.
      • Use the earliest ASED if there are more than one applicable statute date.
      		Leave blank
      6713633Leave blankEnter N/A - 6713 - Penalties under IRC 6713 do not have a statute of limitations for assessment.

       

    • Amount Appealed - Enter the amount appealed per period

     

  2. Treat the case as one appeal number when multiple returns are involved in a preparer penalty case.

    Example:

    IRC 6694(a) is proposed against a preparer on 10 returns that were prepared. Card the case as one appeal number under the preparer's TIN. It is not necessary to record information on the 10 individual taxpayers.

     

  3. Forward the case to the ATM for assignment.
8.20.5.27.1.5 (08-05-2026)
Transaction Penalty Case Carding

  1. These cases are identified with reference to the following IRC sections:

    • 6700, Promoting Abusive Tax Shelters
    • 6701, Penalties for Aiding and Abetting Understatement of Tax Liability
    • 6702, Frivolous Tax Submissions
    • 6703, Rules Applicable to Penalties Under Sections 6700, 6701, and 6702
    • 6704, Failure to Keep Records Necessary to Meet Reporting Requirements Under Section 6047(d)
    • 6705, Failure by Broker to Provide Notice to Payors
    • 6707, Failure to Furnish Information Regarding Reportable Transactions
    • 6707A, Penalty for Failure to Include Reportable Transaction Information With Return
    • 6708, Failure to Maintain Lists of Advisees With Respect to Reportable Transactions
    • 6709, Penalties With Respect to Mortgage Credit Certificates
    • 6676, Penalty for Erroneous Claim for Refund or Credit

     

  2. APS will create a separate appeal number for the penalty case. If Appeals also receives the related unagreed underlying income tax case, create a separate appeal number for that case. Link the related appeal numbers by using the ACMS relationship functionality. For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

  3. This table provides additional guidance for carding a transaction penalty appeal number:

    ACMS FieldTransaction Penalty Case
    CategoryCivil Penalty
    SubcategoryTransaction Penalty
    MFT
    • MFT 13 for all BMF entities
    • MFT 55 for all IMF entities
    PRN Code565, 578, 579, 580, 628, 631, 634, 636, 639, 632, 648, 678
    Feature CodeAI for Appeals Coordinated Issue
    APS Notes (only needed if there is a related underlying income tax appeal number)Related to appeal number - insert appeal number of the related income tax case
    • Statute Date
    • Statute Code

    If penalty has not been assessed:

    • Statute Date - ASED of the related income tax return
    • Statute Code - Blank


    If penalty has already been assessed:

    • Statute Date - Blank
    • Statute Code - ASESD

    Note:

    The Form 872, Consent to Extend the Time to Assess Tax, for the underlying income tax does not extend the period of limitations for assessment of the IRC 6707A penalty unless the form includes specific language addressing the penalty. See IRM 25.6.22.6.17.10, Assessable Penalties, for the approved language.

    Amount AppealedEnter the amount shown on Form 8278

     

  4. The following table provides guidance for carding in the related income tax appeal number:

    ACMS FieldTransaction Penalty Income Tax Case
    CategorySelect the appropriate category from the menu
    SubcategorySelect the appropriate subcategory from the menu
    MFT

    Use the applicable MFT Code, generally:

    • MFT 02 for a BMF entity
    • MFT 30 for an IMF entity
    Feature CodeAI for Appeals Coordinated Issue
    APS NotesRelated to appeal number - insert appeal number of the related transaction penalty case
    • Statute Date
    • Statute Code

    If the deficiency has not been assessed,

    • Statute Date - the ASED of the income tax return
    • Statute Code - Blank

    If the deficiency has been assessed,

    • Statute Date - Blank
    • Statute Code - ASESD
    Proposed DeficiencyEnter the tax deficiency per RAR
    Proposed PenaltyDo not include the amount of the transaction penalty. Include any other penalties as shown on the RAR

     

8.20.5.27.2 (08-05-2026)

Penalty Abatement Request (PENAP) Case Carding

  1. PENAP procedures generally apply to penalties that have already been assessed. They are commonly referred to as "post-assessed" penalties. The APS TE will card the case following general guidelines and:

    • Category is based on the taxpayer type
    • Subcategory is "Penalty Abatement Request (PENAP)"
    • Statute Date - Blank
    • Statute Code - Enter ASESD

    • Proposed Penalty - Enter the total dollar amount of the penalty for each tax period

      Note:

      If there is more than one penalty for each tax period, total the amount for each period and enter the sum for the respective period.

       

     

  2. If a paper file is received, check the “paper” box during carding. Attach the ACMS E-5402 (Printable View) to the administrative file and forward the case to the ATM.
  3. For paperless cases, attach the electronic file to the newly created appeal number.
  4. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
8.20.5.27.3 (08-05-2026)

IRC 6673 - Sanctions and Costs Awarded by the Courts Penalty (Reconsideration) Case Carding

  1. IRC 6673(a) may be imposed by the Tax Court and IRC 6673(b) may be imposed by other courts (e.g., district court).
  2. When the IRC 6673(a) penalty is imposed by the Tax Court, APS posts the penalty to the applicable CVPN module (MFT 13 BMF or MFT 55 IMF) using PRN 643 at the same time they process the entered Tax Court decision.
  3. When the IRC 6673(b) penalty is imposed, the penalty is processed by the respective IRS function on the appropriate CVPN module using PRN 644.

  4. After the IRC 6673 penalty has been posted, the taxpayer may take an action and return to Appeals via one of two venues:

    • Penalty Reconsideration
    • CDP hearing

     

  5. The APS TE will card the case following general guidelines and:

    • Category – “Civil Penalty”
    • Subcategory – “Excise Penalty/Other”

     

8.20.5.28 (08-05-2026)

Shared Responsibility Payment

  1. When a shared responsibility payment (SRP) MFT 35 case file is associated with a non-docketed or docketed income tax case, card in the MFT 35 using the same appeal number as the MFT 30. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS.

  2. The APS TE will enter these fields:

    • MFT – Enter MFT 35
    • APS Notes – Enter 5000A SRP and Unassessed SRP Form 8278

     

  3. The APS TE will enter the following on the return level information screen:

    • Tax Period – Enter period
    • Statute Date – Normal statute date if the full amount of MFT 35 has not been assessed or leave blank if full amount of MFT 35 has been assessed
    • Statute Code – Blank (for MFT 35 screen) or enter ASESD if the full amount of the MFT 35 has already been assessed
    • Proposed Penalty – Enter the SRP amounts shown on the Form 8278

     

8.20.5.28.1 (08-05-2026)

Employer Shared Responsibility Payment (ESRP) Cases

  1. APS receives systemic email notification that the SB/SE Employer Shared Responsibility Payment (ESRP) Compliance group transferred a case to Appeals via the Electronic Case Receipts site. Upon notification, APS will:

    1. Card the case to ACMS as follows:
      • Category = Excise
      • Subcategory = Employer Shared Responsibility Payment (ESRP)
      • MFT = 43
      • PBC = 212 Employment Tax
      • Statute Code = Blank
      • Statute Date = N/A
      • Proposed Penalty = Use the amount(s) provided by SB/SE ESRP compliance group (Leave Proposed Tax field blank)
    2. Attach the Electronic Employer Case File received from SB/SE ESRP compliance group to ACMS
    3. Email Appeals’ point of contact that a new case is ready for assignment
    4. Delete all electronic files for the case on the ECR SharePoint intake site

     

8.20.5.29 (08-05-2026)

Substitute for Return (SFR) and IRC 6020(b) Case Carding

  1. The source function must ensure the TC 150 0.00 is posted to the account(s) and AIMS controls are established prior to forwarding the case to Appeals.
  2. If the source function has not already requested/established AIMS controls, the APS TE will establish them using IDRS CC: AM424A and, on the same day, use AIMS CC AMSTUA to update the AIMS status from 81 to 80 for non-docketed, or to 82 for docketed.

  3. When reviewing the case received for carding, the APS TE must recognize if the case file includes:

    • a signed agreement, or
    • an original delinquent return

    Caution:

    If a signed agreement (for any amount of tax) or a signed and IRS received date stamped original delinquent return is included in the SFR administrative file received from Compliance, those items indicate a potential live ASED. Alert your PTM or Lead and request verification of the ASED to ensure the statute date field is entered correctly before release to the ATM for assignment.

    Note:

    If the signed agreement or the signed and receipted original delinquent return was secured by Compliance, the respective account adjustments must have also been processed by Compliance before the case is transferred into Appeals’ jurisdiction via AIMS CC: AMCLS. If either a signed agreement or original delinquent return has been processed by Compliance, a current TXMODA will reflect the Compliance adjustment activity on the account.

     

  4. The table below provides a quick reference for the various scenarios applicable to an SFR account opened under Compliance’s jurisdiction and then submitted to Appeals as a docketed or a non-docketed case.

    Compliance’s SFR Case Conditions Upon Receipt by Appeals

    TC 150 0.00 SFR Posted andNon-Docketed or DocketedACMS AIMS and ASED Entries
    • No signed agreement
    • No delinquent return
    • IRM 4.4.12.12, Non-Docketed Cases - Group Responsibility
    • Non-docketed
    • Taxpayer protest requesting an appeal hearing
    • AIMS controls must be established by Compliance
    • IRM 4.4.12.14, Skeletal Records
    • Statute Date - MM-EE-YYYY
    • Statute Code - SUB
    • Signed agreement for full amount of Compliance Report
    • IRM 4.4.12.12, Non-Docketed Cases - Group Responsibility
    • Non-Docketed
    • Compliance must process agreed adjustments to taxpayer’s account
    • Case receipt in Appeals may be in error, notify PTM
    • If case received in error, do not card case on ACMS
    • Return case to originator as an erroneous receipt per PTM instruction using Form 3210 or E3210, as appropriate
    • Signed agreement for partial amount of Compliance Report
    • IRM 4.4.12.19.2, Form 5344, Technical Services Responsibility
    • Non-docketed
    • Compliance must assess any agreed amount of tax and/or penalty prior to submitting the unagreed adjustments to Appeals
    • If the partial assessment is not pending (PN) or posted, alert PTM to secure verification of assessment action
    • Statute Date - MM-DD-YYYY
    • Statute Code - Blank

    Note:

    Receipt of an agreement on a non-docketed SFR account serves to establish a live ASED. The ASED is calculated by adding three years to the IRS received date of the taxpayer’s agreement.

    • Original delinquent return received by Compliance
    • IRM 4.8.9.18.2.6, Delinquent Return Filed During Examination
    • IRM 4.4.9.6, Delinquent Return Received After SFR TC 150 Posted at Master File
    • IRM 4.4.9.6.1, TC 971 Action Code (AC) 282
    • Non-docketed
    • Compliance must process any delinquent return received, unless the taxpayer had previously filed a petition to the Tax Court in response to receipt of an SND
    • TC 971 AC 282 is posted to the taxpayer’s account by Compliance
    • If the taxpayer’s account does not reflect that the original delinquent return is posted, or PN, alert the PTM to follow-up with originating function
    • Statute Date - MM-DD-YYYY
    • Statute Code - Blank

    Note:

    IRS receipt of an original delinquent return on a non-docketed SFR account serves to establish a live ASED. The ASED is calculated by adding three years to the IRS received date of the delinquent return. TC 971 AC 282 sets the ASED at MF to three years from the return received date.

    Exception:

    *ASFR posts a TC 599 cc 89 to the account instead of a TC 971 AC 282 when they receive and process an original delinquent return.

    • No signed agreement
    • No delinquent return
    • Both taxpayers petition Compliance’s SND
    • IRM 4.8.9.27.4, Processing Petitioned Cases
    • Docketed
    • Compliance Technical Services uses CC: AMCLSE to transfer case to Appeals
    • Statute Date - Blank
    • Statute Code - DOCKT
    • No signed agreement
    • No delinquent return
    • Only one taxpayer petitions Compliance’s SND for an MFJ Account
    • IRM 4.8.9.27.8, Non-Petitioning Spouse
    • Docketed
    • Compliance Technical Services uses CC: AMCLSE to close the petitioned case to Appeals and retains NPS dummy file in their SND suspense
    • Statute Date - Blank
    • Statute Code - DOCKT

    Note:

    See IRM 8.20.5.5.5, Non-Petitioning Spouse (NPS) Cases, for additional carding guidance.

    • Agreed/No Change Year(s) associated with Petitioned Years
    • IRM 4.8.9.6.2, Closing Electronic Docketed and Non-Docketed Cases to the IRS Independent Office of Appeals (Appeals)
    • Associated with docketed TIN upon Counsel request
    • Compliance processes agreed or no change closings before recharging the NPYs to the Counsel Attorney for association with the petitioned years
    • If the Counsel Attorney does not need the agreed or no changed years to be associated with the petitioned years, then those closed years are sent to Campus Files by Compliance
    • Statute Date - Blank
    • Statute Code - RFRTN


     

    Note:

    When the Counsel Attorney does not need the agreed or the no change years for association with the petitioned years, APS will not include the agreed or no change tax periods on the ACMS record and the administrative files will be sent to Campus file function by Compliance.

    • Original delinquent return received by Compliance after issuance of SND but before taxpayer files a petition
    • IRM 4.8.9.25.2.2, Delinquent Return Secured, (1) a - d
    • Compliance determines status of taxpayer’s case and processes original delinquent return
    • SND may be reconsidered, rescinded, or remain unchanged
    		In the rare circumstance that this type of case would have the original SND unchanged and also petitioned, carding procedures cannot be developed as general guidance for inclusion in this IRM but are dependent upon the specific circumstances applicable at the time the case is received.
    • Original delinquent return received by Compliance after issuance of SND but after taxpayer files a petition
    • IRM 4.8.9.25.2.2, Delinquent Return Secured, (1) e
    • Compliance associates the unprocessed original delinquent return with the petitioned SND
    • Counsel Attorney or ATE notifies APS to process the return adjustments and update the ASED as an interim action via APS SharePoint intake process
    • Statute Date - Blank
    • Statute Code - DOCKT


     

     

  5. A docketed MFT 30 SFR will only involve one spouse even though both husband and wife may have petitioned the Tax Court. Until a joint filing status is approved by the ATE or Counsel Attorney, only the name and TIN reflected on the docketed SFR case is established on AIMS and ACMS. If and when the ATE/Counsel attorney determines it’s appropriate, the case will be converted from separate to joint as an interim or closing action according to the ATE’s instruction. For additional carding guidance, see IRM 8.20.5.5.6.3, Joint Petition Separate Returns Case Carding.

  6. An IMF SFR is carded using normal procedures and:

    • Statute Code - Enter "DOCKT" or "SUB," as appropriate

     

  7. BMF SFR cases can be employment tax or for an excise tax, and are only received as non-docketed. The SFR or 6020(b) cases are carded using normal procedures and:

    • Category - Enter "Corporation," "Employment," or "Excise," as appropriate
    • Statute Code - Enter "SUB"

     

  8. The following additional IRM references are provided for information only and as a quick reference to Examination’s IRM guidance related to processing requirements for "Compliance-secured" agreements and "Compliance-secured" original delinquent returns:

    • Employment Tax IRM 4.23.12.4.2, Processing Delinquent Returns under either Delinquent or SFR Controls
    • Estate and Gift Tax IRM 4.25.8.4.2, Processing Delinquent Returns
    • Estate and Gift Tax IRM 4.25.8.4.4.4, Unagreed Case Closing Procedures for Delinquent Returns
    • Examination Income Tax IRM 4.8.9.18.2.6, Delinquent Return Filed During Examination
    • Examination Income Tax IRM 4.8.9.25.2.2, Delinquent Return Secured
    • Examination Income Tax IRM 4.4.9.6.3, Delinquent Return Secured By Examination After SFR TC 150 Posted - Accepted as Filed Procedures
    • Examination Income Tax IRM 4.4.9.6.3.2, Forward to Centralized Case Processing (CCP)
    • Examination Income Tax IRM 4.4.9.6.4, Delinquent Return Secured by Examination After TC 150 SFR Posted, With Audit Potential - Process Partial Assessment Procedures
    • Examination Income Tax IRM 4.4.9.6.5.2, Additional Adjustments Required/Prepare RAR and Form 5344, Examination Closing Record
    • Examination SFR Reconsideration IRM 4.13.1.5.2, Reconsiderations of Delinquent Returns worked in an SB/SE Campus
    • Examination SFR Reconsideration IRM 4.13.1.5.1, Reconsiderations of Delinquent Returns Worked in a Taxpayer Services Campus
    • Exempt Organizations IRM 4.70.13.9.5, Delinquent Return Procedures (Processing Delinquent Returns Other than Employment Tax Returns)
    • Exempt Organizations IRM 4.70.13.9.8.4, Original Return Received After TC 150 Posts
    • Exempt Organizations IRM 4.70.13.9.5.10, Delinquent Returns Secured for Other Operating Division Jurisdiction
    • Exempt Organizations IRM 4.70.13-1, EO Delinquent Return Checksheet
    • Tax Exempt and Government Entity IRM 4.5.3.16.1, Delinquent Returns and Substitute for Returns Procedures
    • Tax Exempt and Government Entity IRM 4.5.3.16.1.1, Delinquent Returns
    • Tax Exempt and Government Entity IRM 4.5.3.16.2, Delinquent MF Returns Processing Procedures
    • Tax Exempt and Government Entity IRM 4.5.3-4, TE/GE Campus Addresses for Submitting Delinquent Returns (Reference: IRM 4.5.3.19)

     

8.20.5.29.1 (08-05-2026)

Delinquent Return Secured by Compliance Examination After the Compliance-Issued SND is Petitioned

  1. When Compliance has issued an SND because the taxpayer did not file a return and has also not agreed to the tax and penalty adjustments proposed, the taxpayer may file a petition with the USTC. The Compliance function controlling the SND will follow their respective IRM procedures and forward the case to Appeals. APS will card the case on ACMS as a docketed case and transmit the case to Counsel for answer to the petition.
  2. When an original delinquent return is received by Examination prior to the date the taxpayer files a petition with the USTC, the original delinquent return must be both considered and processed timely by Compliance. If the original delinquent return has no impact on the Compliance-issued SND, and the taxpayer files a petition with the USTC, Compliance will update the ASED on AIMS and IDRS, and associate the processed original delinquent return with the docketed administrative file sent to Appeals.

  3. APS will card the docketed case following general docketed carding procedures and:

    • Statute Code - Enter "DOCKT"
    • APS Notes - Enter "Processed original delinquent return received MM-DD-YYYY ASED = MM-DD-YYYY" (the ASED is calculated by adding three years to the return received date)

     

  4. When an original delinquent return is received by Examination after the date the taxpayer files a petition with the USTC, and after the docketed case has already been carded on ACMS, Compliance will not process the original delinquent return, but will forward it to Appeals for association with the docketed administrative file, per guidance in IRM 4.8.9.25.2.2, Delinquent Return Secured.
  5. Upon receipt of the original delinquent return, APS will research ACMS and identify the docketed appeal number for the previously petitioned case.

  6. APS will verify the original delinquent return IRS received date and also pull a current TXMODA transcript to determine if the delinquent return has been processed or not by the receiving function.

    • If the original delinquent return has been processed, follow carding procedures in IRM 8.20.5.29.1 (3) above
    • If the original delinquent return has not been processed, follow carding procedures in IRM 8.20.5.29.1 (7) below

     

  7. APS will card the docketed case following general docketed carding procedures and:

    • Statute Code - Enter "DOCKT"
    • APS Notes - Enter "Unprocessed original delinquent return received MM-DD-YYYY"

     

  8. Receipt of an original delinquent return after issuance of an SND requires special consideration by the ATE or Counsel attorney.
  9. Prepare Form 3210 or E3210 to forward the original delinquent return to the Counsel attorney or to the ATE, for association with the docketed administrative file.
8.20.5.30 (08-05-2026)

Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA)

  1. IRM 8.19, Appeals Pass-Through Entity Handbook, includes policy and procedural guidance for both TEFRA and Non-TEFRA cases in Appeals. Both TEFRA and Non-TEFRA cases are controlled on the Pass-Through Control System (PCS). TEFRA and Non-TEFRA cases can arrive in Appeals in docketed or non-docketed status.
  2. All non-docketed TEFRA partnership cases are submitted to APS by SB/SE Technical Services.
  3. All docketed TEFRA partnership cases are submitted to the applicable APS office based upon the Area Counsel office identified on the docket list.
  4. Both docketed and non-docketed Non-TEFRA cases are submitted to Fresno APS. For carding guidance, see IRM 8.20.5.4.1.4.1, Non-Docketed Non-TEFRA Flow-Through Entity Returns Carding, and IRM 8.20.5.4.1.4.2, Non-Docketed Non-TEFRA Flow-Through Entity Related to a Docketed Case Carding.
8.20.5.30.1 (08-05-2026)

Bipartisan Budget Act of 2015 (BBA)

  1. BBA repealed TEFRA and Electing Large Partnership provisions and replaced them with a centralized partnership audit regime for tax years beginning on or after January 1, 2018. ACMS has feature codes and CAR action codes for BBA cases arriving in Appeals. The ATE and APS will observe and validate feature codes and apply proper CAR action records when working BBA cases.
  2. For all BBA key cases, the category is Partnership BBA/TEFRA.
  3. ACN - APS and ATE will input and validate ACN for BBA cases in ACMS.
  4. Appeal Number - Case will be carded in with a new appeal number each time it returns to Appeals. See IRM 8.19.14.2.1(3), Appeals TEFRA/BBA Team (ATT).
  5. BBA cases are updated to Appeals in status 71 and must be updated to status 70, if non-docketed, or status 72, if docketed.
8.20.5.30.1.1 (08-05-2026)
BBA Docketed Cases
  1. When a petition is received from other business units, APS will retrieve the key case administrative file, check the petition for accuracy, card the case and/or update ACMS, as described below, and forward the case file to Counsel for answer.

  2. APS will input or update ACMS with the following case level information:

    • Docket number
    • Counsel office
    • Attorney
    • Update the jurisdiction indicator to Counsel’s jurisdiction
    • Notice Type: FPA
    • Notice Date
    • ACN

     

  3. In addition, APS will input or update ACMS with the following return level information:

    • Remove statute date from Statute Date field
    • Enter statute code: DOCKT

    Note:

    See similar TEFRA card in procedures below in IRM 8.20.5.30.2, TEFRA Key Case Carding.

     

  4. APS will update AIMS using CC:AMSTUE to status 72.
  5. Refer to IRM 8.19.14.7.3.2, Working Docketed BBA Cases in Appeals, for procedures to follow if the case is later returned to Appeals to settle and when the case is closed by either Appeals or by Counsel.
8.20.5.30.1.2 (08-05-2026)
BBA Modification Case Carding
  1. BBA Modification cases are carded with category "Partnership BBA/TEFRA" and subcategory "BBA Modification."

  2. Use the following information and instructions to assist in identifying a BBA Modification case:

    • The case will come to Appeals with the letters "AE" in the statute date field (e.g., 12/AE/2025).
    • If the case shows a prior status of 63 or 64, go to page 5 of CC AMDISA and verify that a modification request was submitted.
    • Verify on page 5 of CC AMDISA that the fields "MOD-REQUEST-RECVD-DT," , "MOD-DETERMINATION-LTR-DT," and "6235(a)(2)-DT" are populated with a date. The field "FPA-DT" should be blank.

     

  3. When carding a BBA modification case on ACMS:

    • FPA/FPAA Date - Enter the current date. This field is required by ACMS.

      Caution:

      Before validating the appeal, you must remove the date from the "FPA/FPAA Date" field located in the "Partnership Information" section under the "Summary" tab. Delete the date and then select the "Save" button.

       

    • BBA Modification Date - Enter the date listed in the "MOD-REQUEST-RECVD-DT" field on CC AMDISA page 5
    • PICF Code - Enter the code listed in the "PICF-CD" field on CC AMDISA page 1
    • Statute Date - Enter the date listed in the "FPA-DL-DT" field on CC AMDISA page 5

     

8.20.5.30.2 (08-05-2026)

TEFRA Key Case Carding

  1. A TEFRA key case can be either a non-docketed or docketed case for a Form 1065, U.S. Return of Partnership Income.

  2. The case routing guidelines direct IRS source functions to route:

    • Non-docketed TEFRA key cases to Fresno APS
    • Docketed TEFRA key cases to the APS office indicated on the docket list

     

  3. APS will also identify the TEFRA key case by PICF code 1 on the IDRS AMDISA print; however, a PICF code of 5 will override a PICF code of 1 when a partnership is an investor in another partnership. Any time Form 1065 is received, APS will verify whether it is or is not a TEFRA key case.

  4. The following table provides instructions on the receipt and carding process for TEFRA key cases:

    IF the TEFRA key case isTHEN
    Non-docketed

    Fresno APS will:

    • Receive and card all non-docketed TEFRA key cases before assignment
    • Route all non-docketed TEFRA key cases to the Appeals TEFRA/BBA Team (ATT) identified on the Internal Case Routing Guide for screening


    All APS offices will:

    • Card misrouted non-docketed TEFRA key cases, if received in a local APS office
    • Transfer misrouted TEFRA key cases after carding to Fresno APS
    Docketed

    All APS offices will:

    • Update the docketed skeletal ACMS record
    • Send the case to Counsel for answer
    Note:The ATT must screen ALL TEFRA cases before assignment to a Field ATE.

     

  5. APS will establish the TEFRA key cases following normal procedures and:

    • Category - Partnership BBA/TEFRA
    • Notice Type - Select FPAA (Appeals-issued) or FPAF (Compliance-issued) (If docketed).
    • Proposed Deficiency - The APS TE will leave the proposed deficiency on ACMS blank when carding the TEFRA key case. The ATT will compute the estimated proposed deficiency following the guidance in the TEFRA IRM 8.19, Appeals Pass-Through Entity Handbook.

     

8.20.5.30.3 (08-05-2026)

TEFRA Investor Case Carding

  1. When a TEFRA investor case is received in Appeals after the partnership examination is started, and there is an investor with at least one open TEFRA key case linkage, the PICF code on the AMDISA will be 5.
  2. The APS TE will card the TEFRA investor cases following normal procedures and include Category Partnership ILSC. APS will include a TSUMYI print with the administrative file to alert the ATE that it is a TEFRA investor case.

  3. An entry of a single digit in the "PICF" field is required at the return level whenever the AIMS Code = Y. The APS employee carding the case must recognize when a PICF code is present on AIMS and input it in the "PICF" field on ACMS. See the table below for the ACMS Category and PICF code entry requirements.

    IF MFT isAND
    PICF Code is    		THEN
    Category is    		AND"PICF" Field is
    06= 1Partnership BBA/TEFRA1
    06≠ 1Partnership ILSC= to PICF code on 
    AIMS & TSUMYI
    30= 4 or 5Individual4 or 5

     

  4. For the applicable subcategory, refer to the current TEFRA investor subcategory spreadsheet on the APS webpage.

  5. For CIC, LCC, Joint Committee (JC) case, and other Corporate Specialty TEFRA investor cases:

    • AMDIS/AMDISA: The APS TE will secure an AMDIS or AMDISA print from IDRS. CIC/LCC cases will have the CIC/LCC indicator present on the AMDISA print. If the AMDISA print shows PICF code 5, the investor has at least one open TEFRA key case linkage. If there is an open TEFRA linkage(s), the APS TE will secure a TSUMYI for the linkage information. The prints will be retained in the administrative file.
    • The APS TE will print the IDRS TSUMYI and identify any cases with an open ASED. Cases identified as CIC and LCC, JC case, and other corporate specialty investors cases when received in Appeals, will require the following information to determine if case needs to be carded to track the assessment statute of the investor. If there are no open ASEDs, then those investors do not have to be controlled on ACMS.

    • If an open TEFRA linkage exists, each TEFRA investor with an open ASED date listed on the TSUMYI will be carded as related non-key cases as follows:

      ACMS FIELDENTRY
      MFTTSUMYI MFT field
      CategoryPartnership ILSC
      SubcategoryReference Return
      SourceSource code of key case
      Business Function (if applicable)Enter originating function
      Tax PeriodsEnter all tax periods for which there is a TEFRA linkage
      Statute DateIf one-year statute date exists on TSUMYI statute field, input that date
      Statute CodeTFINV - if one-year statute date does not exist
      Proposed TaxLeave blank
      Appeals Related To / Appeals Related From

      Enter the applicable relationship, ensuring the key case is the “Primary Appeal,” and non-key cases are the “Secondary Appeal.” For more information, see:

      • IRM 8.20.13.5.11, Appeals Related To
      • IRM 8.20.13.5.12, Appeals Related From
      • IRM 8.20.13.5.12.1, Appeal Relationship Tab

       

    Note:

    If TSUMYI statute field contains "11111111" for each tax period that has a TEFRA linkage, the tax has been assessed, and the case will NOT be established as a related case.

     

8.20.5.30.4 (08-05-2026)

TEFRA Investor Carding When Non-TEFRA Issues Also Exist

  1. Investor cases will be established as separate appeal numbers on ACMS and will be closed separately when a decision is reached on the non-TEFRA issues. See IRM 8.20.5.4.1.4.1, Non-Docketed Non-TEFRA Flow-Through Entity Returns Carding, for carding guidance.
  2. When an income tax case is received in Appeals, the APS TE will secure an AMDIS or AMDISA for each tax year.

  3. If the AMDIS or AMDISA has a PICF code of 4 or 5, this indicates that the investor has at least one open TEFRA key case linkage (either an eight-digit date or a blank date). The APS TE will:

    1. Input the category "Partnership ILSC"
    2. Secure a TSUMYI for each year in Appeals’ jurisdiction to determine the TEFRA key case linkages and the status of the linkages
    3. Retain the AMDIS/AMDISA and TSUMYI prints in the administrative file

     

8.20.5.30.4.1 (08-05-2026)
Receiving TEFRA Partnership Key Cases
  1. The TEFRA key partnership case can be non-docketed or docketed. The return will be filed on a Form 1065.
  2. All TEFRA partnership key cases will be transmitted to Appeals on Form 3210. APS will promptly sign and date stamp the Form 3210 and return a copy to the originator, or acknowledge receipt via the E3210 Transmittal Database.
  3. Each TEFRA partnership key case should be clearly marked as a TEFRA case by Compliance. The partnership key case file should be flagged with Form 3198, Special Handling Notice for Examination Case Processing. In the block titled "Forward to Technical Services," the box for TEFRA or non-TEFRA key case should be checked.
  4. If the case was noted as a TEFRA key case, it is mandatory that the case be controlled on the PCS. The APS TE will secure a current AMDISA as well as TSUMYP and TSINQP prints and include them in the case file (the PICF code will be 1). For additional information on the PCS, see IRM 4.29.1, Overview of the PCS.
  5. The APS TE will leave the proposed deficiency on ACMS blank when the case is carded in. The ATT will compute the estimated proposed deficiency following the guidance in the TEFRA IRM 8.19, Appeals Pass-Through Entity Handbook, and the Field ATE will update ACMS Proposed Tax field to reflect the estimated proposed deficiency amount they’ve calculated.
8.20.5.30.4.2 (05-17-2022)
Non-docketed TEFRA Partnership Key Case Contents

  1. The partnership key case administrative file should contain the following items:

    • Form 1065 for a TEFRA partnership
    • Consents (if any) extending the statute of limitations. Form 872-P, Consent to Extend the Time to Assess Tax Attributable to Partnership Items, and Form 872-O, Special Consent to Extend the Time to Assess Tax Attributable to Partnership Items, extend the statute
    • Examiner's unagreed report
    • Explanation of Adjustments (either on Form 886-A, Explanation of Items, or Form 5701, Notice of Proposed Adjustment)
    • 60-Day letter (Letter 1827, TEFRA Partnership 60-Day Letter, or Letter 1829, TEFRA Partnership 60-Day Letter for Penalties and Adjustments)
    • Form 4605-A, Examination Changes - Partnerships, Fiduciaries, S Corporations, and interest Charge Domestic International Sales Corporations
    • Form 886-Z, TEFRA Partners' Shares of Income, listing notice partner information
    • Form 886-Z or comparable form listing non-notice partner information, if applicable
    • Copies of executed Form 870-PT, Agreement for Partnership Items & Partnership Level Determinations as to Penalties, Additions to Tax, and Additional Amounts, or Form 870-LT, Agreement for Partnership Items & Partnership Level Determinations as to Penalties, Additions to Tax, and Additional Amounts and Agreement for Affected Items, with schedule of adjustments (if any partners agreed with the examiner's findings). These forms should have been processed and any additional tax assessed as to these partners, and PCS updated
    • Protest
    • An affected item report if penalties or other affected items have been proposed by the examiner
    • POA, if applicable
    • Compliance required mandatory check sheets, if applicable. The following is a list of the check sheets: 
      - Form 13813, TEFRA Partnership Procedures Check Sheet
      - Form 14090, TEFRA Linkage Request Check Sheet (LB&I), or Form 14091, TEFRA Linkage Request Check Sheet (SB/SE)
      - Form 13827, Tax Matters Partner (TMP) Designation Check Sheet
      - Form 13828, Tax Matters Partner (TMP) Qualification Check Sheet

     

8.20.5.30.4.2.1 (05-17-2022)
Additional Items for Non-Docketed TEFRA Partnership Key Cases

  1. The APS TE will:

    1. Verify the statute of limitations date. At least 365 days must remain on the assessment statute when non-docketed TEFRA partnership key cases are received in Appeals.
    2. Verify PICF code (located on AMDISA).

     

8.20.5.30.4.3 (08-05-2026)
Additional Items for Docketed TEFRA Partnership Key Cases

  1. In addition to the items identified in IRM 8.20.5.30.4.2 above for a non-docketed TEFRA partnership key case, the docketed TEFRA partnership key case administrative file should also contain:

    1. A copy of the FPAA.
    2. A copy of the certified mailing list.
    3. A copy of the Tax Court petition or petitions.

    4. If multiple petitions have been filed, advise Associate Area Counsel at the time the case is sent for answer so that the appropriate action can be taken. Until Associate Area Counsel advises which petition is controlling, control each docket number on ACMS as a separate partnership case appeal number.

      Note:

      When multiple petitions have been filed, Counsel will advise APS which petition and docket number is controlling.

       

     

8.20.5.30.4.3.1 (08-05-2026)
Case Information for Docketed TEFRA Cases

  1. The APS TE will card the docketed TEFRA cases with:

    1. Category - Enter “Partnership BBA/TEFRA” for a TEFRA partnership case
    2. MFT - Enter 06 for Form 1065
    3. Feature Code - Enter appropriate code, when applicable
    4. Notice Type - FPAF for FPAA issued by Compliance
    5. Notice Date - Enter date FPAA was mailed to the tax matters partner (TMP)

     

  2. The APS TE will enter the following information at the return level on ACMS:

    1. Statute Date - Blank
    2. Statute Code - DOCKT
    3. Proposed Tax and Proposed Penalty - Blank; the APS TE will leave this field blank at the time of carding and the ATT will update it upon assignment and receipt

     

8.20.5.31 (08-05-2026)

Tax Exempt/Government Entities (TE/GE) Cases

  1. All TE/GE cases are submitted to the Fresno APS Carding Team.
  2. TE/GE cases are carded in with category "Employee Plans," "Exempt Organizations," "Government Entities - Federal, State and Local & Indian Tribal Governments," or "Tax Exempt Bonds." See IRM 8.20.13-1, ACMS Categories and Subcategories, for more information.
  3. TE/GE cases may also be received in Appeals as a Fast Track case.
8.20.5.31.1 (07-01-2017)

Employee Plan (EP) Cases

  1. EP cases are transmitted to Appeals using Form 3210. Once it is determined all items listed on Form 3210 are received, sign the acknowledgment copy of Form 3210, and return it to the originator. Keep a copy of the Form 3210 in the case file.
  2. The technical staff in the appropriate EP Area office, or the EP Centralized Review function (relating to determination matters), screen cases transmitted to Appeals to verify completeness of the protest and the case file, and to resolve factual discrepancies between the protest and the EP specialist's findings.
  3. See IRM Exhibit 8.7.8-1, Most Common EP Returns and Forms, for additional guidance on how to determine the ASED.
8.20.5.31.1.1 (08-05-2026)
EP Determination Case Carding

  1. EP determination cases contain an application prepared on Form 4461, Application for Approval of Standardized or Nonstandardized Pre-Approved Defined Contribution Plans, or Form 5300, Application for Determination for Employee Benefit Plan, series (5300, 5303, 5306, etc.). Follow card in procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, using the following:

    1. Category - Employee Plans
    2. MFT - 74 for the 5300 series (MFT - 75 for Form 4461)
    3. Determination cases are not on AIMS and no return information is entered

     

8.20.5.31.1.2 (08-05-2026)
EP Examination Case Carding (Taxable Returns)

  1. EP examination cases (taxable returns) have non-taxable reference returns (Form 5500-EZ, Annual Return of A One-Participant (Owners/Partners and Their Spouses) Retirement Plan or A Foreign Plan) and taxable returns with an RAR for proposed tax/penalty. Establish the taxable returns (Form 5330, Return of Excise Taxes Related to Employee Benefit Plans, Form 1120, Form 1041, Form 940, Form 941, etc.) on ACMS following carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter:

    • Category - Employee Plans
    • Statute Date - Statute of non-taxable return (Form 5500-EZ)

     

  2. Establish the non-taxable returns as a related reference case:

    • Category - Select the applicable category based on the reference case
    • Subcategory - Reference Return
    • Statute Date - Normal or extended statute

     

  3. The non-taxable reference return controls the statute on the taxable returns.
  4. If present, attach Form 5650, EP Examined Closing Record, to the inside of the administrative folder.
  5. Include the plan number when requesting AIMS prints or transcripts for EP cases.
  6. After carding the case, follow normal procedures for transmitting the case to the ATM for assignment.
8.20.5.31.1.3 (08-05-2026)
EP Revocation Case Carding
  1. EP revocations involve revoking (canceling) the plan. Revocation cases can be identified by checking the letter sent to the taxpayer offering the appeal.

  2. To establish an EP revocation case on ACMS, follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter:

    1. TIN - TIN with P modifier
    2. MFT - Return MFT
    3. Category - Employee Plans

    4. Subcategory - Revocation

      Note:

      On the return information screen, input the tax periods and statute. There is no proposed tax or penalty.

       

     

8.20.5.31.1.4 (08-05-2026)
EP 6707A Carding
  1. TE/GE EP 6707A cases are routed from the EP Mandatory Review Unit to the Fresno APS Team for carding.

  2. Fresno APS will follow the 6707A carding guidance provided below for this specialized case receipt. Enter the taxpayer name, address, and POA information following carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, and enter the codes provided below in the applicable field on ACMS:

    • MFT - 13 (BMF) or 55 (IMF)
    • Category - Employee Plans
    • Sub-Category - Penalty Abatement Request (PENAP)
    • PBC - Use the PBC 401 - 404 or 406 per the MFT 99 AIMS control or per the Form 3198-A, TE/GE Special Handling Notice
    • Statute Date - APS will enter the ASED provided by TE/GE
    • Statute Code - Blank

     

  3. Once the 6707A EP case is received by Fresno APS, and carded on ACMS, Fresno APS will forward the case to the appropriate ATM for assignment to an EP AO.
8.20.5.31.2 (08-05-2026)

Exempt Organization (EO) Case Carding

  1. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS.
  2. Select category “Exempt Organizations.”

  3. Enter the applicable subcategory:

    • Abatement of Interest
    • Claim
    • Deficiency / Over-Assessment
    • Determination
    • Penalty Abatement Request (PENAP)
    • Reconsideration
    • Revocation

     

8.20.5.31.3 (08-05-2026)

EO Determination Case Carding

  1. EO determination cases contain application forms - Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, Form 1024, Application for Recognition of Exemption Under Section 501(a), or Form 1028, Application for Recognition of Exemption. Card the EO determination case with:

    1. Category - Exempt Organizations
    2. Subcategory - Determination
    3. MFT - 67 for Forms 1023 and 1024 (MFT - 33 for Form 1028)
    4. Determination cases are not on AIMS and no return information is entered

     

8.20.5.31.4 (08-05-2026)

EO Revocation Case Carding

  1. EO revocations involve revoking (cancelling) the tax exempt status previously granted. The letter sent by TE/GE to the taxpayer offering the appeal indicates if the issue is a revocation.

  2. Card the EO revocation case with:

    1. MFT - Return MFT
    2. Category - Exempt Organizations

    3. Subcategory - Revocation

      Note:

      On the return level inventory screen, input the tax periods and statute. There is no proposed tax or penalty.

       

     

  3. If present, attach Form 5599, TE/GE Examined Closing Record, to the ACMS record. Form 5599 is an AIMS document and is used in completing additional EO closing information required on Form 5403, Appeals Closing Record.
8.20.5.31.5 (08-05-2026)

Government Entities - Federal, State and Local & Indian Tribal Governments - Case Carding

  1. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS.
  2. Select category “Government Entities - Federal, State and Local & Indian Tribal Governments.”

  3. Enter the applicable subcategory:

    • Abatement of Interest
    • Claim
    • Deficiency / Over-Assessment
    • Penalty Abatement (PENAP)
    • Reconsideration

     

8.20.5.31.6 (08-05-2026)

Tax Exempt Bonds Carding

  1. Follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS.
  2. Select category “Tax Exempt Bonds.”

  3. Enter the applicable subcategory:

    • Abatement of Interest
    • Claim
    • Deficiency / Over-Assessment
    • Reconsideration

     

  4. Enter the applicable Plan/Report Number per tax period.
  5. These cases can be identified by MFT 46, 84, 85, and 86.
8.20.5.32 (08-05-2026)

Transferee/Transferor Case Carding

  1. APS will follow carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, for these cases as follows:

    When there is one transferor:

    1. Establish the transferor as the key case
    2. Establish each transferee case as a related return
    3. Enter the total tax (deficiency) dollars shown by tax period on the transferor's KEY case with no duplication shown
    4. When showing the liability per tax period for each transferee case, remember to show the same amount in duplication


    When there are multiple transferors:

    1. Establish each transferor as a separate appeal number
    2. Establish each of their transferees as a related return
    3. Enter the total tax (deficiency) dollars shown by tax period on the transferor's KEY case with no duplication shown
    4. When showing the liability per tax period for each transferee case, remember to show the same amount in duplication

     

  2. When establishing transferee/transferor cases, use NMF codes in certain data elements to distinguish the case from MF cases with the same name that might be in the office at the same time. The codes also help when researching or updating specific cases based on appeal number, TIN, and MFT.

  3. Enter the applicable relationship, ensuring the key case is the “Primary Appeal,” and non-key cases are the “Secondary Appeal.” For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

8.20.5.32.1 (08-05-2026)

Transferee and Income Tax Liability Cases

  1. When a transferee/transferor case is received that contains both transferee and income tax liabilities, it is established in one of two ways:

    1. The transferee liability and transferor case are established as one appeal number and the income tax liability as a separate appeal number; or
    2. If the income tax liability is related to the transferee/transferor adjustments, all are established in one appeal number by using a TIN modifier to distinguish the transferee case.

     

  2. Establish the transferee and income tax (related) cases first and the transferor (key case) last.
8.20.5.32.1.1 (08-05-2026)
Transferee Case Carding

  1. Follow procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, for establishing transferee cases along with the following entries:

    1. TIN - Enter N after the TIN since the transferee assessment is NMF
    2. MFT - Enter the NMF tax code when the type of tax is known. Refer to Document 6209 for a list of NMF codes for each type of tax.
    3. Category - Enter appropriate category (e.g., Corporation, Individual) per the Form 1296, Assessment Against Transferee or Fiduciary
    4. Tax Period - Enter each tax period for which there is a transferee liability
    5. Proposed Tax - Enter the unpaid liability amount (in whole dollars) for each tax period
    6. APS Notes - Enter "Transferee"

     

8.20.5.32.1.2 (08-05-2026)
Carding the Related Income Tax Case
  1. When establishing the related income tax case, follow the carding procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS.

  2. Enter the applicable relationship for the related cases. For more information, see:

    • IRM 8.20.13.5.11, Appeals Related To
    • IRM 8.20.13.5.12, Appeals Related From
    • IRM 8.20.13.5.12.1, Appeal Relationship Tab

     

8.20.5.32.1.3 (08-05-2026)
Transferor Case Carding

  1. Follow procedures in IRM 8.20.13.3, Establishing Appeals Cases on ACMS, for carding the transferor case and:

    1. TIN - Enter N after the TIN
    2. Category / Subcategory - Enter based on the type of tax indicated on Form 1296
    3. MFT - Enter the NMF tax code per Document 6209
    4. Tax Period - Enter each tax period for which the transferor has tax due
    5. Proposed Tax - Enter the total tax (in whole dollars) for each tax period entered
    6. APS Notes - Enter "Transferor"

     

Exhibit 8.20.5-1 

Innocent Spouse - ACMS Statute Date/Statute Code Tables

Non-Docketed Pre-Assessment:

ASED Jurisdiction:Joint Return Key CaseRS Related CaseNRS Related Case
Proposed Deficiency/Appeals’ Responsibility
  • Statute Date -enter ASED
  • Statute Code - Blank
  • Statute Date -enter ASED
  • Statute Code - Blank
  • Statute Date -enter ASED
  • Statute Code - Blank
Proposed Deficiency/Exam’s Responsibility
  • Statute Date -enter ASED
  • Statute Code - EXAM
  • Statute Date -enter ASED
  • Statute Code - EXAM
  • Statute Date -enter ASED
  • Statute Code - EXAM


 

Non-Docketed Post-Assessment:

Both Spouses Assessed:Joint Return Key CaseRS Related CaseNRS Related Case
Mirrored on MFT 31 Accounts
  • Statute Date - Blank
  • Statute Code - N/A
  • Statute Date - Blank
  • Statute Code -SUSP
  • Statute Date - Blank
  • Statute Code - ASESD
Jointly on MFT 30
  • Statute Date - Blank
  • Statute Code - ASESD
  • Statute Date - Blank
  • Statute Code - SUSP
  • Statute Date - Blank
  • Statute Code - ASESD


 

Docketed Pre-Assessment:

Both Spouses Petition SND:Joint Return Key CaseRS Related CaseNRS Related Case
Same Docket Number
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - DOCKT
Separate Docket Number
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - DOCKT
  • See Note below
  • Statute Date - Blank
  • Statute Code - DOCKT
  • See Note below


 

 

Note:

Each separate docket number must be controlled as a key case record on ACMS with a cross-reference in the APS Notes field to the other appeal number / docket number.

 

Requesting Spouse (RS) Petitions, Non-Requesting Spouse (NRS) is a Non-Petitioning Spouse (NPS):

Status of NRS NPS Assessment:Joint Return Key CaseRS Related CaseNRS Related Case
NRS NPS not yet assessed
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - enter NPS ASED
  • Statute Code - Blank
NRS NPS assessment is posted
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - ASESD
  • APS Notes - enter 23C date of NRS NPS assessment
  • See Note below


 

 

Note:

Once APS has verified the posting of the NRS/NPS assessment, the NRS/NPS ACMS record Statute Date, Statute Code fields must be updated to accurately reflect the correct ASED information for the NRS/NPS and the 23C date of the NRS/NPS assessment must be entered in the CAR or APS Notes field.

 

Requesting Spouse (RS) Petitions Notice of Determination - Assessment Posted:

Assessment Posted:Joint Return Key CaseRS Related CaseNRS Related Case
Jointly on MFT 30
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - ASESD
  • See Note Below
  • Statute Date - Blank
  • Statute Code - ASESD
  • See Note Below
Separately on MFT 31
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - ASESD
  • See Note Below
  • Statute Date - Blank
  • Statute Code - ASESD
  • See Note Below


 

 

Note:

When an RS files a petition of an NOD, and the assessment has already been processed for both taxpayers on an MFJ return on their MFT 30 or their separate MFT 31 accounts, Appeals is neither obligated, nor responsible, for monitoring or controlling the collection statute; thus the Statute Date will be blank and the Statute Code will reflect ASESD.

 

Married Filing Separate (MFS) Returns ACMS Statute Date/Statute Code Entries (For Married Taxpayers Who Filed Separate Returns in Community Property States (IRC 66(c)):

Non-Docketed/Docketed & Assessment Status:RS MFS MFT 30 Key CaseNRS MFS MFT 30 Related Case
Non-Docketed 66(c) Assessed
  • Statute Date - Blank
  • Statute Code - SUSP
  • Statute Date - Blank
  • Statute Code - ASESD
Non-Docketed 66(c) Not Assessed
  • Statute Date - Enter numeric ASED
  • Statute Code - Blank
  • Statute Date - Enter numeric ASED
  • Statute Code - Blank or EXAM
  • See NOTE below
Docketed 66(c) Assessed
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Blank
  • Statute Code - ASESD
Docketed 66(c) Not Assessed
  • Statute Date - Blank
  • Statute Code - DOCKT
  • Statute Date - Enter numeric ASED
  • Statute Code - Blank or EXAM
  • See NOTE below


 

 

Note:

When the NRS is not already assessed, and AIMS control is in Appeals’ or Counsel’s jurisdiction (AIMS status 80/81/82), leave the ACMS Related appeal number Statute Code Blank to ensure the NRS ASED will be included on the applicable ACMS and AIMS statute reports. When the NRS is not already assessed, and the AIMS control is not open in Appeals’ or Counsel’s jurisdiction, enter EXAM in the ACMS Statute Code field to exempt the NRS ASED from being controlled and monitored for Appeals statute protection purposes. Appeals only controls and monitors ASEDs under Appeals’ or Counsel’s Jurisdiction in AIMS status 80/81/82.

 

Exhibit 8.20.5-2 

General Acronyms and Acronym Definitions Included in APS IRMs

AcronymAcronym Definition
ABINTAbatement of Interest
ACAction Code
ACAAffordable Care Act
ACMAppeals Case Memorandum
ACMSAppeals Case Management System
ACSAutomated Collection System
ACT/DMIAutomated Computation Tool (Decision Modeling Inc.)
AGIAdjusted Gross Income
AIVPAppeals Inventory Validation Process
AMTAlternative Minimum Tax
AOCAppeals Office Code
AOICAutomated Offer in Compromise
APOArmy or Air Force Post Office
APSAccount and Processing Support
ASEDAssessment Statute Expiration Date
ATCLAppeals Team Case Leader
ATEAppeals Technical Employee, which includes the following Appeals Employee Categories: Appeals Officer, Hearing Officer, Settlement Officer, Tax Computation Specialist (when applicable), Appeals Team Case Leader
ATMAppeals Team Manager
ATTAppeals TEFRA/BBA Team
AURAutomated Underreporter
BBABipartisan Budget Act of 2015
BMFBusiness Master File
BODBusiness Operating Division
BSBlocking Series
CAFCentralized Authorization File
CAPCollection Appeal Program
CARCase Action Record
CCISOCincinnati Centralized Innocent Spouse Operation
CCPCompliance Case Processing
CDPCollection Due Process
CDP/EHCollection Due Process Equivalent Hearing
CDPTDCollection Due Process Timeliness Determination
CFOChief Financial Officer
CGComputer Generated
CICriminal Investigation
CNCCurrently Not Collectible
CPFCampus Pass-Through Function
CPMControl Point Monitor
CRNCredit Reference Number
CSEDCollection Statute Expiration Date
CVPNCivil Penalty
DATCDoubt as to Collectability
DATLDoubt as to Liability
DCDisposal Code
DDIADirect Deposit Installment Agreement
DLNDocument Locator Number
DODistrict Office
E&GEstate and Gift
E3210Electronic 3210
ECRElectronic Case Receipts
EDLElectronic Docket List
EFINElectronic Filing Identification Number
EHEquivalent Hearing
EICEarned Income Credit
EINEmployer Identification Number
EITCEarned Income Tax Credit
EMPLEmployment
EP/EOEmployee Plan Exempt Organization
EPSSElectronic Products & Services Support
ESEstate Tax
ESAEducation Savings Accounts
EXExcise
FBARReport of Foreign Bank and Financial Account
FEField Examination
FLCFile Location Code
FOIAFreedom of Information Act
FPAAFinal Partnership Administrative Adjustment
FPOFleet Post Office
FSFiling Status
FTEFlow-Through Entity
FTMCFast Track Mediation Collection
FTSFast Track Settlement
HOHHead of Household
HSAHealth Savings Accounts
IAInstallment Agreement
IATIntegrated Automation Tool
IDTIdentity Theft
IGMInterim Guidance Memorandum
IMIncident Management
IMFIndividual Master File
IMSIssue Management System
INNSPInnocent Spouse
INTLInternational
IRAIndividual Retirement Account
IRA MFIndividual Retirement Account MF
IRCInternal Revenue Code
IRMInternal Revenue Manual
IRNItem Reference Number
IRSInternal Revenue Service
ISTSInnocent Spouse Tracking System
ITINIndividual Taxpayer Identification Number
MAASManual Assessment (used to identify a Quick Assessment)
MEFModernized E-File
MFMaster File
MFJMarried Filing Joint
MFSMarried Filing Separate
MFTMaster File Tax
MMIAManually Monitored Installment Agreement
MOICMonitoring Offer in Compromise
MRManual Refund
MSAMedical Savings Accounts
NAPNational Account Profile
NFNon-Filer
NMFNon-Master File
NODNotice of Determination
NPSNon-Petitioning Spouse
NPYNon-Petitioned Year
NRSNon-Requesting Spouse
NRUNon-Returns Unit
NSDNo Source Document
OAROperations Assistance Request
OICOffer in Compromise
OMBOrganizational Mailbox
PCPost Closing
PCSPass-Through Control System
PDCPosting Delay Code
PDIAPayroll Deduction Installment Agreement
PENAPPenalty Abatement Request
PERPotential Error Report (AQMS)
PICFPartnership Investor Control File
PIIPersonally Identifiable Information
POAPower of Attorney
PODPost of Duty
PRPremature Referral
PREPSTIPStipulation sent to Counsel for preparation
PRNPenalty Reference Number
PSPetitioning Spouse
PTMAPS Processing Team Manager
Q/AQuick Assessment (Manual Assessment MAAS)
RARRevenue Agent Report
RDDReturn Due Date
REFReference
REPRepresentative
RJRetained Jurisdiction
RRAPRapid Response Appeals Process
RRBRailroad Retirement Board
RSRequesting Spouse
RSDRetained Source Document
RSEDRefund Statute Expiration Date
SB/SESmall Business/Self-Employed
SCSource Code 
(If not used for Source Code, may be used to indicate Service Center (Campus) (e.g., SC Claim))
SDSource Document
SFRSubstitute For Return
SNDStatutory Notice of Deficiency
SSNSocial Security Number
STStatus
SUBSubstitute For Return (ACMS Statute Code)
TASTaxpayer Advocate Service
TBOR2Taxpayer Bill of Rights 2
TCTransaction Code
TCSTax Computation Specialist
TETax Examiner
TE/GETax Exempt & Government Entities
TEFRATax Equity and Fiscal Responsibility Act of 1982
TETRTelephone Excise Tax Refund
TFRPTrust Fund Recovery Penalty
TINTaxpayer Identification Number
TIPRATax Increase Prevention and Reconciliation Act of 2005
TLTeam Leader
TMTeam Member
TMPTax Matters Partner
TSTaxpayer Services
TSATechnical Services Advisory
TXITaxable Income
UNCUnclaimed Notice
UNDUndeliverable Notice
USTCUnited States Tax Court
VTSValidation Tracking System
WHWithholding
WHCWithholding Compliance
Exhibit 8.20.5-3 

Audit Information Management System (AIMS) Acronyms and Command Codes (CC) Included in IRM 8.20.5, 8.20.6 and 8.20.7

Acronym/CCAcronym/CC Definition
AIMSAudit Information Management System
CCCommand Code
AM424AIMS CC used to request establishment of AIMS controls
AMAXUAIMS CC used to update the AIMS Database
AMCLSAIMS CC used to input account adjustments
AMDISAIMS research CC
AMSOCAIMS CC used for short closing of the AIMS record
AMSTUAIMS CC used to update the AIMS Status Code
Exhibit 8.20.5-4 

Integrated Data Retrieval System (IDRS) and Corporate Files On-Line (CFOL) Acronyms and Command Codes (CC) Included in IRM 8.20.5, 8.20.6, and 8.20.7

Acronym/CCAcronym/CC Definition
IDRSIntegrated Data Retrieval System
CFOLCorporate Files On-Line
CCCommand Code
cc (lowercase)Closing Code
MFMaster File
ACTONIDRS CC used to open, update, and close an IDRS control base
BMFOLCFOL CC used to research a business taxpayer's account information
ENMODIDRS CC used to research a taxpayer's entity information
CFINKCFOL CC used to research POA information on CAF
ESTABIDRS CC used to enter requests for original paper documents, copies, information, etc. The kind of request made depends on the request code input with CC ESTAB.
IMFOLCFOL CC used to research an individual taxpayer's account information
INOLESCFOL CC used to research a taxpayer's entity information
ISTSRAISTSR with Definer A displays a case with all its data fields, stages, and comments.
REQ77/FRM77IDRS CC used to input miscellaneous TCs to the tax module
STAUPIDRS CC used to update/suspend MF status for modules that are, or have been, balance due modules. CC STAUP is valid for IMF, BMF, IRAF, and NMF.
TSCLSPCS CC used to close the partnership/partner linkage
TXMODAIDRS CC used to display a taxpayer's account, monitor account updates, and research pending, posted, and unpostable TCs.
XSINQIDRS CC used to research the Excess Collections File