Campus Exam Classification is responsible for reviewing amended returns/refund claims submitted to the Internal Revenue Service and referred to Exam under the Category A (CAT-A) process. Accounts Management (AM), Submission Processing (SP) and other areas refer claims to Campus Exam Classification in both Small Business/Self Employment (SB/SE) and Taxpayer Services (TS) Return Integrity Compliance Services (RICS) Exam when they identify CAT-A criteria. Claims are typically referred via the Account Management Services (AMS) Correspondence Imaging Inventory System (CII) using the "2CATA" suspense option, which systemically reassigns the IDRS control base to the co-located Campus Exam Classification IDRS number.

The CII case (claim) is reviewed by Campus Exam Classification (Revenue Agents for BMF and Tax Compliance Officers for IMF) to determine whether the issue being claimed is allowable and whether the amended return has audit potential. Claims that are either accepted as filed, not allowable, or have insufficient information to make a determination are returned to AM/SP via CII, which reassigns the IDRS control base back to the originator. The AM/SP originator then processes the adjustment (when accepted) or issues the disallowance notice (when not allowed) and closes the CII case, which closes the IDRS control base. Claims that are considered to have audit potential are selected for examination and routed to Campus Exam Classification Support. The CII case is returned to AM/SP with notations that the claim was selected and the originator closes the CII case.

When a classifier identifies a claim with Large, Unusual, and/or Questionable (LUQ) items and decides it has audit potential, they send the claim to Classification Support (Case Building) for delivery to Correspondence or Field Exam. Campus Exam Classification Support builds the case by opening an AIMS base (which establishes a TC 420), closing IDRS control bases on CC TXMOD as necessary, and electronically delivering any necessary case documents to local area office Planning and Special Programs (PSP) or Campus Exam. See IRM 4.19.12, Classification Support.

IRM 1.1.16.5.5.1, Examination Field and Campus Policy

IRM 1.1.16.5.5.3, Exam Case Selection

IRM 1.2.1.2.36, Policy Statement 1-236, Fairness and Integrity in Enforcement Selection

IRM 1.2.1.5.7, Policy Statement 4-9, Highest Integrity Expected

IRM 1.2.1.5.10, Policy Statement 4-21, Selection of returns for examination

IRM 1.2.1.5.22, Policy Statement 4-76, Disallowed claims may be reconsidered on the merits

IRM 1.2.1.5.23, Policy Statement 4-77, Claims may be allowed without examination

IRM 1.2.1.5.31, Policy Statement 4-103, Abatement claims considered only in exceptional circumstances

IRM 4.1.5.3, Classification

IRM 10.5.1, Privacy Policy

Examination Field and Campus Policy (EFCP) is responsible for leading the development and delivery of policy and guidance that impacts SB/SE taxpayers and SB/SE Campus and Field examination processes.

Campus Exam and Field Support (CEFS) is responsible for providing policy on compliance processes that relate to campus examination classification operations for Correspondence, Field, and Specialty Exam programs.

The Taxpayer Bill of Rights (TBOR) lists rights that already existed in the tax code, putting them in simple language and grouping them into 10 fundamental rights. Employees are responsible for being familiar with and acting in accordance with taxpayer rights. See IRC 7803(a)(3), Execution of Duties in Accord with Taxpayer Rights.

The following reports may be used to monitor inventory assigned in Classification:

The following table lists commonly used acronyms and their definitions used throughout this IRM.

IRM 4.1.5.3, Classification

IRM 4.13, Audit Reconsideration

IRM 4.10.11, Claims or Refund and Requests for Abatement

IRM 4.19.14, Refundable Credits Strategy

IRM 4.19.15, Discretionary Programs

IRM 21.5.2.4.23.6, Discriminant Index Function (DIF) SCORE or Classification Send Return(s) to Examination for Review

IRM 21.5.3, General Claims Procedures

IRM 21.5.3-2, Examination Criteria (CAT-A) - General

IRM 21.5.3-3, Examination Criteria (CAT- A) - Credits

IRM 21.7.4.4.2.9, Form 1065 and 1065X, Amended Return, Administrative Adjustment Request (AAR) and Bipartisan Budget Act (BBA)

IRM 21.8.1.2.10, Examination Criteria CAT-A International

IRM 21.8.2.2.12, Examination Criteria

IRM 25.6, Statute of Limitations

IRM 25.23, Identity Protection and Victim Assistance

The order for classifying all CAT-A claims is by IRS received date. Additional information can be found in IRM 4.19.16.2.2, Claims Processing in Accounts Management Branch.

The following CAT-A Classification work types should be worked as a priority:

Claims are received, scanned, and stored in the Account Management Services (AMS) Correspondence Imaging Inventory System (CII). When an AM or SP assistor identifies CAT-A criteria they refer the claim to Exam Classification using the "2CATA" suspense option, which systemically reassigns the IDRS control base to the co-located Campus Exam Classification IDRS team number (see Exhibit 4.19.11-2, Campus Exam Classification Unit IDRS Numbers). The original CII case is moved to the AM/SP assistor’s CII Suspense Folder and a copy of the CII case (with limited functionality enabled) is transferred to CAT-A inventory in CII.

The Dependent Database (DDB) is a rules-based selection application that is designed to identify potentially ineligible tax returns claiming Earned Income Tax credit (EITC) and other refundable credits (for example, Premium Tax Credit (PTC), Additional Child Tax Credit (ACTC) and American Opportunity Tax Credit (AOTC)). DDB selects returns using an automated process based on programmed selection criteria designed to select the most productive returns for examination. The highest scored returns are made available for audit selection.

To ensure impartiality, independence, and employee privacy, subordinates, associates or co-workers of an employee will not classify or examine that employee’s return.

Command Code IMFOL on IDRS shows the IRS employee indicator. A "P" indicates the primary taxpayer is an IRS employee, an "S" indicates the secondary taxpayer is an IRS employee, and a "B" indicates both the primary and the secondary taxpayers are IRS employees. See IRM 2.3.51-12, Command Code IMFOL Output Display - Index.

Classification Support will send employee returns selected for examination to the PSP area office closest to where the employee lives. Classification Support will not route employee returns to Campus Correspondence Examination.

For additional information reference IRM 4.1.1.6.7, Employee Audits and IRM 4.2.6, Examination of Employee Returns.

IRM 25.23, Identity Protection and Victim Assistance, provides servicewide guidance on Identity Theft (IDT) issues, including documentation and actions required for general processing of IDT claims.

BMF IDT indicators are not applied until required research has been completed to rule out a possible mixed entity issue. Never assume identity theft prior to completing preliminary research. Refer to IRM 25.23.9-7, BMF Identity Theft Research Requirement, and IRM 25.23.9-2, BMF ID Theft Indicators – Transaction Code (TC) 971 Action Code (AC) 522 IDTCLM - Initial Allegation or Suspicion of BMF Identity Theft, when researching BMF accounts.

A "-Z" freeze or an unreversed TC 914 on a tax module indicates that return has Criminal Investigation (CI) controls.

If a case is received in CAT-A Classification and there is an open CI control base on the IDRS tax module, return the case to AM/SP with advice to route the case to the open control base.

The Fraud Coordinator in TS Refundable Credits Examination Operations (RCEO) makes selection determinations for TS Corr Exam.

Invariably, the definition of significant will depend on the classifier’s perception of the return as a whole and the separate items that comprise the return. However, there are several factors to consider when determining whether an item is significant:

This subsection includes general and background information on Classification work processes.

Classification responses will not contradict IRM 21.5.3-1, Claims Processing with Examination Involvement, which is the IRM Accounts Management follows when they receive a response from CAT-A Classification.

Classification will only provide one determination when responding.

The table below only applies to complete cases containing the necessary returns and taxpayer documentation to make a determination. If the case is not complete and can’t be classified, it will be returned to the requestor/originator with an explanation of why it can’t be classified.

If a classifier determines a claim has audit potential and selects the case, they will take appropriate actions to ensure the case is built and sent to the appropriate area.

When Exam Classification selects a claim, AM/SP transfers claim resolution liability to the Exam function. Appropriate Exam functions are then responsible for establishing AIMS, and proceeding with auditing or processing the claim.

Statute awareness is vital and required to minimize barred assessments and erroneous abatements.

The Assessment Statute Expiration Date (ASED) generally expires three years from the time the return was filed or two years from the time the tax was paid, whichever is later (see IRC 6511, Limitations on Credit or Refund). The ASED may be extended for specific reasons however, the expiration of the statute prohibits further assessment unless a valid extension is in place or exception to IRC 6501, Limitations on Assessment and Collection, applies.

When a tax assessment is not made within the prescribed period for assessment it is considered a "barred assessment."

In the event an ASED expires while a tax return is under Classification control, refer to IRM 25.6.1.13.2.1, Barred Statute Report (Form 9355/3999) and IRM 25.6.1.13.2.8.1, Procedures for the Submission of SB/SE Statute Expiration Reports.

Statute information, including conditions which may extend the Assessment Statute Expiration Date (ASED), Refund Statute Expiration Date (RSED), or Collection Statute Expiration Date (CSED), can be found in IRM 25.6.1, Statute of Limitations Processes and Procedures.

A bundled claim (tax and credit decreases or tax and credit increases) that results in an overall net increase (results in a balance due and/or increases the balance) should not be sent to CAT-A Classification. Return Bundled Claims with net increases back to the Accounts Management/Submission Processing originator as "Not CAT-A" and reference IRM Exhibit 21.5.3-2 Examination Criteria (CAT-A) – General.

A bundled claim (tax and credit decreases or tax and credit increases) that meets CAT-A criteria and results in an overall net decrease (generate a refund and/or decrease the balance) is sent to CAT-A Classification using the following referral reasons:

Protective claims are filed to preserve the taxpayer’s right to claim a refund when the taxpayer's right to the refund is contingent on future events and may not be determinable until after the statute of limitations expires. Reference IRM 25.6.1.10.3.2.5, Protective Claims.

The IRS has discretion in deciding how to process protective claims. In general, it is in the best interests of the IRS and taxpayers to delay action on protective claims until the pending litigation or other contingency is resolved. Once the contingency is resolved, the IRS may obtain additional information necessary to process the claim and then allow or disallow the claim. Reference IRM 25.6.1.10.3.2.5, Protective Claims.

Protective Claims may be informal claims or amended returns for credit or refund normally based on expected changes in current regulation, pending legislation or current litigation. Any claim based on a pending court case or decision is considered a Protective Claim. A protective claim can be identified with a literal "protective claim" or similar language or verbiage related to current regulation or pending or current litigation on the claim itself. These claims are filed to protect the claimant's right to recover internal revenue tax before the expiration of the statute of limitations. For this reason, they are all considered to meet CAT-A criteria. Reference IRM 21.5.3.4.7.3, Protective Claims and IRM Exhibit 21.5.3-2, Examination Criteria (CAT-A) – General.

Submission Processing (SP) and Accounts Management (AM) verify Protective Claims are processable prior to sending to CAT-A Classification. Reference IRM 21.5.3.4.7.3.1, Processing Protective Claims.

If a Protective Claim cannot be closed due to contingency action, the claim is reviewed in CAT-A Classification to ensure it is processable and valid before the claim is selected and forwarded to the appropriate area office (PSP).

The PSP Claims Coordinator will forward valid protective claims to Technical Services and update status code, source code, and project code (if necessary). Reference IRM 4.1.1.6.5.1, Claims Coordinator.

Technical Services will maintain area suspense cases while waiting for an event to occur, such as completion of litigation or other administrative action, based on national or area directive. Reference IRM 4.8.2.11, Suspense Cases.

When a claim involving Penalty Reference Numbers (PRNs) 600 or 612 is received in CAT-A Classification with a -W Freeze Code, Classification will provide a determination and return the claim via the Account Management Services (AMS) Correspondence Imaging Inventory System (CII) system. Accounts Management (AM) or Submission Processing (SP) will coordinate with Appeals to close the case. Reference IRM 21.5.6.4.46, -W Freeze.

An audit reconsideration is the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax credit was reversed.

When the IRS issues an erroneous refund on a BMF return that must be recovered with a Statutory Notice of Deficiency (SNOD), the case will be routed to the co-located Campus Examination function. Reference IRM 21.4.5, Erroneous Refunds.

BMF Classification will provide support for these cases by completing a technical review of the case. The technical review will include:

After completing the review, BMF Classification will return the erroneous refund case to the Campus Examination operation to take the next routing or processing steps.

Accounts Management (AM) and Submission Processing (SP) assistors identify Joint Committee cases by applying Category A (CAT-A) criteria outlined in IRM 21.5.3-2, Examination Criteria (CAT-A) – General. When any case results in a refund or credit greater than the amounts outlined in IRM 21.5.3-2, Examination Criteria (CAT-A) – General, regardless of the issue, the case is referred to CAT-A Classification.

All refunds from source years open with respect to the statute of limitations need to be considered in determining the jurisdictional amount. For example, if tentative refunds added together exceed the amounts outlined in IRM 21.5.3-2, Examination Criteria (CAT-A) – General, both the source years and tentative refund years will be reported. This is true if none, one, or all, of the separate tentative refunds exceed the outlined thresholds.

Classifiers must be aware that refunds meeting Joint Committee criteria require special processing. Generally, IRC 6405 requires the submission of reports by the IRS to the Joint Committee on Taxation.

Classifiers will select all Joint Committee cases.

LB&I provides support to SB/SE and TEGE for the Joint Committee Review (JCR) program and oversees the preparation of the report sent to the Joint Committee for all agreed, partially agreed, no-change, and surveyed cases meeting Joint Committee criteria. Reference IRM 4.36, Joint Committee Procedures.

Exam will monitor for incoming Automated Underreporter (AUR) technical advice and CAT-A referrals daily. Prior to electronically delivering the case, AUR will update the IDRS control base activity code to CATAmmdd (mmdd represents the month and day the referral is due back from CAT-A Classification). Incoming referrals will contain: a complete and accurate Form 15339, AUR case contents (including a copy of the last CP 2000 or CP 2501 Notice), and the document the taxpayer submitted.

Exam Classification will review the referral to determine if the expenses are allowable or if the case has audit potential within 45 calendar days of receipt.

Exam Classification will work AUR referrals from the aligned SB/SE Exam site(s) as outlined below.

If Classification determines the referral will be selected for audit:

If Classification determines the referral will be accepted as filed, Classification will send the AUR coordinator an email stating the Form 1040X can be accepted as filed (email title "Accepted as Filed" ).

If Classification determines the additional expense is not allowable by law, Exam will send the AUR coordinator an email stating the expense is not allowable and provide a standard paragraph that can be sent to the taxpayer explaining why it is not allowable (email title Not Allowable).

The DIF system is used to evaluate the examination potential of:

A Section 761(a) partnership return is an unincorporated organization which qualifies under IRC 761(a) as:

A qualifying partnership may elect under IRC 761(a) to be excluded from treatment as a partnership. (See Treasury Regulation 1.761-2.)

Additional processing information and Exam criteria can be found in the following:

For the first year for which it wants the exclusion, the unincorporated organization should make the election in a statement attached to the Form 1065, U.S. Partnership Return of Income.

Submission Processing (SP) suspends processing 761(a) elections until a review is made by Classification.

Classification will review returns that are identified as potential IRC 761(a) elections. Classification is responsible for making classifiers available to Code and Edit in SP to determine if IRC 761(a) elections will be accepted or rejected before processing is completed.

If the classifier determines missing information needs to be obtained to validate the IRC 761(a) election:

Phone inquires and technical responses by taxpayers on the aforementioned letters are also directed to Classification.

Classifiers of IRC Sec. 761(a) elections should have experience in tax shelters.

Classifiers reject elections that are determined to be invalid. Valid elections are accepted as filed.

After a determination is made on an IRC 761(a) election, SP processes the return as follows:

Returns selected for examination are forwarded to their respective area offices.

The taxpayer may request abatement of interest due to an error or delay in the performance of a ministerial/managerial act.

The Accounts Management Operation at each campus generally receives requests for abatements of interest and determines which functional area is the source of the claimed error or delay. See IRM 21.5.2.4.10.1, Ministerial/Managerial Interest Abatement. Accounts Management will:

Accounts Management will forward claims originating in Customer Account Services (CAS) to Examination as technical advice requests. Examination will review and return them with a recommendation whether to allow or disallow the claims.

Interest abatement claims may also be received directly in Examination either in the processing of an examination program, or in a prior examination reconsideration request.

See IRM 20.2.7.5, IRC 6404(e)(1), Unreasonable Error or Delay in Performing a Ministerial or Managerial Act, for additional information.

Form 8697, Interest Computation Under the Look-Back Method for Completed Long-Term Contracts, is required for each year after February 28, 1986, when a taxpayer completes a long-term contract that was accounted for using either the percentage of completion method or the percentage of completion - capitalized cost method for Federal income tax purposes.

Form 8697 is required for any tax year in which the contract price or contract costs are adjusted for one or more of these long-term contracts from a prior year. See IRM 20.2.11.12, Look-Back Interest, and IRM 20.1.3.2.6, Form 8697, Interest Computation Under the Look-Back Method for Completed Long-Term Contracts, for additional information.

Refer to IRM 21.7.4.4.20, Form 8697, Interest Computation Under the Look-Back Method for Completed Long-Term Contracts and IRM 21.7.12.5.8, Form 8697 - Interest Computation Under the Look-Back Method for Completed Long-Term Contracts Overview, for additional information.

Claims contending the taxpayer’s signature was forged or they were not legally married may be referred to campus classification by Accounts Management (AM). See IRM 21.6.1.5.7, Married Filing Joint or Married Filing Separate is Invalid or Filed with Incorrect Status, for exam referral criteria.

Allow claims based on unlawful filings where the marriage was not valid if the following is present:

In accordance with IRC 6064, the taxpayer must prove that they did not intend to file jointly and that the signature was forged. If the claim cannot be allowed, follow selection criteria for field and campus exam for audit referrals. Classifiers should be alert to indications of identity theft on the account. Suspected Identity Theft Category A claim referrals should be returned back to Accounts Management for research and processing as outlined in IRM 25.23, Identity Protection Program. The following subsection contains procedures on identity theft accounts. IRM 4.19.15.37, Multiple Filers, provides guidance for Correspondence exam to process the claim.

Every foreign corporation that is engaged in trade or business in the United States or is subject to tax under Subtitle A of the Internal Revenue Code must file a Form 1120-F, U.S. Income Tax Return of a Foreign Corporation. However, a foreign corporation which at no time during the taxable year is engaged in a trade or business in the United States is not required to file a return for the taxable year if its tax liability for the taxable year is fully satisfied by the withholding taxed at the source under chapter 3 of the Code.

If required to file a return, a foreign corporation that has no gross income for the taxable year is not required to complete the return schedules but:

Form 1120-F returns are filed at the Ogden Campus.

See IRM 21.8.2.2.12, Examination Criteria, for claims and examination referral issues. Amendments to Form 1120-F are forwarded to Ogden and Cincinnati campuses for classification.

Form 1120-IC-DISC, Interest Charge Domestic International Sales Corporation Return, is an informational return and is filed by a domestic corporation that has elected to be treated as an Interest Charge Domestic International Sales Corporation (IC–DISC) and has satisfied the requirements under IRC 992. It is also filed by a domestic corporation that is a former DISC or former IC-DISC. Generally, an IC-DISC is not taxed on its income. Shareholders of an IC-DISC are taxed on its income when the income is actually (or deemed) distributed. See IRM 21.7.4.4.4.11.6, Form 1120-IC-DISC, Interest Charge Domestic International Sales Corporation Return for additional information.

A 1120-IC-DISC is required to make an election using Form 4876-A, Election To Be Treated as an IC-DISC, in order for it to be treated as an IC-DISC. Form 4876-A must be filed within 90 days after the beginning of the tax year if it is the taxpayer’s first tax year. For any tax year other than the taxpayer’s first tax year, the election must be made during the 90 days preceding the first day of that tax year. If the election is not timely filed, then the corporation must file the appropriate corporate (or other) return and pay income tax.

The Form 4876-A election determination is made by Kansas City Submission Processing (SP). A data file is kept by Code and Edit during the processing of these forms. For additional information see IRM 3.11.16.44.1, Form 4876-A and Form 1120-IC-DISC Data File.

Generally 1120-IC-DISC are not subject to tax.

However, the shareholders of an IC-DISC are:

If a corporation files as an IC-DISC but does not qualify as an IC-DISC Kansas City SP initiates correspondence to notify and explain to the corporation why it does not qualify as an IC-DISC. See IRM 3.11.16.45.3, Ineligible Filers.

The Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation, is filed for transfers made after August 4,1997. These forms are considered information returns, and must be filed with the U.S. Transferor’s annual tax return for the tax year that includes the date of transfer.

Returns processed by Submission Processing with Form 926 attached are identified with audit codes. See IRM 3.12.2-6, Audit Codes, and IRM 3.11.3-3, Audit Codes.

Claims filed with a Form 926 are considered Examination International Category A (CAT-A) criteria and are classified by an LB&I International Examiner. See IRM 21.8.1.2.10, Examination Criteria CAT-A International.

SB/SE holds BMF Large Business & International (LB&I) cases in their Accounts Management System (AMS) Correspondence Imaging Inventory (CII) system inventory under referral reason "HQ Reserved 5," (and sometimes other referral reasons related to HQ Reserved 5, such as OARS-HQ Reserved 5) pending review and determination by LB&I Assistant Deputy Commissioner Compliance Integration (ADCCI).

SB/SE holds IMF Large Business & International (LB&I) cases in their Accounts Management System (AMS) Correspondence Imaging Inventory (CII) system inventory under referral reason "HQ Reserved 15," (and sometimes other referral reasons related to HQ Reserved 15, such as OARS-HQ Reserved 15) pending review and determination by LB&I Withholding Exchange and International Individual Compliance (WEIIC).

SB/SE Classification will not work any LB&I inventory housed in CII CAT-A queues under referral reasons related to "HQ Reserved 5" or "HQ Reserved 15" .

SB/SE holds Tax Exempt/Government Entities (TE/GE) cases in their Accounts Management System (AMS) Correspondence Imaging Inventory (CII) system inventory under referral reason "HQ Reserved 18," (and sometimes other referral reasons related to HQ Reserved 18, such as OARS-HQ Reserved 18) pending review by TE/GE.

TE/GE claims are identified by BOD "TE" on IDRS. TE/GE claims must be referred under "HQ Reserved 18." Rare exceptions are outlined in IRM Exhibit 21.5.3-2, Examination Criteria (CAT-A)-General and IRM Exhibit 21.5.3-3, Examination Criteria (CAT-A) - Credits.

SB/SE Classification will not work any TE/GE inventory housed in CII CAT-A queues under referral reasons related to HQ Reserved 18.

SB/SE holds SB/SE Employment Tax (ET) cases in their Accounts Management System (AMS) Correspondence Imaging Inventory (CII) system inventory under referral reasons HQ Reserved 9 and "HQ Reserved 10," (and sometimes other referral reasons related to HQ Reserved 9 and HQ Reserved 10, such as OARS-HQ Reserved 10) pending review by SB/SE ET classifiers.

HQ Reserved 9 and "HQ Reserved 10" claims typically involve high dollar net tax and refundable credit changes on an amended Employment Tax return. See IRM Exhibit 21.5.3-2, Examination Criteria (CAT A)-General.

SB/SE Classification will not work any SB/SE ET inventory housed in AMS CII CAT-A queues under referral reasons related to HQ Reserved 9 or "HQ Reserved 10" .