4.25.2. Campus Estate and Gift

(1) If needed, secure the original return. Only secure the original return from Files if a copy is not provided or the original figures cannot be verified using available command codes, such as CC BRTVU or BMFOLR.

(2) Math verify the return using the approved E&G Microsoft Excel computation tool.

(3) Refer math verified decreases of ≡ ≡ ≡ ≡ ≡ ≡ ≡ or more to a TTT who will make the determination or refer to the Campus ETA. If the amount is below tolerance, continue processing for adjustment.

(4) If the amended return is filed to correct a math error, follow IRM 21.5.4, General Math Error Procedures. These amended returns should not be referred to a TTT or ETA to correct the math error.

(5) Use the IF/THEN chart below to determine appropriate case action:

(6) If account is restricted, adjust interest, and/or penalties as necessary. See IRM 20.2.1.4.2.1, Manual Calculation of Interest - Documentation, for more information.

(7) Attach/Associate the amended return to the TC 421 (controlling Document Locator Number (DLN)) using Form 10023-B, Attachment, or Form 9856, Attachment Alert.

(1) Math verify the return using the approved E&G Microsoft Excel computation tool

(2) If the amended return is filed to correct a math error, follow IRM 21.5.4, General Math Error Procedures.

(3) Use the IF/THEN chart below to determine appropriate case action:

(1) If the abatement will not be allowed:

• A Form 5706, Case History Sheet, is required on all penalty abatement cases, and must document the reason for denial.

• Input a TC 290 for zero, BLK 98/99 and Reason Code (RC) 062, HC 3 and, if appropriate, Priority Code (PC) 1.

• Prepare Letter 854-C, Penalty Waiver or Abatement Disallowed/Appeals Procedure Explained.

• Attach to the abatement request document, a copy of the Letter 854-C. Use the letter and the history sheet as the adjustment source document.

(1) Input the appropriate transaction codes to reverse the penalty in full or in part. Hold all information until the adjustment posts.

• Form 5706, Case History Sheet, is required on all penalty abatements and must document the reason for approval.

• If the account still shows a balance due on an international account, refile the documents in the international monitoring file.

(2) Form 843, Claim for Refund and Request for Abatement: Refer to IRM 21.5.3.4, General Claims Procedures, for claim procedures.

(1) Due to the processing time of Form 706, it is possible that a closing letter request may be received prior to SOI scanning and WSD classification.

(2) A closing letter may be issued when a TC 421 has not posted if the following conditions are all met:

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(3) If screening criteria is met, continue monitoring the closing letter request for the TC 421 to post.

(1) Follow procedures in the following table for Transfer Certificate Requests received from Nonresident Citizen of the U.S. (NR-C):

(1) Follow procedures in the following table for Transfer Certificate Requests received from Nonresident Not a Citizen of the U.S. (NRNC):

(1) All Form 4768 must be date stamped upon receipt, sorted by type, and batched.

(2) Clerks will sort and batch extension requests as follows by looking at Form 4768, Part IV Line 3:

• Extensions reflecting money

• Extensions reflecting no money (balance due)

(3) Extensions will be batched and assigned upon receipt. Each batch will be:

• Numbered and contain up to 20 documents

• Entered on the spreadsheet reflecting the date, batch number, and volume

(4) Time frames to Complete Batched Work - Complete all work within the following response times from E&G received date:

• Extensions to File and/or pay with no payment will be approved or denied within 20 calendar days (30 calendar days during filing season February-April)

• Extension to Pay reflecting money owed - 8 calendar days

(5) Assignment of Work - Before distributing the extensions to the employees, the managers will maintain a spreadsheet to track the following:

1. Number of extensions per batch,

2. Batch number, and

3. Name of assigned employee.

(1) Standard Procedures for all Extensions to File and/or Pay:

• All extensions must be screened for accuracy.

• The entity must be established on IDRS before the extension can be processed.

• Specific transactions must be input on IDRS to reflect the appropriate outcome.

• Extensions to pay and denied extensions to file must be added to the extension database.

(2) Screening - All Forms 4768 will be screened as follows:

• Verify the form is timely filed

• Verify signature

• Verify SSN

• Verify Date of Death

• Check for cash shortage (reference IRM 5.5.5.4, Processing Responsibility of Forms 4768, Application for Extension of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes). Follow up on indications of payment to ensure posting before determining a cash shortage.

(3) Additional Screening for International Extensions:

• Check that entity is established,

• If entity not established, research IDRS with command codes NAMEE/NAMEI for a SSN or a previously filed IRSN.

• If no SSN or IRSN found, obtain IRSN by preparing Form 9956, Request for Temporary SSN and E-Fax to Entity at ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡. Entity will E-Fax the assigned IRSN for the estate. Correspond with Estate informing them that an IRSN has been assigned for the estate to use for filing Form 706-NA and all other correspondence. See IRM 3.13.2.7.4.1, Internal Revenue Service Numbers (IRSNs), for more information on requesting IRSN.

(4) International Extensions to File:

• Grant six months extension if the estate does not specify a length of time for the extension.

• Grant an additional six-month extension if the estate correspondence advises the executor is out of the country and is requested before the expiration of the extended due date.

• Verify that a statement is attached explaining in detail why the Form 706-NA cannot be filed by the due date.

(1) Applications that meet the criteria below must be sent to the Advisory Estate Tax Lien (ETL) group for consideration. Due to the 30-day period to reply to the taxpayer on their application, the applications and attachments must be e-faxed to Advisory ETL group within 3 business days of assignment to a tax examiner.

• All requests for extension to file and pay involving unfiled tax returns in which the estate anticipates a cash shortage to pay taxes that will become due ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ will be sent to Advisory ETL group for approval consideration.

• Extension requests on unfiled returns, where the estate sends payment of the estimated liability with the request (payment and estimated tax are equal), will not be sent to Advisory ETL group; requests where the estimated tax is not paid will be sent to Advisory ETL group if the estimated liability ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡.

• All requests for extensions to pay on accounts in which the tax return has been filed and reflect a balance due ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ will be sent to Advisory ETL group.

• All extensions to pay where it is the third request, regardless of the dollar amount, will be sent to Advisory ETL group.

• All requests for extension of time to pay annual installments that are deferred under IRC 6166 will be sent to Advisory ETL group.

(2) Forwarding Extension to Pay to Estate Tax Lien (ETL) Group:

• Campus E&G teams will work Form 4768 extensions within one day.

• All extensions to pay (ETP) meeting Advisory ETL group criteria will be assigned to a TE and controlled on the extension database.

• The extension to pay will be e-faxed daily to Advisory ETL group. Send Letter 5986, Form 4768 Sent to Advisory, to executor/POA.

• The Advisory ETL group e-fax number is ≡ ≡ ≡ ≡ ≡ ≡ ≡.

• Each Form 4768 and attached correspondence will be e-faxed with a separate two-way transmittal, notating the name and e-fax number of the sender (TE).

  Note: For second request and beyond, include a copy of the Letter 2568-C, Follow-up for Installment Billing & Section 6161 Balance Due Billing: Form 706, in the submission to Advisory.

• The TE will schedule a follow up in the extension database for 45 days from the date the Form 4768 was e-faxed to Advisory ETL group. If after 45 days a response has not been received from Advisory ETL group, the TE will contact Advisory ETL group to inquire who the Form 4768 is assigned to and status of the Form 4768 request. A new follow up date should be noted in the extension database.

• The same day ETP is closed, Advisory ETL group will send a copy of the letter mailed to the taxpayer and page two of the Form 4768, or a copy of Form 4768-A, Reply to Request for Extension of Time to Pay U.S. Estate Taxes, to the examiner listed on the transmittal by e-fax. The E&G examiner will input the TC 468 on IDRS and update the extension database within three days of Advisory ETL group’s response.

• E&G managers will monitor the extension database to ensure timeframes are met.

• When the account is full paid and AIMS is closed, the campus will associate the closed extension file with the Form 706 tax return.

(1) A request for extension to pay can be made for:

• The amount owed with the original return, or

• An audit assessment, or

• An IRC 6166 annual installment amount due.

(2) All extension to pay requests are entered into the extension database.

(3) Any extension to pay request that doesn’t have an accepted reasonable cause statement will be allowed an additional fifteen (15) calendar days to provide this statement.

(4) The employee reviewing the extension to pay request will:

• Send Letter 5989, Form 4768 Missing Information, to the executor requesting the additional information needed, and

• Document the extended time allowed in the case history.

(5) International Extensions to Pay:

• Generally the same length of time is given as the extension to file, making it reasonable to expect the executor will know the tax liability and liquidity of assets by the end of the six month period.

• Allow twelve months due to the executor being out of the country if a filing extension was granted for the same time period.

(6) For additional information concerning extension of time to pay estate tax see:

• IRM 5.5.5.2, Section Overview Request for Extension of Time to Pay Estate Tax

• IRM 5.5.5.4, Processing Responsibility of Forms 4768, Application for Extensions of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes

• IRM 5.5.5.5, Evaluating Requests for Extension of Time to Pay

• IRM 5.5.5.8, Approval of Requests for Extension of Time to Pay

(7) The table below shows the IDRS command codes and the actions to take for researching extensions and establishing the entity if needed.

(8) Allowing and Denying Extensions: The IF/THEN table below shows the extension processing inputs for IDRS Command Code REQ77.

(9) Tax on Return - A request for an extension of time to pay is made on Form 4768 and should contain a detailed written statement explaining why the estate can’t pay the full amount of tax by the return due date.

1. In lieu of filing Form 4768, the application for extension of time to pay shall be in writing, state the period of extension requested, and include a declaration that it is made under a penalty of perjury.

2. Any extension for time to pay will not be considered by the Service unless the extension is applied for on or before the date fixed for payment of tax.

(10) Tax on Deficiency:

1. The extension to pay request may be made on Form 4768 or by letter. The request must show there is reasonable cause to extend the payment date. Verify that the statement of reasonable cause is attached.

2. The extension for time to pay may be granted for a period not to exceed 4 years from the date fixed for payment of the deficiency, for up to one year at a time.

3. To be considered, the extension application must be filed on or before the date fixed for payment of the deficiency billed.

4. The extension shall not be granted if the deficiency is due to negligence, or intentional disregard of rules and regulations, or fraud with intent to evade tax.

5. Extensions with a cash shortage ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ are sent to Advisory ETL group.

(11) IRC 6166 Annual Installments:

1. The extension for time to pay must be filed on or before the due date of the annual installment to be considered.

2. The procedures for processing annual installment extensions are similar to procedures for processing IRC Section 6161(a)(2)(A) extensions. The main difference is interest and penalty amounts are computed on the unpaid installment amount instead of the unpaid total tax due.

3. ALL extension requests for IRC 6166 annual installments are sent to Advisory ETL group for consideration.

(12) Reasonable Cause - See IRM 5.5.5.5, Evaluating Requests for Extension of Time to Pay.

(13) Case Monitoring:

• If the initial extension to pay date is different from the initial extension to file date, a case file must be set up and manually maintained for any future actions such as interest, penalty adjustments and manual billing.

(14) The table below shows the steps for monitoring extension cases with different extension to file and pay dates:

(15) A subsequent additional extension of time in which to pay may be granted for reasonable cause per Treas. Reg Section 20.6161-1(a)(1). The following actions are needed:

• Extension should be to a stated date on the Form 4768.

• File should be notated and transferred to the IRC 6161 file.

• File should be filed chronologically by the new date, and

• Attach a copy of the document granting the additional extension.

(16) If notification of denial is received from the Advisory ETL group, compute penalty from the payment due date to the date of payment or to the date of Notice and Demand. Input TC 270 on IDRS.

(17) If extension is terminated, input TC 489 to remove the account from the deferred status.

(18) Manual Billing: A manual billing is done on extension accounts that are in status 14. It may be necessary to cross-reference extended payment dates for billing purposes when the approved Form 4768 is received as follows:

• Annotate the new extended payment date shown on Form 4768, Part III, and

• Establish a filing system for the extension to pay cases in chronological order per the approved extension date.

(19) The manual billing process is initiated four weeks in advance of the extended payment date as follows:

1. Compute interest at the existing rate from the return due date to the extended date, applying payments as necessary.

2. Input TC 340 on IDRS to assess interest.

3. Prepare and mail Letter 6335, Estate Installment Program, or Letter 2568-C, Follow-up Letter for Installment Billing and Section 6161 Balance Due Billing: Form 706.

(20) Missing Payments: If an extension indicates a payment was sent (green rocker) but not on IDRS:

• Input on extension database the Form 4768 data and a history item of what the green rocker shows as a payment.

• Check IDRS for payment.

• Research RTR for payment.

• If payment not found, contact estate representative to verify a payment was sent.

• ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡, follow the criteria in IRM 4.25.2.8.2.3, Extension to Pay Sent to Advisory Estate Tax Lien Group for Processing. Send to Advisory ETL group (even if payment hasn’t posted), noting the amount of misapplied funds that will be moved to the account.

(21) CP 191 Payment Notification: When a payment is received, and posted to the account on BMF, a CP 191 Notice will generate (Code 2). For list of CP 191 codes and definition see IRM 4.25.2.8.1, Understanding Estate Accounts. The payment should include the tax amount in full and interest accrued from the due date of the return. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ Input TC 340 on IDRS to assess additional interest, if applicable.

1. Research IDRS or NMF for potential misapplied payments and/or additional extensions of time to pay.

2. If the extension has expired and no payments or additional extensions are found, compute interest from return due date to the 23C date, taking into consideration any payments made on the account. See IRM 20.2.10, Interest on Estate, Excise, Employment, and Foreign Taxes, for computation of interest. Input TC 340 for any interest that has not yet been assessed and a hold code zero. Compute FTP penalty from the extended date of payment to the 23C date. Input TC 270 on IDRS to assess the penalty. Input TC 489 to terminate deferred status.

3. When the penalty and interest transactions post on IDRS, a computer-generated notice will be issued to notify the taxpayer of the balance due. When CP 191 is received showing TC 270, TC 340, and TC 489 have posted, associate with the original Form 4768 case file and close the case. If an additional extension of time in which to pay was granted, change the extended payment date on the 4768 case file accordingly.

4. Attach a copy of the document authorizing the additional extension and refile the case according to the new extended payment date.

(22) Taxpayer Extension Correspondence - Taxpayer correspondence may be received indicating that an extension under IRC Section 6161 was requested, but IDRS notices are still being sent to them.

• Research account for TC 460/468.

• Input STAUP for nine weeks to stop collection activity.

• Check extension database. If extension is listed on the database, but not on IDRS, then update IDRS with TC 460/468.

• If extension is not on IDRS or the database, request from the taxpayer a copy of the submitted Form 4768 and proof of timely mailing.

• Once the extension is received with timely proof of mailing, follow the table in paragraph (22) below for allowing and denying extensions.

(23) The IF/Then table below shows what action the TE should take for allowing and denying the timely filed extension.

(24) Retention:

• Form 4768 is held for at least one year past the approved extension to pay date. If Master File indicates there is no liability on the account or the account is in Tax Delinquent Investigation (TDI) or Tax Delinquent Account (TDA) status, no further action is necessary.

• If extension requests for time to pay under IRC Section 6161 have been appealed, denied by Advisory ETL group or there is a balance due on the account, follow instructions in the table above. See IRM 4.25.2.8.2.4, IRC 6161 Extension of Time to Pay and Extensions to File. Associate the file with the original Form 706 document (controlling DLN).

• Form 4768 extension to file can be destroyed after the posting of the TC 460 and TXMOD history is documented.

(1) An application for an extension of time to pay certain tax liabilities under IRC 6161 is made by timely filing Form 1127, Application for Extension of Time for Payment Due to Undue Hardship. The types of taxes for which an extension to pay requested on Form 1127 are listed in the instructions to the form. These include income taxes, gift taxes, and certain excise taxes.

(2) See IRM 5.1.12.26, Form 1127 Application for Extension to Pay Due to Financial Hardship, for additional information.

(3) The E&G unit will determine whether the application is processable in accordance with the guidelines provided in IRM 5.1.12.26, Form 1127 Application for Extension to Pay Due to Financial Hardship. Applications that are determined non-processable may be signed by the E&G unit manager and returned to the taxpayer along with a cover letter explaining why the application is non-processable. If it is determined that the application is processable, the following steps will be taken within seven calendar days of receipt:

• Establish an entity under MFT 51.

• Document the TXMOD history with the date the application was received and the date it was forwarded for consideration.

• Forward the application and supporting documents to the Advisory ETL Group.

• Monitor the account for the approved application, reverse the TC 470 when necessary, and abate the FTP penalty if assessed for the period the extension was granted.

• Associate a copy of the application and the cover letter sent to the taxpayer with the related Form 709 tax return.

(4) Applications from the Advisory ETL Group:

• Denied applications from the Advisory ETL Group will include copies of the denied application and the cover letter sent to the taxpayer. Document the TXMOD history that the extension request was denied.

• Approved applications from the Advisory ETL Group will include copies of the approved application, cover letter sent to the taxpayer, and a Form 4844, Request for Terminal Action, requesting the E&G unit to input a TC 470, no closing code, for the appropriate number of cycles, and a TC 270 for $0.00. Document the TXMOD history that the extension request was approved and the new extension date.

(1) WSD Review: Forward the 6163 request to WSD National Gatekeeper electronically for review. WSD will determine if the election is approved for 6163. Once Campus E&G receives the case back from WSD, proceed to (4).

(2) General Information:

• Field Exam analyzes the election and works with Counsel to secure the bond. Counsel ensures that the language of the bond is sufficient. Once the bond is secured, it is sent to Advisory ETL for safekeeping.

• Campus monitors the election case file and issues annual letter to estate to ensure that the condition precedent hadn’t been triggered.

• Advisory ETL group stores the bond (like they do for other collateral agreements.) Once condition precedent is triggered, they start collection proceedings. Campus lets Advisory ETL group know that the condition was triggered and the freeze code expired.

(3) See IRM 4.25.14.2.4, Estate Tax Extension of Time to Pay - IRC 6163, and IRM 4.25.11.11.5, Preparing Agreed Case with 6163 Election Case File for CCP, for additional information.

(4) Campus Process - Prepare a folder notating the following:

• Estate’s name, and

• Received date of the return, and

• Date request was referred to Field Exam.

(5) The folder will be placed in temporary suspense in front of other extensions granted under IRC Section 6163 and then do the following:

1. Forward the request to Field Exam along with a copy of the return.

2. Forward a copy of the return to Advisory ETL group with a note indicting an election under IRC Section 6163 by the estate.

3. Approximately 90 days after the return received date, verify receipt of Form 2276, Collateral Deposit Record.

   Note: Collateral is equal to twice the amount of tax deferred under IRC Section 6163.

4. If the collateral is on deposit with the Advisory ETL group, annotate case file "Form 2276 Received reflecting collateral secured" and file by received date in a separate IRC Section 6163 folder.

5. Put on extension database with notation 6163 extension with annual follow-up date.

6. Input TC 488.

7. Pending termination of the precedent interests (surviving heirs) at a future unknown date, no further collection or follow-up action is required other than annual letter. The file becomes essentially informational.

8. If Form 2276 has not been received, contact the responsible Advisory ETL group to determine the required collateral status. If the Advisory ETL group did not receive the required collateral, advise the Revenue Officer and the taxpayer in writing that the election of an extension under IRC Section 6163 is not valid. Terminate the extension. Reverse the TC 488 with a TC 489 to remove the account from deferred status.

(1) Per IRC 6166(a)(1), an executor may elect to pay all or a portion of the estate tax attributable to a closely held business in two (2) or more equal annual installments.

(2) To qualify for annual installments:

1. Decedent was a citizen or resident of the United States on the date of death.

2. The value of the decedent’s interest in a closely held business must exceed 35 percent of the adjusted gross estate.

3. A timely filed return including a timely IRC 6166 election request was filed.

(3) An interest in a closely held business is defined as:

1. A proprietorship that carries on a trade or business.

2. An interest in a partnership that carries on a trade or business. Deceased partner’s interest must be 20% or more of the total capital interest in the partnership or the partnership has 45 or fewer partners.

3. Stock in a corporation carrying on a trade or business if 20% or more of the value of voting stock of the corporation is included in the gross estate or the corporation has 45 or fewer shareholders.

(4) Deferred tax is the amount of estate tax owed that is applicable to a closely held business if the installment request is approved.

(5) Non-deferred tax is all other tax owed on the balance of the estate.

(6) Estates with approved IRC 6166 installment, must certify each year that the assets associated with the closely held business are intact, or explain the changes, to ensure the qualification for installment still exists. This is called a Certification of Unchanged Status. This certification is sent with the annual bill and must be signed under penalty of perjury.

(7) Monitor for TC 150 and status 14. If account is not in status 14, input TC 488 provided the TC 150 posted.

(1) Installment elections or requests are filed with the original Form 706. The return with the installment election is referred from Submission Processing to E&G to ensure prompt processing of the requested installment before the return is processed.

(2) Occasionally, Submission Processing fails to refer installment requests to E&G. These are known as missed elections. Missed elections are found through the following:

• Taxpayer correspondence, or

• Generated CP 191, or

• Classification of the return

(3) In addition to the pre-and post-processing of installment requests, installments are received from the field due to an audit adjustment.

(4) Submission Processing identifies IRC 6166 installment requests:

• On Form 706, Part 3, Number 3, if the Section 6166 box is checked "yes" or installments, Code and Edit codes the return and rejects to Error Resolution System (ERS).

• ERS sends the Form 706 to SOI to be scanned. After the documents are scanned ERS notifies E&G via email at *SBSE Estate & Gift 6166 once the return is available for viewing. Designated employee prints necessary documentation for 6166 set up.

(1) The designated employee assigns IRC 6166 installment set-ups to the teams using the employee assignment listing.

(2) The Form 706 is entered on spreadsheet including the date received, date received from ERS or the date notified of a missed 6166 election set up and the team the case is assigned to.

(3) There is a ten-day turn around (two work weeks) for returning Form 4349, Computation of Estate Tax Due with Return and Annual Installment, and completed spreadsheet to processing.

(1) The following must be verified for an estate to qualify for an IRC 6166 installment:

• Timely filing of Form 706 estate tax return and IRC 6166 installment election request.

• Decedent was a United States citizen or resident on the date of death.

• Value of interest in closely held business must meet or exceed 35% of the adjusted gross estate.

• SSN on Form 706 belongs to the decedent.

• DOD on INOLE.

• POA on CFINK.

  Note: If POA not on file, fax signed Form 706 pages one and two or Form 2848 to the appropriate CAF unit as found in Form 2848 instructions.

(1) Review the IRC 6166 election. This election must be made with a timely filed Form 706. A statement must be attached to the Form 706 with computations indicating the deferred tax, non-deferred tax and the value of the closely held business amount with a list of the schedules showing the amounts of what makes up the closely held business.
The above statement should include the following information:

• Decedent’s name and SSN.

• Amount of tax to be paid in installments.

• Date selected for the first installment payment.

• Number of annual installments in which the estate tax is to be paid. This includes the first installment payment.

• Properties shown on the estate tax return which constitute the closely held business interest and are identified by schedule and item number.

• Facts that formed the basis for the executor’s conclusion that the estate qualifies for estate tax installment payments.

  Note: See Treas. Reg. 20.6166–1(b), Time and Manner of Election, which provides information necessary for the Notice of Election.

(2) Non-deferred tax must be paid by the return due date unless the estate has an extension of time to pay under IRC 6161.

(3) Math verify the Form 706 by completing the Computation of Estate Tax Worksheet (Excel program located in the E&G common drive) to verify tax computation per return. If there is a math error, correct in red ink on return.

(4) ≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

(1) Research IRC 6166 installment for correctness. Verify the IDRS information is the same as the information on the Form 706 by using IDRS CC INOLES to check decedent’s SSN, name and date of death.

(2) If the decedent’s information is not on file, establish the entity using CC ENREQ.

(3) If the decedent’s information is on file, verify that the entity information is the same as Form 706: decedent’s name, SSN, executor’s name and address, city, state, zip code.

(4) IDRS CC CFINK is used to research the CAF system for authorization information from both power of attorney and tax information authorization. The following table provides guidance researching the POA:

(1) After initial IDRS research, input case on installment database regardless if denied or accepted.

(2) Prepare case file with copies of:

• First three pages of Form 706.

• Any schedules the closely held business refers to

• Schedules J, K & L

• All Schedules with money amounts on them

• Form 4349

• IRC 6166 spreadsheet from installment database

• Letter 2568-C,, Follow-up for Installment Billing & Section 6161 Balance Due Billing: Form 706

• Copy of IRC 6166 election statement

(3) List on outside of folder decedent name, SSN and return due date. Send folder with return to TTT for review. Notate installment database.

(4) When the case is received back from TTT, mail Letter 2568-C, Follow-up for Installment Billing & Section 6161 Balance Due Billing: Form 706. It is not necessary to wait for TC 150 to post. Give the return to the clerk to send to ERS for processing. Monitor for TC 150 and STAT 14 to post. If account is not in STAT 14 input TC 488, provided the TC 150 posted. Prepare history sheet and file the folder in cabinet by due date and month.
Reminder: All actions must be annotated in the database.

(5) The TTT reviews the IRC 6166 cases for accuracy of the Letter 2568-C, Follow-up for Installment Billing & Section 6161 Balance Due Billing: Form 706, IRC 6166 election and Form 4349. They will update the installment database history and return to the TE. There is a three-day turnaround time.

(6) Missed IRC 6166 Set Up: If the Form 706 is already posted, but received because of missed installment setup, verify and set up file as stated above. Send to TTT as technical referral stating needs to be classified. If selected, return will be sent to the WSD National Gatekeeper. If not selected, close off Aims with AMSOC.

(1) The IRC 6166 installment bill is sent yearly. The first bill is sent 30 days prior to the due date as a reminder. The letter includes a certification request.

(2) A listing is generated from the Installment Database reflecting accounts to be billed for the month. The listing must be worked within that month’s time frame. Complete IDRS research. If not the first bill, then compute interest and applicable penalties.

(3) The first letter (reminder) is Letter 249-C, Installment or Interest Due - Current Status Requested or Explained: Form 706. Also send Notice 330, Change of Status of Estate Due to Disposition of Interest or Withdrawal of Funds from Business, or by Reason of Undistributed Income or Failure to make Payment.

(4) If payment is not received:

• Second letter is Letter 6335, Estate Installment Program.

• Third letter is Letter 6335-T, Final Notice for Payment of Estate Tax.

• Fourth letter is Letter 950-H, 30 Day Letter - Intent to Terminate IRC 6166 Election.

• Fifth letter is Letter 6335-F, Notice of IRC 6166 Denial or Termination.

(5) Billing Next 10 Years or Remaining Years: The steps for billing the next 10 years are the same as the first five years except the installment amount for the tax owed is included with the bill.

(6) Annual Billings:

• Send Letter 249-C, Installment or Interest Due - Current Status Requested or Explained: Form 706, from database.

• Include certification of unchanged status and Notice 330.

• Suspend for 45 days.

• Monitor for payment.

• Monitor for signed certification of unchanged status.

• Update database when payment and certification of unchanged status are received.

(7) Follow the IF/THEN table below for payment and certification of unchanged status:

(8) For estate appeal rights, See IRM 4.25.2.8.3.10, Estate Appeal Rights.

(9) IDRS Input: Assess Interest on TXMOD:

• TC 290 for .00

• TC 340 interest amount

• BLK 10

• Hold Code 3 (hold notice since a manual bill is sent)

• Interest-to-Date (Installment due date)

• NSD Comment what is being assessed

(10) Accelerated Inputs on TXMOD:

• TC 270 for .00

• TC 340 interest amount

• BLK 10

• Hold Code 0

• Interest-to-Date (Installment due date)

• NSD Comment what is being assessed

• TC 489

• TC 241 to reverse LI, if applicable

(1) Payments should be applied in the following order:

1. Non-Deferred Tax

2. Deferred Tax

3. Fees

4. Penalties

5. Interest

(2) Payments made with the original filed return are applied to non-deferred tax. Occasionally an estate will overpay the non-deferred tax. The amount paid that is greater than the amount of non-deferred tax due is referred to as an "overpayment" or "interim" payment. These payments reduce interest but are not applied to interest billed in the first four years. The estate must pay the full amount of interest and penalty, if applicable, unless an election to apply the interim payment is made.

(3) ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

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(4) Additional Considerations:

• Interim payments are held and applied to the first installment of tax. (Exception: If Executor/POA writes in requesting overpayment be applied to interest)

• ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

• If the installment is not paid in full and an extension to pay is not filed, then additional notices are required. See IRM 4.25.2.8.3.8 (4), Initial and Annual Billing, for list of notices.

• ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

• Reminder: The estate may elect to apply the interim payment to interest first.

(1) Estate Appeal Rights: The Letter 950-H, 30 Day Letter - Intent to Terminate IRC 6166 Election, provides the estate a 30-day period to appeal the termination of the installment. If an appeal is not made within the 30-day period, or as extended, or if the estate sends an untimely post-marked protest, the Letter 950-H becomes a final determination letter.

(2) If the estate fails to appeal the Letter 950-H within the 30-day period, prepare and issue Letter 6335-F, Notice of IRC 6166 Denial or Termination. Letter 6335-F, shall be mailed certified mail, return receipt requested. See certified mail IRM 4.25.2.8.3.11 (2), Installment Denial Procedures. The Letter 6335-F shall reflect the account balance, less the LI penalty, plus the revised delinquent interest, plus any additional penalty and interest as of the 23c date. Send a copy of Letter 6335-F to the Advisory ETL group.

1. Abate the Late Installment (LI) penalty (TC 241) that is associated with this delinquent period (LI penalty is not applicable for accounts that are accelerated). Do not abate TC 240 with reference code. These have been input by other functions.

2. Recompute the statutory interest on the past due installment from the last installment due date, adding any applicable FTP penalties as they were assessed to determine the correct interest now due, to the 23C date. (The previously assessed delinquent interest amount associated with this delinquent period will need to be subtracted from the recomputed amount.) Compute additional IRC 6166 interest up to the termination date (the 23c date). Combine the IRC 6166 interest and statutory interest amounts together and assess. Compute and assess FTP penalties as applicable, on the unpaid tax on the prior delinquent amount. See IRM 4.25.2.8.3.8, Initial and Annual Billing, IDRS Input.

3. Monitor the account for the adjustments to post and status 21. The Letter 6335-F shall be dated and mailed on the 23c date. When the account goes to status 21, accelerate the account to status 26 using CC ASGNB with assignment code 6466. Close case.

(3) If the estate provides a written protest in response to the Letter 950-H, review the estate’s protest. If the Service agrees with the estate and the payment has been received, continue the IRC 6166 election.

(4) If after reviewing the protest letter, E&G campus still believes the estates’ election should be terminated, prepare and send to Appeals within 30 days from the postmark date of the protest letter an auxiliary file containing the following:

1. Copy of pages 1, 2, and 3 of the Form 706 and the schedules related to the closely-held business,

2. Notice of IRC section 6166 election and attachments,

3. Form 4349, Computation of Estate Tax Due With Return and Annual Installment,

4. Copy of Letter 2568-C, Follow-up for Installment Billing & Section 6161 Balance Due Billing: Form 706,

5. Any Form 4768, Application for Extension of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes,

6. All correspondence between the Service and the Taxpayer related to the last year,

7. Case history,

8. Certification of Unchanged Status for previous year,

9. Letter 950-H, 30 Day Letter - Intent to Terminate IRC 6166 Election,

10. All prior bills related to this year,

11. Protest from taxpayer,

12. Power of Attorney information.

(5) Transfer the auxiliary file for review to the Independent Office of Appeals for the state of the decedent’s last domicile using the case routing list on the Appeal’s website, https://portal.ds.irsnet.gov/sites/ap/Pages/Home.aspx, with the understanding the case may be transferred to another Appeals Office based on inventory needs. Prepare Form 3210 forwarding case to Office of Appeals notating "Type of Case IRC section 6166 Termination for Failure to Pay. This is an emerging issue. Please check the Appeals Technical Guidance issue locator on the Appeals webpage for further information."

(6) Input history item on IDRS that indicates the protest has been sent to Appeals.

(7) Update 6166 database to record that the case has been transferred to Appeals and sendLetter 86C, Referring Taxpayer Inquiry/Forms to Another Office.

(8) Prepare a Form 3210 to Advisory ETL group notating that the case is being sent to Appeals and attach a copy of the protest and forward to the appropriate Advisory ETL group. The Form 3210 is for informational purposes only. Place copy of the Form 3210 in the case folder. The case must be mailed using certified mail. See certified mail IRM 4.25.2.8.3.11, Installment Denial Procedures.

(1) To deny the installment:

• Accelerate after third billing.

• Send Letter 6335-F, (final bill) fourth notice. Send copy of Letter 6335-F to Advisory ETL group.

• Stop the acceleration process if the installment payment is received at any point in time.

• Follow up in 45 days for first and second notices.

(2) Certified Mail: The Certified Automated Mailing Solution (CAMS) application must be used when sending certified mail. This web-based system assists with mail label production, preparation and tracking of USPS Certified Mail and Return Receipt Mail services.

• The mailer can enter addresses manually, choose from an address book or upload an address file/list.

• The system will validate addresses per USPS requirements for the mailing.

• The system will provide the mailer with USPS compliant Certified Mail Barcodes.

(3) Mailers must affix the USPS 22-digit Intelligent Mail Package Barcode (IMPB) to each mail piece ensure it meets all USPS barcode requirements. Attach the IMPB to Letter 6335, Letter 6335-T, Letter 6335-F or Letter 950-H.

1. Letter 6335: Record the IMPB information on the database under Executor and Power of Attorney Information.

2. Letter 6335-T, Letter 6335-F and Letter 950-H: Record the IMPB on the Account History Sheet along with an explanation of the type of letter sent (For example, sent 950-H)

(1) Interest is always accruing on any tax, penalties or interest due except when the Form 890, Waiver of Restriction on Assessments & Collection of Deficiency & Acceptance of Overassessments, is signed and notice and demand is not issued within the 30-day period.

(2) When computing interest and penalties, you need to address if interim payment(s) is received. Manually compute the interest. Follow the pro-rating instructions, if applicable.

(3) The following is an IF/THEN Table for the interest percentages used in computing interest:

(4) Penalties are assessed when the installment is not timely paid. There are two penalties that are applicable and are included on all notices after first notice:

1. LI Penalty on the unpaid installment (principal and interest) at 5 percent per month (or fraction thereof) from the installment due date (considering any extension of time to pay) to the payment due date. Maximum penalty is 30% of the installment owed.

   Note: LI penalties cannot be abated for reasonable cause.

2. FTP Penalty on the principal portion of the installment, from the installment due date (considering any extension of time to pay) to the payment due date.

(5) The following is an IF/THEN Table for Billing the First Five Years-Interest Only:

(6) See IRM 20.2.10.2, Interest on Estate Tax Returns, for additional information.

(7) The campus will complete a full review of the interest calculations on all IRC 6166 cases every three years.

(1) Form 706 series returns and Form 709 may need perfection to secure missing or additional documents. These are assigned with the IDRS control "Perfection".

(2) Once response is received or the suspense period has expired, whichever is sooner:

(1) Stock valuation research is used to determine whether the return should be submitted for verification of stock valuation. Request for stock valuations are received either during the classification detail or as a fax request from a Field Tax Attorney that is conducting an open audit.

(2) Any schedules with listed stocks or bonds should have a valuation completed. Do not write on the Form 706. Use post-it notes or a copy of the schedule to number the stocks and bonds. Committee on Uniform Securities Identification Procedures (CUSIP) numbers will be used to research values.

(3) Each stock/bond has a nine-digit CUSIP number assigned to it. All stocks/bonds are valued using this number. Ticker symbols may be used only in cases where no CUSIP number can be found. The ticker symbol is provided by the estate.

(4) After all CUSIP numbers have been found, use the Estate Val program to research the stocks/bonds. Complete the following:

1. Enter Date of Death along with the CUSIP number.

2. Total number of shares.

3. Total value of the stock/bond and interest or dividends provided on the estate tax return.

(5) Once the above information has been entered, generate a report and place report in the case file. If the case was received from WSD classification, update on IDRS AIMS to Status 06, EGC 1067 and give to the National Gatekeeper to continue the classification. If received from a field attorney, return by e-mail as a .pdf file.

(6) When completing a stock valuation, be sure to check requested items that can be valued. Only publicly traded items can be valued. Below is a list of items that can be valued using the Estate Val program:

• Stocks

• Bonds

• Mutual Funds

• US Treasury Notes

• US Treasury Bonds

• US Treasury Bills

• US Savings Bonds

(7) Items that cannot be valued:

• Money Markets

• Promissory Notes

• Cash

• Personal property

(8) Date of Death or Alternate Valuation Date: Look on page 2, Part 3, Line 1 of the Form 706 tax return. If they have elected alternate valuation you will use the alternate valuation values listed. If they have checked “no” or left blank, you will then use the date of death values.

(9) Researching CUSIP numbers using CUSIP global services: Issuer name is the name of the stock/bond. Enter the name of the stock/bond into one of the following lines per the following criteria:

• If the name of the stock is correct, then enter the name beside "START with." This searches for the name as it appears. For example, "Dragon, Caiman and Gator" – this would search this information exactly as it appears, so possibly no results.

• If unsure of the name or the order of the name being researched, then type this information in the CONTAINS section. This will search for all available information that appears and will not restrict the search to only as input.

  Example: Caiman, Dragon and Gator– this would search all information in any order, so you will receive all possibilities for the information given

(10) Each stock/bond can have multiple issues:

• Common

• Preferred

• Class A

• Class B etc.

(11) The more information provided, the better chances are of finding a match. For stocks, if no information is listed other than the name of the stock, assume it is either common or Class A whichever is available.

(12) Field Descriptions:

• Common enter "com"

• Preferred enter "pfd"

• Class A enter "cl a"

• Class B enter "cl b"

Note: If nothing is input in this field, the website will bring up every issue for that stock.

(13) A bond could have many issues such as using percentages, date of issuance and dates of maturity. Bonds must have percentage and maturity date input to find the CUSIP information. If the schedule does not list this information, the chances are that no CUSIP information will be found.

(14) Enter the maturity date into the field as MM/DD/YYYY; next enter the percentage in the rate field. The percentage must be entered with the decimal and not as a fraction. For example, 7 3/4 would be entered as 7.75. After all information is entered, click the search button. This gives all possible information. On this screen, the top will list all possible issuers based on the information requested. Select the Issuer you need and click on display issues. This will display the information at the bottom of your screen. To get the CUSIP number, you take the six numbers from beside the Issuer at the top of the screen (for example, AT&T is 001957) and the three numbers from the correct issue at the bottom of the screen (for example, Com is 109). Write the number down on a post-it note on the return next to the name of the stock/bond with the Issuers number first and the issue number following, for example, 001957109. This will need to be completed for each stock/bond reported.

(15) If you are unable to find a CUSIP number or unable to determine which number is correct, put a check mark on the post-it note or copy of schedule along with any information as to what information you need to find the correct CUSIP number.

(16) Using Estate Val Program: Enter the date of death from page 1 box 5 of the Form 706. Hit the tab key. The alternate valuation date will automatically appear. Even if you will be using the date of death ONLY, the program automatically calculates the alternate valuation date.

• Enter the decedent’s name and the schedule you are valuing. For example, Schedule B, and hit the tab key.

• Enter the CUSIP number for the first stock and hit enter.

• Enter under shares the number of shares held in the stock or the face value of the bond and hit enter.

• Enter under return Val., the total value of the stock or bond on the return and hit enter. If date of death was elected by the estate, enter the date of death values. If the alternate valuations were elected, then enter that value.

• Enter under return Acc, any interest or dividends reported on the Form 706 for that stock or bond and hit enter.

  Note: If more than one stock or bond needs to be researched, then go to the next number and repeat the above steps.

(17) After all stocks and bonds are entered in the template, go to the top of the screen using the mouse and click on Evaluate. Choose either date of death or alternate valuation whichever the taxpayer elected on page 2 part 3 of the Form 706 tax return. The tool will request a name for the report. The name of report will consist of the first initial of the last name, the last four digits of the SSN and the schedule valued and year. For example, the Estate of John Cobra, SSN 000-00-XXXX and valued schedule B. The year you are valuing the report is 2017. The report name is CXXXXB-17.

(18) After the report is named, hit enter to begin the valuation. A progress bar will appear to let you know that the report is being generated. After the valuation is complete, a preview of the report will automatically appear. Check the report for any problems. If corrections are needed, click on close and go back to the template to make any necessary correction and hit valuation again. If the correction is the number of shares or total value of interest/dividends, go to report and choose either the date of death or the alternate date. This recomputes the new figures per the value already obtained. Print report once all corrections have been completed. A copy of the report will be placed with the case file.

(19) Caution: When using the alternate valuation date, the schedule may list dates that the stocks/bonds were sold before the alternate valuation date, but after the date of death. These must be valued using the sale date. To do this, after you enter the CUSIP number, shares, total value and interest/dividends, make sure a box on that line is highlighted and then with the mouse click on adjust inventories at the bottom of the template. A box will then appear. Click the tab that states alternate valuation date, then click "edit" and enter the number of shares that are still owned as of the alternate date. Click OK and "add" and enter the number of shares sold. Next go to action, use the drop-down menu to select "sold" and enter the date to the right of action and enter the sold date and click OK. The adjusted inventory now shows number of shares held on the alternate valuation date and the number of shares sold along with the date they were sold. Hit OK again and the tool will go back to the template. This must be done for each stock sold before the alternate valuation date.

(1) Form 2092, Estate and Gift Tax Treaty Information Sheet, is prepared for Form 706 and Form 706-NA using information from closed or accepted-as-filed returns.

(2) ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

(3) Put the name of the treaty partner country at the top of the Form 2092 and complete Lines 1 through 6 using information reported on the estate tax return as follows:

• Input the decedent’s name and TIN on Line 1.

• Input the decedent’s date of death on Line 2.

• Enter the country where the decedent resided on Line 3.

• Enter the country of the decedent’s citizenship on Line 4.

• Enter the executor’s information on Lines 5a and 5b.

  Note: Enter the information for one executor, even if the estate has more than one.

• Input the name of the treaty partner country on Line 6.

• List the value of property that may be taxable in the treaty partner country on Lines 7 and 8 in U.S. dollars.

(4) If the decedent is a U.S. citizen domiciled in the treaty partner country, include all assets shown on Form 706. If the Form 706 schedules can be photocopied, enter a reference to the schedule on Form 2092 and include the photocopy.

(5) If the decedent was a non-resident, and not a citizen of the U.S., include all assets located in the U.S. reported on the Form 706-NA. If assets not located in the U.S. are disclosed (for example, for the purpose of claiming deductions), do not include those assets on the Form 2092.

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(1) E&G Campus receives a list of returns processed by Submission Processing in Kansas City that do not meet the screening criteria for classification. These returns are to be closed on AIMS as Accepted As Filed. Once completed, the list showing closed cases will be emailed back to the contact designated in Kansas City Submission Processing Files.

(2) Returns accepted as filed are closed by the clerical team. Actions needed to close include closing AIMS with appropriate closing codes and issuing closing letters if requested via Pay.gov. See IRM 4.25.2.5.10, Closing Letters, for closing letter procedures.

(3) Research IDRS CC BMFOLI to check for freeze codes A, F or R. If one of these freeze codes are present, notate the Submission Processing listing with the present Freeze Code. Prepare an Action Request sheet and forward to ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ for resolution and closure. See Exhibit 4.25.2-4, Action Request.

(4) Using the Files closing listing, attach AMSOC print to Form 5351 to close cases off AIMS using IDRS CC AMSOC:
AMSOC▴▴▴52▴6000X
SSNV▴000000▴NAMC▴20

(5) AMSOC allows closing 20 cases at one time. Check that actions are completed by verifying that the word "OK" and the sequence number are next to each SSN input. If there are two asterisks, an error message will appear at the bottom of screen. If the case cannot be closed and needs further action, remove the case file and cross out the label on the Form 5351. Print the AMSOC screen and attach to the back of Form 5351.

(6) Sequence numbers are noted on the Form 5546, Examination Return Charge-Out, attached to the return, in the section at the bottom of this form, FOR REC/CTR USE. Input your IDRS number and the sequence number from the AMSOC screen associated to that return, for example 001.

(1) Information received concerning an estate or gift filings are called informant referrals. The informant referrals are taxpayer-generated. Taxpayers submit information to report suspected or perceived tax law violations by other taxpayers. Most referrals are on Form 3949-A, Information Referral, Form 3949, Information Report Referral, or in correspondence.

(2) Informant referrals are reviewed by the Referral Coordinator for E&G issues. Non-E&G issues (income, embezzlement, trusts, etc.) are forwarded to the appropriate office. See IRM 3.10.72.19.2, Form 3949-A Information Referral Routing Guide. Most of the referrals fall into this category.

(3) Informant referrals with possible E&G issues are researched for estate or gift tax returns filed, asset reporting, potential tax deficiency, noncompliance, etc. Referrals with audit potential are referred to the campus E&G National Gatekeeper for consideration. The National Gatekeeper sends these referrals to a WSD Project Coordinator to review and select for examination. See IRM 4.25.3.9.2.5.3, Informant Form 3949-A Referrals, for more information.

(1) Technical referrals assigned to TTTs are to be considered and a response issued in five days. The turnaround time can be extended to 10 days if technical volumes increase substantially during the filing period for gift tax returns (February through May.) Any technical referral requiring additional time for consideration will need management approval.

(2) Technical referrals assigned to Estate Tax Attorney (ETA) are to be considered and a response issued in 15 business days, 20 business days during peak February through May.

(1) TTTs will work all Form 3870, Request for Adjustments, (Domestic and International), with one exception:

• If there is an open audit, resulting in a TC 300/301 tax adjustment, send to CCP to process. Once AIMS is closed and a request is received for a tax adjustment, E&G will process the adjustment, not CCP.

(2) If AIMS is open and the case in WSD EGC, contact the National Gatekeeper.

(3) Requests will be received by fax and/or eFax and monitored daily.

(4) Cincinnati Campus E&G unit will be responsible for payoff computations related to IRC 6166 accounts and penalty adjustments or abatements to all E&G accounts. Philadelphia CCP Field Office Resource Team (FORT) will be responsible for payoff computation (interest and penalties) related to IRC 6161 accounts.

(1) Unpostable transactions are those which failed validity checks to allow them to be posted to the Master File. Unpostables that cannot be resolved by the Unpostable Function are closed to the initiating function for correction. A Form 4251 is usually generated to pull source documents from Files and return them to the initiating function.

(2) Unpostables are controlled on IDRS to the employee who input the transaction. These controls are listed on the CCA reports (age listings). Input of STAUP and interim letters should be addressed if applicable

(3) The CCA 4243 age listing should be monitored to ensure all unpostable transactions are resolved

(4) Unpostable Codes (UPC) identify the condition that caused the transactions to be unpostable. The Form 4251 shows the 3-digit unpostable code and a 1-digit unpostable reason code (RC) next to the unpostable code. Refer to the unpostable section in Document 6209, IRS Processing Codes and Information, Section 8, for interpretation of these codes.

(5) Unpostables are identified on IDRS by the following Pending Transaction Identification Codes:

• UNNN (U = unpostable, NNN = the numeric unpostable code) - This is an open unpostable case

• CU - Corrected Unpostable - this shows the transaction should post to the module in the cycle appearing to the right of the transaction

• NU - Nullified Unpostable - this case has been referred to the responsible function for correction

• DU - Deleted Unpostable - this case has been closed and deleted from the ECC-MTB Unpostables tape - research to determine appropriate action

• DJ - A transaction deleted through normal weekly updates

• RJ - Reject transaction - case referred to Rejects Function

• DC - Transaction deleted by ERS or SC Reject Processing

(6) The following IRMs provide information, guidelines and procedures to resolve unpostable conditions:

• IRM 3.12.279 - Error Resolution - BMF/CAWR/PMF Unpostable Resolution - Identifies unpostable transactions/conditions not compatible with existing master file data or normal Submission Processing Campus operating procedures and their resolution.

• IRM 21.5.5 - Account Resolution - Unpostables - Provides general instructions for resolving unpostable tax account conditions.

(1) Payoff requests for IRC 6166 accounts are received from the Department of Justice (DOJ) and Revenue Officers (ROs). The requests are sent to the IRC 6166 e-mail box, ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡.

(2) Computation is at the discretion of the examiner whether Notebook or COMPAX is used.

(3) Requests should be processed within 14 calendar days of receipt. However, DOJ may need a shorter time. ROs will mark expedite, if needed.

(1) Refer to IRM 25.23.9, BMF Identity Theft Processing.

(1) −O (Disaster Indicator) freeze refer to IRM 21.5.6.4.30, −O Freeze.

(2) −S (Disaster Indicator) freeze refer to IRM 21.5.6.4.37, −S Freeze.