Articles by Alvin Brown
Offer In Compromise
State Offers in Compromise
IRS Tax Liens
IRS Tax Liens - continued
IRS Tax Liens - continued 2
Levy - continued
Audit Techniques Guide
D.O.J Criminal Tax Manual
Statute of Limitations
Frivolous Tax Argument
Tax Reform Legislation
Trust Fund Penalty
Innocent Spouse Relief
Tax Lien - IRS Lien - Lien Discharge
Lien Filing Requirements
Lien Filing Requirements cont.
Certificates - Claim for Damages
Claim for Damages cont.
Internal Revenue Code 6321
State Law 6321
Internal Revenue Code 6322
Internal Revenue Code 6323
Internal Revenue Code 6324
Internal Revenue Code 6325
Internal Revenue Code 6326
Internal Revenue Code 6320
Internal Revenue Code 6327
Internal Revenue Code 6330
Certificate of Discharge from Tax Lien
Certificate of Subordination of Tax Lien
Lien Notice Requirements and Appeals
Tax Lien Certificate
Action to quiet title
Burden of Proof
Discharge of Bankruptcy
Effect of Partial Abatement
Certificate of release of tax lien
Certificate of Discharge
Claim for Damages
Choate Requirement - State Law
Suit to Cancel Lien
Certificate of Subordination
Effect of Discharge
Notice of Sale
Period of Redemption p1
Period of Redemption p2
Release of Right of Redemption
Scope of Redemption
After Foreclosure Result
6320-Applicability of Statute
6321 - After Aquired Property p1
6321 - After Aquired Property p2
6321 - After Aquired Property p3
6321 - After Aquired Property p4
6321 - Applicability of Statute
6321 - Collection Due Process Hearings
6321 - Annuities
6321 - Bank Deposits p1
6321 - Bank Deposits p2
6321 - Bankruptcy p1
6321 - Bankruptcy p2
6321 - Bankruptcy p3
6321 - Bankruptcy p4
6321 - Bankruptcy p5
6321 - Bankruptcy p6
6321 - Conveyances to Related Parties p1
6321 - Conveyances to Related Parties p2
6321 - Conveyances to Related Parties p3
6321 - Conveyances to 3rd Parties p1
6321 - Conveyances to 3rd Parties p2
6321 - Conveyances to 3rd Parties p3
6321 - Conveyances to 3rd Parties p4
6321 - Community Property p1
6321 - Community Property p2
6321 - Community Property p3
6321 - Employee Pension Plans
6321 - Creation of Lien p1
6321 - Creation of Lien p2
6321 - Creation of Lien p3
6321 - Creation of Lien p4
6321 - Creation of Lien p5
6321 - Debts Owed to the Taxpayer p1
6321 - Debts Owed to the Taxpayer p2
6321 - Debts Owed to the Taxpayer p3
6321 - Debts Owed to the Taxpayer p4
6321 - Debts Owed to the Taxpayer p5
6321 - Debts Owed to the Taxpayer p6
6321 - Escrow Accounts
6321 - Foreign Property
6321 - Forfeited Property
6321 - Fraudulent Conveyances Part1 p1
6321 - Fraudulent Conveyances Part1 p2
6321 - Fraudulent Conveyances Part1 p3
6321 - Fraudulent Conveyances Part1 p4
6321 - Fraudulent Conveyances Part1 p5
6321 - Fraudulent Conveyances Part1 p6
6321 - Fraudulent Conveyances Part1 p7
6321 - Fraudulent Conveyances Part1 p8
6321 - Fraudulent Conveyances Part1 p9
6321 - Fraudulent Conveyances Part1 p10
6321 - Fraudulent Conveyances Part1 p11
6321 - Fraudulent Conveyances Part1 p12
6321 - Fraudulent Conveyances Part2 p1
6321 - Fraudulent Conveyances Part2 p2
6321 - Fraudulent Conveyances Part2 p3
6321 - Fraudulent Conveyances Part2 p4
6321 - Fraudulent Conveyances Part2 p5
6321 - Fraudulent Conveyances Part2 p6
6321 - Fraudulent Conveyances Part3 p1
6321 - Fraudulent Conveyances Part3 p2
6321 - Fraudulent Conveyances Part3 p3
6321 - Fraudulent Conveyances Part3 p4
6321 - Fraudulent Conveyances Part3 p5
6321 - Fraudulent Conveyances Part3 p6
6321 - Funds on Deposit p1
6321 - Funds on Deposit p2
6321 - Funds on Deposit p1
6321 - Homesteaded Property p1
6321 - Homesteaded Property p2
6321 - Homesteaded Property p3
6321 - Insurance p1
6321 - Insurance p2
6321 - Insurance p3
6321 - Insurance p4
6321 - Licenses 2 - p1
6321 - Licenses 2 - p2
6321 - Licenses 2 - p3
6321 - Legal Obligations
6321 - Partnerships p1
6321 - Partnerships p2
6321 - Partnership Property
6321 - Other State Created Exemptions
6321 - Property Rights of 3rd Parties p1
6321 - Property Rights of 3rd Parties p2
6321 - Property Rights of 3rd Parties p3
6321 - Prior Law p1
6321 - Prior Law p2
6321 - Property rights of a nondeclared spouse p1
6321 - Property rights of a nondeclared spouse p2
6321 - Property rights of a nondeclared spouse p3
6321 - Property rights of a nondeclared spouse p4
6321 - Property Seized During Arrest
6321 - Stolen Property
6321 - Rent
6321 - Stock Certificates
6321-Unperfected interests p1
6321-Unperfected interests p2
6321-Unperfected interests p3
6321-Unperfected interests p4
6321-Unperfected interests p5
6321-Tangible property in the taxpayer's possession
6321-Trusts for third parties p1
6321-Trusts for third parties p2
6321-Property transferred during divorce (2) p1
6321-Property transferred during divorce (2) p2
6321-Real property p1
6321-Real property p2
6321-Real property p3
6321-Real property p4
6321-Real property p5
6321-Real property p6
6321-Real property p7
6321-Real property p8
6321-Relinquishments and disclaimers
6332 - Annotations- Exclusiveness of Remedy
6332 - Annotations- Evidence of Debts
6332 - Annotations- Garnishment
6332 - Annotations- Levy and Demand
6332 - Annotations- Insurance Policy 1 p1
6332 - Annotations- Insurance Policy 1 p2
6332 - Annotations- Insurance Policy 1 p3
6332 - Annotations- Insurance Policy 2
6332 - Annotations- Interest and Penalties
6332 - Annotations- Leasehold Interest
Taxpayer's Property in Possession of Thrid Party p1
Taxpayer's Property in Possession of Thrid Party p2
Taxpayer's Property in Possession of Thrid Party p3
6322-Release of liens
6322 - Nevada
5.12.2 Lien Filing
Requirements (Cont. 1)
Mutual Collection Assistance Requests (MCAR)
Procedures for Refiling and Release
International will be responsible for determining
whether to refile these NFTLs and for requesting the
release of NFTLs even though area offices file NFTLs for
Notices of Federal Tax Lien for refiling and
certificates of release will be:
Forwarded to the
appropriate area office for recording.
No TC 582 or TC 360 will be input and no NFTL fees will
be assessed against MCAR taxpayers.
Lien Filing Approval
Revenue officer group managers will note their review and
approval using the manager's queue on their automated
systems for revenue officers below the GS-9 level.
filed by Dyed Fuel Compliance Officers below GS-9 will be
reviewed and approved by a designated Examination manager.
it is necessary that a manual (typed or handwritten) NFTL be
prepared, managers will sign the NFTL for employees below
all cases document the case file.
Approve the NFTL Determination
determination to file a NFTL by revenue officers below
GS-9 must be approved by the manager prior to the NFTL
actually being filed.
Appropriate disciplinary action may be taken against the
employee if review procedures are not followed.
The Manager's Review Process
The manager of revenue officers below GS-9 is required
verify that a
balance is due, and
affirm that the
lien filing is appropriate given the taxpayer's
circumstances, considering the amount due and
the value of the property or rights to property.
In all cases revenue officers must document the
A summary of any
information the taxpayer provides that may
affect the decision to file a lien.
If the taxpayer
provided information, an explanation of the
employee's review and findings; and
the amount is owed, e.g., the balance has been
checked on IDRS.
Consider the following when determining if lien filing
responsiveness to attempts at contact and
about the taxpayer's financial condition;
history of delinquency;
efforts to pay the tax;
taxes are being paid or there are returns not
Whether there is a
lien already filed.
This information must
be clearly marked in the history.
lien fees to file or release manually prepared NFTLs when
the NFTL is forwarded for input.
360 should always appear on a module that has a TC 582
lien filed indicator (LFI) present.
of fees for systemically generated NFTLs is accomplished by
having ALS generate a file to the servicing campus. Files
are generated weekly on Friday and include fees through
close of business Wednesday of the same week.
- A 24
hour delay of the transaction code going to the data file
allows for corrections resulting from quality review of NFTL
listing will generate for TC 360 associated with NMF
accounts. A request for posting MARS must be prepared and
forwarded to the servicing campus on Form 3244, Payment
Reverse the TC 360 when a NFTL is filed in error.
Section 5.12.6, for information regarding billing methods.
Lien Filed Indicator
lien filed indicator (LFI) should appear on any module that
has a TC 582 posted.
lien filed indicator on ALS generated NFTLs will be
systemically input through IDRS to all tax modules that are
included on a Notice of Federal Tax Lien. The LFI is the
primary means by which areas are notified that modules are
satisfied and that a release of the NFTL is in order.
input of LFIs is accomplished by having the automated system
generate and forward a file to the servicing campus. The
file is generated weekly and will include ACS NFTLs to take
advantage of the LFI upload file.
582 is not generated to NMF accounts.
Request input of TC 582 for a lien file indicator and TC 360
for recording fees for all manually prepared liens,
including estate tax liens, if applicable.
Removing LFI Indicators
Whenever an FTL is released, the related LFI must be removed
from IDRS/master file. However, if the balance due is
non-master file and no LFI is present for that module on
IDRS, no action is necessary.
LFI is removed when the automated system generates a file to
the servicing campus for the input of TC 583.
Designated Payment Code
designated payment is a voluntary payment designated by the
taxpayer to be applied in a particular manner, i.e., kind of
tax, specific tax period, etc. These designations are
normally followed by the Service.
the absence of a designation by the taxpayer, payments will
be applied in a manner consistent with the provisions of
Rev. Rul, 2002-26, unless a specific statute, regulation or
procedure designates otherwise.
designated payment code (DPC) is mandatory on all Collection
initiated posting vouchers for transaction codes 640, 670,
680, 690, 693 and 700. DPCs serve three purposes.
They are used to
identify payments that are designated for trust fund
or non-trust fund employment and excise taxes.
DPCs are used to
indicate application of payments for a specific
DPCs also identify the
event which resulted in the payment.
DPC 07 when applying payments secured for the release of a
notice of federal tax lien or to secure a certificate of
discharge or subordination.
The mere fact that a lien has been filed does not
indicate that the payment is due to the filing of a NFTL.
In this case, the appropriate DPC should be used .
Special rules apply in some instances when filing a Notice
of Federal Tax Lien
Actual Notice or Knowledge of Lien Requirement
IRC 6323(l) defines actual notice or knowledge of a FTL.
The burden is on the Internal Revenue Service to show
the existence of actual notice or knowledge whether such
notice is material in determining the priority of a FTL
as against certain competing lien or interest, under IRC
Section 1-201 of the Uniform Commercial Code is cited in
part for your guidance for when a person has knowledge
or received notice.
"(25) A person has "notice" of a fact when:"
"a) he has actual
knowledge of it; or"
"b) he has received
a notice or notification of it;"
"c) from all the
facts and circumstances known to him at the time
in question he has reason to know that it
exists. A person 'knows' or has knowledge of a
fact when he has actual knowledge of it.
'Discover' or 'learn' or a word or phrase of
similar import refers to knowledge rather than
to reason to know. The time and circumstances
under which a notice or notification may cease
to be effective are not determined by this
"(26) A person
'notifies' or 'gives' notice or notification to
another by taking such steps as may be
reasonably required to inform the other in
ordinary course whether or not such other
actually comes to know of it. A person
'receives' a notice or notification when"
"(a) comes to his
"(b) it is duly
delivered at the place of business through which
the contact was made or at any other place held
out by him as the place for receipt of such
Copies of Notices to Third Parties
The Federal Tax Lien (FTL) under IRC 6321 attaches to "
all property and rights to property" of the person or
entity liable for the tax. This very broad statutory
language has been interpreted as including all real,
personal, and intangible property of greatly varying
natures, as well as future interests, and property
acquired by the taxpayer after the lien has come into
Since the FTL attaches to after-acquired property the
FTL may be enforced administratively by levy, that is
use of a levy to collect taxes is not limited to
property or rights to property of the taxpayer that
existed at the time the assessment is made.
The effect of levy on other than wages, salary or other
income is not prospective; that is, service of a levy
upon the taxpayer or a third person, respectively,
results in a seizure of property or rights to property
in possession of either party at the time of service of
levy. Should property come into possession of the
taxpayer or third party following such service, another
levy should be made to seize the property,
notwithstanding the fact that the FTL attaches itself
automatically to such after-acquired property.
In order to establish uniformity in giving the required
actual notice or knowledge, a copy of the appropriate
NFTL will be delivered to the person(s) requiring the
copy of the filed NFTL should be furnished to an
insurance company to meet the actual notice requirement.
Cost of Living Adjustment
those tax lien interest designated as "Superpriorities, "
RRA 98 provides that for tax years beginning in 1999 and
thereafter, the higher exemption amounts will be indexed
annually for inflation (consistent with the cost-of-living
adjustment (COLA) amounts for the applicable tax year) and
rounded to the nearest multiple of $10. See 5.17, Legal
Disclosure of Outstanding Lien Amount
Delegation Order 156 for a list of employees authorized to
disclose information concerning the amount of the
outstanding obligation secured by the NFTL. Disclosure may
be made to any person who demonstrates that he/she possesses
a right or intends to obtain right in the property. See IRM
11. 3.1.10, Disclosure of Amount of Outstanding Lien.
Employees listed in Delegation Order 156 have the authority
to determine whether or not to disclose the requested
information under the authority of IRC 6103(k)(2).
person, other than the taxpayer or their designee, desiring
information as to the amount of the outstanding obligation
in order to decide whether to acquire the property covered
by the NFTL (when a NFTL has been filed) must submit a
written request stating the reasons the information is
desired and properly identifying the NFTL in question. A
prospective purchaser should attach a copy of the sales
contract or a lender a loan application.
requested information will be furnished using Letter
1038(DO), Response to Inquiries About Release of Federal Tax
Disclosure to Escrow and Title Companies
When a completed Form 8821, Taxpayer Information
Authorization, is provided, employees designated the
authority to execute Forms 668(Y), may disclose the
amount of the outstanding obligation secured by the NFTL
to escrow agents, title companies, lending institutions,
etc., (See IRC 6103(c)).
The Form 8821 must be completed prior to the taxpayer
signing it and should authorize disclosure of lien
information on the specific piece of property for sale.
The following information should be provided:
identity information, i.e., name, address,
taxpayer identification number, or any
combination of these three.
The information to
be disclosed, for example, the amount shown on
the NFTL, including the address of the real
property subject to the filed NFTL.
The identity of the
company or escrow agent authorized to receive
the information. It is not necessary to name an
signature and date.
It is not necessary
to specify tax type or tax year.
Taxpayers may also authorize disclosure telephonically.
Verify the taxpayer's identity using approved functional
procedures and document the information in writing.
The information to
be disclosed; for example, the amount shown on
the NFTL, including the address of the property
subject to the NFTL.
The identity of the
escrow agent or title company authorized to
receive the information.
The date of the
consent. For example, "John Doe on 03/05/03
consents to disclose the payoff of all filed
NFTLs on 134 Maple Boulevard to XYZ Title."
Disclosure of lien information not subject to a filed
NFTL should not occur without obtaining the taxpayer's
authorization either orally or in writing. Obtain and
document the information referred to (4) above.
In situations where the taxpayer's authorization cannot
be obtained, seek advice from area counsel; for example,
if a taxpayer is medically incapacitated, is on vacation
outside the U.S. and cannot be reached, etc.
Refiling the NFTL
Refile the NFTL to maintain the continuity of priority
established by the original lien filing when the collection
period is extended.
Consider refiling the NFTL if the statute date has been
extended or suspended by any action within the required
the form used
for the original refiling was earlier than
failure to file
at the appropriate time does not affect the
validity of the filing. However, it does
nullify the effect of the prior filing.
Federal Tax Lien are filed on forms revised
on 12/1982 or later
"self-releases" unless timely refiled. These
forms are considered as both a NFTL and a
Potential Refile Report generated by the ALS will be worked
monthly. See IRM 5.12.6. for additional guidance.
Release of the NFTL is conclusive that the underlying,
statutory FTL is extinguished. Follow procedures in IRM.
5.12.3 for revocation and reinstatement procedures.
applicable, ALS Units will route the appropriate information
to the unit or employee responsible for the case for a
Collection Technical Services will make refile
determinations for CNC mandatory follow-up and ACS cases.
Designated employees in the Automated Collection System Unit
are responsible for NFTL refiling on active ACS cases.
Requests for refiles will be input through ALS.
Criteria for Refiling
Before any NFTL is refiled, each assessment should be
examined to determine that the statutory period for
collection has been suspended or extended beyond the
normal ten-year period beginning with the assessment
The normal collection statute may be suspended or
Execution of Form
900, Tax Collection Waiver
Offer in Compromise
(prior to 01/012000).
Assets of taxpayers
in custody of a court in certain types of
Judgment for the
Absence of taxpayer
from the United States continuously for six
suspending or extending the collection statute.
The extension of the statutory period for collection
does not mean that a NFTL must be automatically refiled.
Each case should be analyzed regarding present and
future assets to which the refiled NFTL might attach.
The present balance still due on the FTL would be
another factor to be taken into consideration.
Required Refiling Period
The time period for refiling the NFTL has a starting and
ending date. Therefore, a refiled Notice of Federal Tax
Lien is invalid if it is filed after the period for
The refiling period lasts for one year. For the first
refiling, the period begins nine years and 30 days from
the date of the assessment and ends 10 years and 30 days
from the date of assessment. For example, if the
assessment date is 3/1/85, the first refiling period
3/31/94 - 3/31/95. For subsequent refilings, each period
begins nine years after the end of the previous refiling
period and ends 1 year later. An example using the first
refiling period above is that the second refile period
would be 3/31/04 - 3/31/05.
The following is an example of the "Required Refiling
Period" On March 1, 1985, an assessment of tax was made
against A, a delinquent taxpayer, and a FTL for the
amount of the assessment arose on that date. On July 1,
1985, a NFTL was properly filed. The NFTL filed on July
1, 1985, is effective up to and including March 31,
1995. The first required refiling period for the NFTL
begins on April 1, 1994, and ends on March 31, 1995. A
refiling of NFTL during that period will extend the
effectiveness of the NFTL filed on July 1, 1985, up to
and including March 31, 2005. The second required
refiling period for the NFTL begins on April 1, 2004,
and ends on March 31, 2005.
For calculations of the required refile period see
Place for Refiling
During the required refiling period, the NFTL is to be
In all cases in
every office in which a prior NFTL (including a
refiled notice) was filed, and
In the proper
office in the State where a new residence is
located, if, 90 days or more prior to the date
of refiling, the Service receives written
information concerning a change in the
residence is located outside the United
will be made in the District of
Columbia. This refiling is extremely
important in the case of personal
property. If it is not accomplished as
and when required, all other refilings
one written notice of change of address
is received on or before the 90th day.
recent one will be used for purposes of
refiling, whether or not the taxpayer
resides there on the date of refiling.
Address Change Procedures Affecting Refiling
Except as provided below, a notice of change of a
taxpayer's residence will be effective only if it is
received in writing from the taxpayer or his/her
representative (Form 8822, Change of Address), relates
to an unpaid tax liability of the taxpayer, and states
the taxpayer's name and the address of the new
The notice of change of a taxpayer's residence will be
effective if it is contained in a return or amended
return of the same type of tax filed with the Internal
Revenue Service by the taxpayer.
The return or amended return must indicate that it is a
change of address and correctly state the taxpayer's
name, address of present residence and identification
number required by IRC 6109.
Other than the means specified above, no communication,
either written or oral, will be considered as notice of
a change of a taxpayer's residence.
Procedures and Responsibilities for Refiling
Under normal circumstances, the Automated Lien System
(ALS) should be used.
At times, circumstances may exist that do not allow time
for a refiled NFTL to be created through ALS. In these
cases Form 668F should be prepared as shown in Exhibit
ALS Units will print the Potential Refile Report and
forward information on suspended cases to the
appropriate function or employee for a refile
determination. ACS and Form 53 mandatory follow-up
determinations will be made by Collection Technical
Prior to refiling, all balances must be updated to
reflect the current unpaid balance of assessment,
Satisfied modules should not appear on a refiled NFTL.
NFTL is prepared through ALS
automatically not include any satisfied
assessed amount has been paid,
unassessed accrued amounts remain
total amount of the accruals as of the
date the refiled NFTL is requested.
These amounts should be shown in column
(f). Line through the words Unpaid
Balance of Assessment and write in
there us a
diminimus amount due on the assessed
balance and unassessed accruals
total amount owed plus accruals as of
the date the refiled NFTL is requested.
Line through the words Unpaid Balance of
Assessment and write in Outstanding
Notice of Federal Tax Lien lists more
than one liability, and the assessment
dates are different,
NFTL should list only the period(s)
which meet the criteria for refiling.
multiple assessments within the same
period, and the refile periods are
be taken to only enter the balance for
the assessment(s) being refiled. The
Automated Lien System (ALS) will allow
refiling of each specific assessment.
668(Y) was filed in a given
jurisdiction, but because of a change of
residence a NFTL is to be refiled during
the refiling period in another
668F for refiling, even though Form
668(Y) was never filed in that
ALS will allow NFTLs to be refiled when the statute has
expired against one person on a joint assessment.
Release of Refiled NFTL
The Form 668F, used to refile a NFTL, is not
self-releasing. File a certificate of release when an
extended statutory period for collection has expired.
Filing Form 668Z, Certificate of Release of Federal Tax
Lien, will extinguish the NFTL and remove all notices
from the record. Each refile, amended or corrective
associated with an original NFTL must be identified on
the certificate of release.
Original Notice of Lien After Refiling Period
Occasionally it is necessary to refile an original NFTL
after the end of the first refiling period. The ALS
system will prompt you for the CSED. When the NFTL
document is printed, ALS will print "N/A" in the "last
day for refiling" block.
Resolution of NFTL Related Unpostable Transactions
are a number of reasons why transactions do not post. Below
we discuss the unposted transaction and how it should be
End of Day (EOD) List
Weekly an upload is made to the Campus of all
transaction codes (TC) 582 and 583 for the previous
week's created and released Notices of Federal Tax Liens
(NFTL). These transactions are input to the Integrated
Data Retrieval System (IDRS) and trough End of Day (EOD)
processing. EOD processing is the first validity check
that is performed on any transaction attempting to post
TC 582 and 583 transactions which drop from EOD
processing will appear on an EOD control list. This list
will be used by the area office to make appropriate
corrections to allow the transaction to be reinput.
EOD control lists are created in Campus computer rooms
and forwarded to the Compliance Services Collection
Operations (CSCO) function. CSCO separates the records
by area office and forwards the list to the Lien
Processing Unit manager in the appropriate area.
Areas will review the dropped transactions, determine
the reason the transaction dropped and take necessary
corrective action to reinput. The most common errors
will be name control/TIN and MFT/period mismatch, much
The list will show the following:
that the record dropped from processing.
reason the record dropped.
following data fields marked:
Taxpayer Identification Number
Masterfile Tax (MFT)
Transaction Code, and
Area offices will receive a Nullified Distribution List
from the Campus for resolution weekly. This a list of TC
582 which have not posted.
Computer generated source documents for unpostable TC
360 will also be received weekly. TC 360 will not come
to the area office on a nullified distribution list.
Unpostables will be worked within 5 workdays of receipt.
The most common unpostable conditions are TIN/name
control mismatch. Some of the reasons these conditions
an input document
was prepared incorrectly or data was transcribed
The NFTL request
was prepared with in correct information and
generated an incorrect systemic transaction
Correcting the Unpostable Condition
To correct the unpostable condition, do the following:
Check the ALS to
determine if the information on the unpostable
record matches the corresponding information on
the ALS NFTL record.
appropriate corrections to the unpostable and
reinput the transaction code with the correction
information, if the information on the
unpostable does not match.
Check IDRS and/or
master file to attempt to determine what the
correct information is if the information
unpostable record with the correct information.
If the ALS NFTL
record is incorrect, refer to IRM 5.12.6 for
correcting NFTLs for the appropriate
Take no further
action to correct unpostable for TC 360
transaction ONLY, with an unpostable code of 197
(IMF) and unpostable code 347 (BMF). These
transactions unposted because the TC 360
attempted to post to an inactive account.
Reinput the income TC 360 unpostables and remove
any UPC 197 and UPC 347.
Close the open IDRS
control base as part of the resolution process.
CSCO will send Technical Services a Case Control
Age List Weekly of Technical Services cases by
IDRS employee number and age of case. This
listing may be used by Technical Services as a
monitoring device that open control bases are
being closed timely.
will receive Accounts Maintenance Transcripts
reflecting a TC 360 and there is no liability
open on the module where the TC 360 posted. It
should not be assumed that the TC 360 is
automatically a NFTL fee. Upon receipt of the
transcripts, do the following:
Research ALS to
determine if the NFTL was filed for the taxpayer
entity on the transcript.
Input TC 582 if
necessary and correct the TC 360 posting if the
NFTL is found for this entity.