- 8.21.2 Account and Processing Support (APS) Statute Responsibility
- 188.8.131.52 General Guidelines for Account and Processing Support (APS)
- 184.108.40.206 Verifying the Statute of Limitations on New Receipts
- 220.127.116.11.1 Examining Consent Forms 872, 872-A, etc.
- 18.104.22.168.2 Consent Signed by Individual Named in the Power of Attorney (POA)
- 22.214.171.124.3 Verifying Compliance Assessments or Abatements
- 126.96.36.199.4 Special Situations
- 188.8.131.52 Cases Not Accepted by Appeals
- 184.108.40.206 Actions When Statute Date is Uncertain
- 220.127.116.11 Updating Statutes on ACDS and AIMS
- 18.104.22.168.1 Adding Tack-On Time to Statutes
- 22.214.171.124 Transmitting Files to Other Offices
- 126.96.36.199 Receipt of Consent Termination (Form 872-T or 872-N)
- 188.8.131.52.1 Consent Termination on Cases Open in Appeals
- 184.108.40.206.2 Consent Termination on Cases Closed in Appeals
- 220.127.116.11 Statutory Notice of Deficiency (SND) Procedures
- 18.104.22.168.1 Undeliverables and Unclaimed Notices
- 22.214.171.124.2 Agreement Received during 90(150)-Day Notice Period
- 126.96.36.199.3 Defaulted Statutory Notice of Deficiency Cases
- 188.8.131.52.4 Statutory Notice of Deficiency Issued on a Tax Period Extended with Form 872-A , Special Consent to Extend the Time to Assess Tax
- 184.108.40.206 Petitioned Statutory Notices of Deficiency Cases
- 220.127.116.11 Receipt of Cases for Closing
- 18.104.22.168.1 Statute Verification on Case Closings
- 22.214.171.124.2 Processing Closings on Short Statute Cases
- 126.96.36.199.3 Cases That Reject at Closing
- 188.8.131.52.4 Unpostable Closings
- 184.108.40.206 Individual Statute Reports
- Exhibit 8.21.2-1 ACDS Statute Codes
Part 8. Appeals
Chapter 21. Appeals Statute Responsibility
Section 2. Account and Processing Support (APS) Statute Responsibility
October 15, 2014
(1) This transmits revised IRM 8.21.2, Account and Processing Support (APS) Statute Responsibility.
(1) This revision incorporates the Appeals Judicial Approach and Culture (AJAC) changes for APS from Interim Guidance Memorandum AP-08-0614-0003.
(2) This revision includes various editorial changes.
(3) This revision includes updates to conform to the Plain Language Writing Style Guidelines.
(4) This revision includes links to various forms and other Internal Revenue Manual sections.
(5) IRM 220.127.116.11 is deleted to removed references to receipt and processing responsibilities of original amended returns APS is not responsible for processing amended returns received in Appeals.
(6) IRM 18.104.22.168.1 is updated to remove reference to obsolete Form 872–Q and to clarify APS procedures for receipt of consent termination forms for cases open on the Appeals Centralized Database System (ACDS).
(7) IRM 22.214.171.124.2 is revised to remove reference to obsolete Form 872-Q and to clarify APS procedures for receipt of consent termination forms for cases closed on ACDS.
(8) IRM 126.96.36.199.4 is revised to clarify defaulting procedures for tax periods open with Form 872-A, Special Consent to Extend the Time to Assess Tax cases.
John v. Cardone
Director, Policy, Quality and Case Support
Account and Processing Support (APS) employees include the following positions:
Processing Team Manager (PTM)
Tax Examining Technicians (TE)
Any other Appeals employee doing processing work similar to the TE
IRM 8.21 is the primary source of reference used by APS employees when verifying, updating, and monitoring statute dates on Appeals' cases.
APS is responsible for verifying and monitoring the statute dates on all tax periods or returns under its jurisdiction. APS has jurisdiction of the case under the following circumstances:
Case is carded on Appeals Centralized Database System (ACDS) as being in APS possession
Case file is date stamped "received" by APS but not yet carded on ACDS
Case file is transmitted to another location but no acknowledgment is received from the intended recipient
To ensure that adequate statute control is maintained at all times while APS has jurisdiction of the case, APS will :
Timely open incoming mail and verify statute dates on all new receipts, including cases transferred from another Appeals Office
Keep ACDS current by timely updating ACDS for statute extensions and consents.
Input new receipts and close cases off ACDS as soon as possible
Issue Statutory Notices of Deficiency (SND) in a timely manner
Immediately assign cases and returns when an assessment is required. The assigned APS employee will validate the assessment statute date upon receipt;
Verify that Compliance-initiated assessments and abatements have been completed at the time the case is carded on ACDS
Generate and process ACDS reports and follow-up lists as provided in IRM 8.10.1
Generate CASES on Processing Employees Automated System (PEAS) Inventory statute reports as outlined in this document
Monitor Partnership Control System (PCS) reports generated from ACDS for cases that have Tax Equity and Fiscal Responsibility Act (TEFRA) linkages
Immediately upon assignment, APS will inspect all case files to verify the earliest statute date for each tax period and each type of tax contained in the file.
APS will also verify that the statute dates reflected on the transmittal and/or AMDISA print are correct.
APS will never assume that the statute date on the transmittal and/or AMDISA print is correct. If the statute date on the Audit Information Management System (AIMS) is incorrect, update it to the correct date by using command code AMSTUB (positions 15-22). See IRM 188.8.131.52(2)c for additional information.
If it is unclear which statute date applies, always use the earliest, most conservative date. Alert the PTM, Appeals Team Manager (ATM) and/or Appeals Technical Employee (ATE) assigned the case to the discrepancy.
Verification of the statute date should include a review of all original, copy, information, reference or substitute for return contained in the file. PTM/ATM must follow the AIVP validations. See IRM 184.108.40.206.2 for additional information.
Consider assessment and/or collection statute dates when verifying statute of limitations on the following receipts:
Innocent Spouse Cases
Collection Due Process (CDP), Offer in Compromise (OIC), Trust Fund Recovery Penalty (TFRP), Penalty Appeals (PENAP)
Use the most recently executed consent (Form 872, 872-A, etc.) when determining the statute date.
Analyze the most recent consent (Form 872, 872-A, etc.) to ensure that it is properly executed, contains the correct taxpayer information, and covers all years and types of tax included in the work unit.
If the current consent is not valid, the APS employee will need to verify the validity of the next prior consent. If valid, the statute date reflected on that prior consent will be used as the statute control date.
The above actions will be repeated until it can be determined that there is a valid statute on all the returns included in the work unit.
If a valid statute date cannot be determined, immediately seek assistance from the PTM in determining what statute date to use.
If it is determined that a valid statute exists but there are less than 365 days remaining on the assessment statute, follow the procedures found in IRM 220.127.116.11.1 for additional information. See IRM 18.104.22.168.1.2(2) for exceptions.
If an individual named in the POA, Form 2848, signs the consent, the TE will verify that the POA is authorized to sign the consent for the tax period, type of tax and taxpayer shown in the consent. See IRM 2.3.31 for information regarding IDRS Command Code CFINK.
If the POA form does not cover all periods, types of tax, etc. of the case, the APS Tax Examiner will make a notation in the NOTES field on ACDS to alert the ATM and ATE of this fact.
If there is evidence that Compliance should have made an assessment or abatement, the APS Tax Examiner will request a current IDRS transcript (IDRS Command Code TXMOD, IMFOL, BMFOL,etc.) to verify that the action was taken and follow these steps
Highlight the assessment or abatement on the transcript
Place the transcript in the case file
If there is evidence that Compliance should not have made an assessment or abatement, the APS Tax Examiner will request a current IDRS transcript to verify the current status of the account.
The APS Tax Examiner will notify the PTM who will verify with the ATM, ATE or the Counsel Attorney that the Compliance adjustment should remain or should be reversed.
The PTM will secure written authority to adjust the account, when appropriate, from the ATM, ATE or Counsel Attorney.
The APS Tax Examiner will take action to process the approved account adjustment, using Form 5403 if the case is established on the AIMS or Form 3870 if the case is not established on AIMS. Refer to IRM 8.20.7, Account and Processing Support, Closing Procedures.
On innocent spouse cases, the APS TE must first determine whether or not the amount at issue has been assessed in order to determine the appropriate statute date and code to input on ACDS for the requesting and non-requesting spouse. Refer to IRM 22.214.171.124 for procedures for the receipt and control of Innocent Spouse cases.
There are several cases that Appeals will not accept.
If an APS TE receives any of the following cases for carding, notify the PTM and return the case to Compliance:
Cases where the Assessment Statute Expiration Date (ASED) statutory period of limitations has expired on any tax year in the case.
Cases with less than 365 days remaining on the assessment statute. This is applicable to Compliance/Examination type cases. See IRM 126.96.36.199.1.2(2) for exceptions.
OIC cases where the taxpayers appealed too late. Statute dates on untimely appeals are not suspended.
Pre-Assessed Trust Fund Recovery Penalty (TFRP) Taxpayer Bill of Rights 2 (TBOR2) cases where the taxpayer appealed beyond the 60 days from the date of Letter 1153 (DO).
Letter 1153 (DO) gives the taxpayers 60 days to appeal a proposed TFRP assessment (75 days if the letter was mailed to an address outside the United States). If a taxpayer appeals a proposed TFRP beyond the 60 day period, the normal ASED is applicable and TBOR2 provisions do not apply. In counting the 60 days, do not include the date on the Letter 1153 (DO) or the delivery date, if the letter was delivered in person by the revenue officer.
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."
Cases that are in 90-day status.
Cases that involve Jeopardy or Termination Assessments, unless an SND has been issued. The exception to the above is cases received in Appeals for administrative review, pursuant to IRC 7429.
Cases that have an unassessed agreement in the file.
Any new case received in APS where the correct statute date cannot be identified will be handled as a priority case and identified as a short statute case until the correct statute date is determined. Under no circumstances should the case be held more than two (2) work days without action to resolve the statute date question.
If the APS Tax Examiner is unable to determine the correct statute date, immediately contact an ATM or other designated ATE located on-site. If there is no one who can provide on-site assistance, seek guidance from the PTM.
If for any reason the correct statute date still cannot be identified, the PTM may authorize use of statute code "UNKNOWN" on ACDS. This will allow the APS Tax Examiner to complete the carding process on ACDS and move the case to the appropriate ATM for assignment.
If the PTM is not available, the APS Area Manager can authorize use of statute code "UNKNOWN" .
Every effort should be made to determine the correct statute date. Statute code "UNKNOWN" will only be used in very rare situations.
Before sending the case with a statute code of "UNKNOWN" to the ATM, the APS Tax Examiner will place the case in a red folder and mark an expedite tag to alert the receiver that the statute date is uncertain at this time.
The APS TE will enter LACTION/LTODATE "to ATM" and the date the case was sent to the ATM for assignment. If the ATM is co-located with APS, the APS TE will hand-carry the case to the ATM or designated ATE.
APS will use Form 3210, Document Transmittal, for all case movement out of APS. Jurisdiction shifts from APS upon confirmation of receipt (acknowledged 3210) by the ATM.
Statute date and statute code must be updated on ACDS and AIMS in a timely manner. Timely is defined as one (1) workday from the date of notification or receipt of documentation.
The following is a list of circumstances that affect the statute date, and will require an update to the statute date or statute code on ACDS and AIMS. See Exhibit 8.21.2-1 for ACDS Statute Codes.
Signed consent forms extend the date to a particular date (i.e., Forms 872, etc.). When updating ACDS, enter the extended date in MM/DD/YYYY format (i.e., 12/31/2015).
Other signed consent forms extend the assessment period indefinitely (i.e., Forms 872-A, 872-O, and 872-R). When updating ACDS, use the appropriate statute code A, O, R, etc.
Signed notice of termination of special consent (i.e., Forms 872-T, 872-N, 872-Q, etc.). Enter a date of 90 days from when your office received the notice OR 90 days from mailing a signed termination to the taxpayer if issued by the Service.
Petition filed with Tax Court. Eliminate the statute date and enter the statute code DOCKT.
Petition filed with Bankruptcy Court. Enter the statute code BKRUP; however, the original statute date must also remain. In this instance you must also update the Feature Code to BK.
Defaulted notice of deficiency. Enter a date of 150 days (210 for foreign country residents) from what the normal or extended statute date was before the statutory notice was issued. (Consent Forms 872-A, 872-O, 872-R, are cancelled on the date the statutory notice was issued.) See IRM 188.8.131.52.1 , Adding Tack-On Time to Statutes.
Agreement during the 90-day period after a notice of deficiency. Enter a date 60 days from the date the agreement is received in Appeals or the original statute date, whichever is later. See IRM 184.108.40.206.1 for procedures on tack-on time.
Decision entered on a petitioned Tax Court case. Enter a date 150 days from what the normal or extended statute date was before the statutory notice was issued OR 150 days from the decision entered date, whichever is later. Remove the statute code DOCKT. If less than 60 days remain on the statute, compute the statute date using tack-on procedures. If you use a tack-on statute date, also input statute code TACKON. See IRM 220.127.116.11.1 for procedures on tack-on time.
Decision entered on docketed substitute for return (SFR). Compute the statute date: Decision Entered Date + 3 years + 150 days = the newly computed statute date. For example: entered date = March 1, 2014 + three years = March 1, 2017 + 150 days = July 29, 2017. The newly computed statute date is July 29, 2017.
Stay lifted on assessment by Bankruptcy Court. Enter at least 60 days from the date the stay was lifted. (This determination should be made by the Bankruptcy Coordinator or appeals officer.)
Written request to update the statute date is received from the ATM or ATE.
Appeals will not use "Tack-On" time unless there is less than 60 days remaining on the statute.
"Tack-On" time is the number of days remaining on the statute date which is impacted by the issuance of a notice of deficiency or a tax court decision or order of dismissal being entered.
"Tack-on" time for defaulted notices of deficiency is computed as follows: Issue date PLUS number of days from issue date to the normal or extended statute date before the notice of deficiency was issued.
If the tack-on statute date is used at ANY time, the statute code FINAL must be entered for every return impacted. APS Tax Examiners will use the standalone program TackonACDS.EXE to compute the tack-on statute date. Input an OS Get Services ticket to have the TackonACDS.exe icon added to your computer's desktop.
Tack-On Time - Agreed Notice of Deficiency
The tack-on statute date (90-Day Agreed statute) on an agreed notice of deficiency is the number of days that the statute was suspended plus 60 days.
Tack-On Time - Defaulted Notice of Deficiency
Defaulted Notice of Deficiency - The tack-on statute date (90-Day Agreed Statute) on an agreed notice of deficiency is the number of days that the statute was suspended plus 60 days.
NOTE: Exception to the above - If a notice of deficiency was issued on a case extended by an executed Form 872-A, the default statute date is computed by adding 90 days plus 60 days to the date the notice of deficiency was issued. The statute date is not suspended indefinitely.
Tack-On Time - Docketed Cases with Decisions Entered
The tack-on statute date (Decision Entered Statute) on a docketed case with an entered decision is computed by adding 90 days (for the decision to become final) plus 60 days (for assessment) plus the suspension period (the period from the date of the notice of deficiency to the normal or extended statute date).
All cases movement must be documented using a Form 3210, Document Transmittal.
APS is responsible for monitoring the statute date on any case sent outside the local Appeals office until an acknowledged 3210 transmittal or other written confirmation is received from the recipient office.
When transmitting unassigned non-docketed cases to Counsel for any reason, list all statute dates on the transmittal memorandum to Counsel.
Enter the earliest statute date on the front of the administrative file (Form 3198 or similar form) and on the transmittal.
Since APS is responsible for monitoring the statute of limitations until the acknowledgement receipt is received, the APS Tax Examiner will follow-up by phone or secure email if the acknowledgement is not received within ten (10) work days.
If the acknowledgement is not received within 20 work-days, alert the PTM for involvement.
Transferring cases with assessment periods expiring within 60 days should be avoided. Cases with imminent statute dates should only be shipped under the direction of the APS Area Manager.
When secure emailing or faxing a case, include the Taxpayer's name, Taxpayer Identification Number (TIN), tax periods and statute dates.
The receiving APS office will review all statute dates on the returns received to ensure the correct dates are shown on ACDS and AIMS.
Receipt of a Form 872-T, Notice of Termination of Special Consent to Extend the Time to Assess Tax Form, or Form 872-N, Notice of Termination of Special Consent to Extend the Time to Assess Tax Attributable to Partnership Items, , signed by, or on behalf of, the taxpayer, automatically decreases the statute date to 90 days from the receipt date of the form.
The actions taken will depend on whether the case is open or closed. This section details the procedures to follow when these forms are received on both open and closed cases.
When the APS receives a Form 872-T or 872-N signed by, or on behalf of the taxpayer, is received the APS Tax Examiner will immediately research ACDS to find the assigned ATE.
If the employee is on-site, hand-deliver the form.
If off-site, immediately fax the form. Email the ATE to notify that the form is being faxed. Mail the original soon after.
When a Form 872-T or 872-N is received on a case that has already closed in Appeals, immediately check IDRS to determine if the tax year is open in another function.
If it is, contact that function by phone or email to alert them of receipt of the form. A copy should be faxed immediately and the original form mailed to the other function using Form 3210 , Document Transmittal.
Ensure that the other function acknowledges receipt by returning a copy of the Form 3210.
If the tax year is not currently open in another function the APS Tax Examiner will give the form to the PTM who will forward it to the proper Campus for association with the return (original or refiled Document Locator Number (DLN)).
APS Tax Examiners will follow these procedures after the statutory notice of deficiency is issued.
If a Notice of Deficiency or Determination Letter is returned undelivered or unclaimed, follow the procedures in IRM 18.104.22.168.7.
Prompt attention must be given when Notice of Deficiency or Notice of Determination letters are returned since the assessment statute expiration period is still running.
If the taxpayer agrees to the deficiency in the statutory notice during the 90(150)-day period, the APS Tax Examiner will follow the procedures in IRM 22.214.171.124.1 . The APS Tax Examiner will also update the statute date on AIMS.
The APS Tax Examiner will promptly notify the ATE when an agreement is received during the 90/150-suspense period after an SND is issued.
The APS Tax Examiner will follow the procedures in IRM 126.96.36.199 to close TEFRA notices Prepayment (Refundable) Credits and Final S Corporation Administrative Adjustment (FSAA).
The APS Tax Examiner will follow the procedures in IRM 188.8.131.52.2 for defaulted SNDs.
If the statute was previously opened under Form 872-A (at the time the SND was issued), the revised assessment statute expiration date is 60 days from the agreement received date However, Form 872-A cases should be defaulted within 10 days to allow ample time to make the assessment.
When issuing an SND on a tax period that has an open ended Form 872–A holding the assessment period open, the APS Tax Examiner will either staple a pink Expedite tag or other Special Handling form to the front of the file to flag the case that the assessment statute expiration date is open under Form 872-A.
If the taxpayer submits an executed agreement form during the 90-day period on a Form 872-A case, the APS Tax Examiner will take the following actions within five (5) work days:
Request that the ATE assigned to the case determine if Appeals accepts the agreement.
Update the statute date on ACDS and AIMS to the agreement date + 60 days.
Prepare the case for closing following the procedure in IRM 184.108.40.206.2.
The APS Tax Examiner will follow the procedures in IRM 220.127.116.11.9 when taxpayers petition the Tax Court after issuance of the SND.
If the taxpayer does not petition one or more years of a multi-year notice, the APS Tax Examiner will update the statute date on ACDS and AIMS. The APS Tax Examiner will establish a new workunit on ACDS for the non-petitioned tax years to control the correct statute dates. See IRM 18.104.22.168.5.
The APS Tax Examiner is responsible for reviewing all cases received for closing. The review includes verifying the correct statute date and ensuring ACDS is promptly updated with the correct statute date.
The APS Tax Examiner will follow IRM 8.20.7 to process tried, dismissed or settled docketed cases.
Cases received in APS for closing will be date stamped by the APS Tax Examiners upon receipt. The date stamp on the case is the date the APS Tax Examiner will enter on PEAS.
When a case is assigned for closing, the APS Tax Examiner will inspect the file to determine the correct statute date for each tax period and each type of tax in the case. APS will use the most current extension (Form 872, 872A, etc.) attached to the return.
The APS Tax Examiner will consult with the PTM if there is uncertainty about the correct statute date.
Cases not controlled on AIMS, such as Interim Action Requests, and cases not controlled with an ASED statute date, such as Innocent Spouse cases, will also be reviewed by the APS Tax Examiner for assessment statute determination.
The APS Tax Examiner will closely inspect the file to ensure that all documents requiring assessment (partial agreements, taxable amended returns, etc.) have been properly processed.
A case received with less than 60 days remaining on the assessment statute requires the APS Tax Examiner to prepare a manual assessment package including Form 2859 , Request for Quick or Prompt Assessment, for submission to the Customer or Processing Campus. APS Tax Examiners will adhere to the following timeframes:
Cases with statute dates expiring in 10 business days or less must be faxed to the Customer or Processing Campus.
Cases with statute dates expiring in 11-59 days can either be sent by mail/courier, or faxed depending upon requirements/agreements with the local campus for each office.
The APS Tax Examiner will follow up if no verification has been received prior to the 23C date.
Responsibility for monitoring the statute remains with the APS Tax Examiner until verification is received. When received, the APS Tax Examiner will verify that the correct taxpayer, tax period, and tax amount were assessed before filing the verification.
Cases received with an assessment period expiring the same day will be processed by the APS Tax Examiner using the After Hours Assessment procedures, if received beyond the cutoff time for the campus that services the office with the case. Responsibility for monitoring the statute date remains with the APS Tax Examiner until verification is received.
Prior to any known absence from the office, the APS Tax Examiner will notify the PTM of short statute cases needing action. Once notified, the PTM is responsible for follow-up actions on the case during the APS Tax Examiner's absence.
When a case sent for closing is missing or contains incorrect information, contact the ATE for clarification. It is important to remember that the jurisdiction of the case is with the APS Tax Examiner.
If a case is rejected and the tax periods have not been assessed/abated, the APS Tax Examiner will not change the statute date information on ACDS. Leaving the original statute date on ACDS ensures the case will continue to appear on the statute report.
The APS Tax Examiner will follow procedures in IRM 8.20.7 for updating the statute date and statute code on ACDS for any rejected returns.
If the case is to be returned to the ATE, the APS Tax Examiner will note the earliest statute date on the front of the case file and ensure that the correct statute date is reflected on ACDS. The APS Tax Examiner will use Form 3210 to return the case to the ATE. Jurisdiction shifts to the ATE upon receipt of an acknowledged Form 3210. If the assessment period will expire in less than 60 days, the APS Tax Examiner will advise the ATM by e-mail that the case is being transferred to the ATE.
The APS Tax Examiner will retain copies of all non-AIMS adjustments, such as those input with IDRS Command Code REQ54, and will place them in a "monitor folder" . The APS Tax Examiner must monitor IDRS for unpostables on a weekly basis to ensure all unpostables are identified and corrected before a statute problem occurs.
Refer to IRM 22.214.171.124.6.2.4 for additional information regarding unpostables.
On a weekly basis, each APS Tax Examiner will generate their individual statute report, and note the status and actions taken or expected to be taken on the report.
The APS Tax Examiner will return this report to the PTM for review of the notes and verification that the proper actions are being taken.
The individual statute reports for each APS Tax Examiner will be attached behind the monthly report for the entire group.
|6501E||25% Omission||Exam Report|
|6694(B)||Preparer Penalty for willful or reckless conduct|
|872-D||872-D||Form 872-D - Tax Return Preparer Penalty (Statute Date also Required)|
|872-I||872-I||Form 872-I (Statute Date also Required)|
|872-T||872-T (Corresponding Date)||Form 872-T|
|ABATE||Abatement of Previous Assessment||Form 3870|
|ABINT||Abatement of Interest||Form 843|
|ADQDISCL||Adequate Disclosure under IRC 6501(c)|
|ASESD||Assessment Made||Transcript of Account|
|BKRUP||Bankruptcy||Various documents (including lien)|
|CBYYYYMM||Carryback + year i.e. CB200312||Exam Report, claim forms, etc.|
|CLAIM||Claim||Amended return, Form 843, etc.|
|COLL||Collection is controlling the Statute|
|CSED||Collection Statute Expiration Date||IDRS research|
|DOCKT||Docketed||Docket list, petition, etc.|
|EXAM||Exam is controlling the Statute||Approved Early Referral Request|
|FINAL||Tack-On time statute||Only used when less than 60 days remains on the statute for SND and Tax Court decisions|
|FBAR2||2 Year Limitation Date in which Department of Justice may file a civil action to reduce an FBAR judgement|
|FBAR10||10 Year Limitation date for the Government to obtain payment of the FBAR by offsetting payments|
|FRAUD||Fraud||Exam Report, Doc. 6411|
|NPS||Non-Petitioning Spouse||Used on the Joint Return Key Case|
|SUB||Substitute for Return||Administrative file contents, IDRS research, etc.|
|SUSP||CSED Suspended||Collection Due Process administrative file contents, Innocent Spouse administrative file contents, etc.|
|TBOR2||T/P Bill of Rights||Trust Fund Recovery Penalty administrative file|
|TIPRA||TIPRA 24 Month OIC Determination Required|