Internal Revenue Manual
IRM 25.27.1 — Third Party Contact Program
Part 25. Special Topics
Chapter 27. Third Party ContactsSection 1. Third Party Contact Program 25.27.1 Third Party Contact Program Manual Transmittal May 06, 2026 Purpose (1) This transmits a revision to IRM 25.27.1, Third Party Contacts, Third Party Contact Program. Material Changes (1) IRM 25.27.1.1.3, added Third Party Contact Coordinators and the Exam Third Party Contact Analyst. (2) IRM 25.27.1.1.7, updated various links, headings, and TBOR information. (3) IRM 25.27.1.2, updated definition and examples to more closely mirror 26 CFR 301.7602-2. (4) IRM 25.27.1.3, updated to include reprisal statement. (5) IRM 25.27.1.3.1(4), updated with bankruptcy. (6) IRM 25.27.1.3.1(5), new paragraph to incorporate information from IGM SBSE-25-0125-0004, Interim Guidance on Letter 3164 third-party refresher notice. (7) IRM 25.27.1.3.2(1), revised Jeopardy exception to more closely mirror 26 CFR 301.7602-2. (8) IRM 25.27.1.3.3, revised reprisal information. (9) IRM 25.27.1.3.4, expanded reprisal guidance and incorporated some guidance from the following section. (10) IRM 25.27.1.3.5, deleted section and incorporated necessary information into other sections. (11) IRM 25.27.1.3.6, included statement about Form 12180 and added POA guidance. (12) IRM 25.27.1.6(f), increased response timeframe from 10 to 14 days. (13) IRM 25.27.1.3.8, added section to cover exception for pending CI cases per CFR 301.7602-2. (14) IRM 25.27.1.3.9, added section to cover exception for government entities per CFR 301.7602-2. (15) IRM 25.27.1.3.10, added section to cover exception for confidential informants per CFR 301.7602-2. (16) IRM 25.27.1.3.11, added section to cover exception for non-administrative contacts per CFR 301.7602-2. (17) IRM 25.27.1.4, added note about collection systems, added wording for mailed TPCs, added summons example. (18) IRM 25.27.1.4.1, added section for correcting form 12175. (19) IRM 25.27.1.5, updated guidance for third party contact list responses. (20) IRM 25.27.1.6, removed duplicate IRWeb sharepoint links, updated guidance for Coordinator responsibilities, added note to link to command code IRM, added reference to the TPC Coordinator guide. Effect on Other DocumentsThis IRM supersedes IRM 25.27.1 dated April 07, 2021. This IRM incorporates Interim Guidance Memorandum SBSE-25-0125-0004, Interim Guidance on Letter 3164 third-party refresher notice, dated January 22, 2025. AudienceAll IRS personnel who require guidance regarding third-party contacts. Effective Date(05-06-2026)Thomas KramerDirector, Collection PolicySmall Business/Self-Employed Division
Program Scope and Objectives
25.27.1.1 (10-19-2017) Program Scope and Objectives Purpose: This IRM provides guidelines on IRS employee contacts with third parties in the determination of a tax liability or collection of a tax liability. Audience: All IRS personnel who make TPCs in the course of their operations. Policy Owner: Director, Collection Policy, SB/SE. Program Owner: Headquarters Collection, Collection Policy, SB/SE. Primary Stakeholders: All IRS personnel, TIGTA, GAO, and the National Taxpayer Advocate. Program Goals: While it is the IRS's practice to obtain information relating to a liability or collectibility determination directly from the taxpayer whenever possible, there are situations when IRS employees must contact third parties. By following the procedures in this IRM section, employees will be able to balance the interests of taxpayers (reputation and business relationships) and third parties (privacy) with those of the IRS (effective and efficient tax administration).
Background
25.27.1.1.1 (04-07-2021) Background Third party contacts by IRS personnel in connection with determining and collecting tax from taxpayers are governed by disclosure regulations as well as by certain notice and reporting requirements. IRC 6103(k)(6) provides that IRS employees may disclose return information to the extent that such disclosure is necessary in obtaining information, which is not otherwise reasonably available, with respect to the correct determination of tax, liability for tax, or the amount to be collected. IRC 7602(c) stipulates that IRS personnel may not contact third parties with respect to the determination or collection of the tax liability without providing advance notice to the taxpayer. Section 3417 of RRA 98 further amended IRC 7602(c) to require IRS personnel to maintain a record of such contacts and provide taxpayers with this record upon request. Section 1206 of the Taxpayer First Act amended IRC Section 7602(c)(1), Notice of Contact of Third Parties and now requires IRS to: Issue advance notice of third-party contacts Intend, at the time such notice is issued, to contact third parties (the notice must state this intent) Specify in the notice the time period, not to exceed one year, in which IRS intends to make the third-party contact(s) Send the notice at least 45 days before the first contact with a third party The remaining provisions of IRC Section 7602(c) still require the IRS to: Record the third-party contact Provide a list of third-party contacts to the taxpayer upon request
Authority
25.27.1.1.2 (04-07-2021) Authority The authorities for these policies are: IRC 6103 IRC 7602 Treas. Reg 301.7602-2 Section 3417 of the Restructuring and Reform Act of 1998 Taxpayer First Act, effective July 1, 2019
Roles and Responsibilities
25.27.1.1.3 (05-06-2026) Roles and Responsibilities The Director of Collection Policy, SBSE, is responsible for the procedures in this IRM. Managers of employees who make TPCs are responsible for ensuring their employees comply with TPC guidelines and procedures. Employees who make TPCs are responsible for following these procedures. Third Party Contact Coordinators are responsible for fulfilling Coordinator duties. The Headquarter's Collection program analyst will partner with the Headquarter's Exam program analyst to ensure the IRM is consistent for all compliance employees.
Program Management and Review
25.27.1.1.4 (10-19-2017) Program Management and Review Program Reports: When IRS personnel document a TPC as described in this IRM, the information is captured in the Third Party Contact Database. This information is provided to taxpayers upon request. Program Effectiveness: Each BOD functional unit with TPC-related activities should conduct periodic reviews of the TPC program to ensure that taxpayers are being notified of potential third-party contacts and that third-party contacts are being properly reported. Case reviews and quality reviews may include this topic. The methodology and review cycle will be determined by the BOD functional units.
Program Controls
25.27.1.1.5 (10-19-2017) Program Controls The third-party database is maintained within IDRS, and it is subject to the same access controls and permissions governing IDRS.
Acronyms
25.27.1.1.6 (04-07-2021) Acronyms The following table defines acronyms commonly used throughout this IRM section: Acronym Definition CDP Collection Due Process IDRS Integrated Data Retrieval System IRC Internal Revenue Code IRM Internal Revenue Manual POA Power of Attorney PDT Potentially Dangerous Taxpayer PUB 1 Publication 1 RRA 98 Restructuring and Reform Act of 1998 TFA Taxpayer First Act TPC Third Party Contact Treas. Reg. Treasury Regulation
Related Resources
25.27.1.1.7 (05-06-2026) Related Resources In addition to this IRM, there are other relevant IRM sections employees will use, including but not limited to: IRM Title Summary IRM 5.1.1.12 Third-Party Contacts Provides Field Collecting Procedures for TPCs. IRM 5.9.3.12.1 Third Party Contacts Provides Collection Division procedures for TPCs in Bankruptcy and Other Insolvencies. IRM 8.1.6.3 Prohibition of Third Party Contacts by Appeals Provides Appeals Function with TPC procedures. IRM 13.1.6.12 Third Party Contacts Provides Taxpayer Advocate Case Procedures for TPCs. IRM 4.11.57 Examining Officers Guide (EOG), Third-Party Contacts Provides Examiners Procedures for TPCs IRM 5.19.5.14 Notification of Third-Party Contact Provides ACS Procedures for TPCs IRM 2.4.52 Command Codes TPCIN and TPCOL Describe how to input information into the TPC System database of all TPCs that are made regarding a taxpayer during the determination or collection of a tax liability. IRM 1.2.2.15.12 Delegation Order 25-12 (Rev 1) Authorizes employees to determine for good cause shown that providing the taxpayer with general notice or notice of specific TPC would jeopardize the collection of any tax or may involve reprisal against any person. IRM 20.1.6.19 Third Party Contacts - IRC 7602(c) Provides servicewide policy for the administration of return preparer penalties, promoter penalties, and material advisor penalties and the effect of IRC 7602(c), Notice of contact of third parties on penalty development. IRM 4.8.8.18 Third-Party Contacts Provides Technical Services' staff with the basic procedures to conduct reviews to determine whether Examination employees observed the advance general notice requirements of IRC 7602, Examination of Books and Witnesses. IRM 4.16.1.4.5 Third-Party Contacts Provides SEP agents with direction regarding TPCs IRM 4.19.13.10 IRC 7602(c)(1) Third Party Contacts Provides Campus examiners with TPC procedures IRM 4.32.2.8.3.2 Third-party Contacts Provides AT examiners with TPC procedures. Helpful information can be found on websites, including, but not limited to the following: SBSE Collection Coordinators SBSE Exam Coordinators The IRS adopted the Taxpayer Bill of Rights (TBOR) in June 2014. 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 accord with taxpayer rights. See IRC 7803(a)(3), Execution of Duties in Accord with Taxpayer Rights. For additional information about the TBOR, see IRS Taxpayer Bill of Rights and IRM 1.2.1.2.36, Policy Statement 1-236.
Third Party Contact (TPC): Definition
25.27.1.2 (05-06-2026) Third Party Contact (TPC): Definition 26 CFR 301.7602-2, Third Party Contact, defines a TPC as a communication which Is initiated by an IRS employee, Is made with a person other than the taxpayer, Is made with respect to the determination or collection of a tax liability of such taxpayer, Discloses the taxpayer's identity, and Discloses the association of the IRS employee with the IRS. Note: Generally, an IRS employee will identify himself or herself when attempting to obtain information from third parties. The following are examples of actions that are not TPCs: Examples Searches made on computer databases that do not require any personal involvement on the other end (e.g., LEXIS, Information America). Contacts made with any office of any local, state, federal, or foreign government entity (such as contacting the U.S. Postal Service to obtain the taxpayer's current address). Exception: Contacts concerning the taxpayer's business with the government office contacted, such as the taxpayer's contracts with or employment by the office, are TPCs. Unsolicited information received from a third party where the third party initiated the contact. Information that the IRS receives from, or provides to the government of a foreign country or U.S. possession pursuant information exchange programs under treaties or agreements with such governments or as authorized by domestic or foreign statutes, including programs concerning specific, routine, spontaneous and simultaneous exchanges of information. Contacts made by the IRS to respond to a request from a government of a foreign country or U.S. possession concerning a foreign or possession tax liability. Contacts made with third parties to collect taxes for another country as part of a Mutual Collection Assistance Agreement. Exchanges of information via tape programs, e.g., State Income Tax Levy Program and Federal Payment Levy Program. Contacts with individuals who have a valid power of attorney for the taxpayer. Contacts made to obtain information regarding an industry or market segment where specific taxpayers have not been identified. Contacts made by IRS employees during litigation if the contact relates to a matter and issue being litigated, including, but not limited to, service of Tax Court subpoenas on third parties by employees. Contacts made with other IRS employees in the scope of an employee's official duties, including employees of the Office of Chief Counsel. Contacts made as the result of unsolicited requests for a payoff of a Notice of Federal Tax Lien or to respond to requests for information regarding the priority of a lien, e.g., lending institution (IRC 6103 provisions do apply). Contact with a current employee or officer of a taxpayer who is acting within the scope of their employment. An employee or officer shall be presumed to be acting within the scope of their employment during business hours on business premises. The following are generally TPCs: Solicitation by an IRS employee for additional information as a result of a follow up to a third party initiated call. Contacts made with employees of the taxpayer who are questioned outside the scope of their normal employment when the taxpayer is a business. A levy or summons issued to anyone other than the taxpayer such as a bank, credit card processor or employer. See 26 CFR 301.7602-2 for statutory and regulatory definitions of third party contact, including examples.
Notification Requirements
25.27.1.3 (05-06-2026) Notification Requirements It is the IRS's practice to obtain information relating to a liability or collectibility determination directly from the taxpayer whenever possible. In most cases, it is preferable for the employee to first try to obtain the information directly from the taxpayer and/or representative or obtain taxpayer approval to contact third parties using Form 12180, Third Party Contact Authorization Form. See IRM 25.27.1.3.5, Taxpayer Authorizes Contact with a Third Party. However, these are not legal requirements. Situations will arise when the IRS must contact third parties to complete an investigation. The IRS employee: Must not contact any third party without first providing the advance third party contact notification to the taxpayer, Must have an intent, at the time such notice is issued, to contact third parties, Note: A notice shall not be issued unless there is an intent to contact third parties at the time such notice is issued. Must specify in the notice the time period, not to exceed one year, within which the IRS intends to make the third-party contact(s), and Must send the notice at least 45 days before the first contact with a third party. Reprisal must be considered for every TPC and the determination must be made on a contact-by-contact basis (no blanket determinations) using all available information. See IRM 25.27.1.3.3, Reprisal.
TPC Notification Procedures
25.27.1.3.1 (05-06-2026) TPC Notification Procedures In all cases involving third-party contact (TPC) notices provided after August 15, 2019, a notice meeting the requirements of IRC 7602(c)(1) must be provided. Employees may not contact a third party until the 46th day following the date of the notice. Note: Effective August 15, 2019, Publication 1 no longer satisfies the advance notice requirement of IRC Section 7602(c)(1). The Letter 3164, Third Party Notice, is issued by Collection and Exam employees to notify taxpayers of potential TPCs. There are over twenty versions of the Letter 3164, available to meet specific functional requirements. Note: Letter 3164 should only be issued when the employee intends to contact a third party. If a TPC will occur during a bankruptcy automatic stay period, Letter 3164-B must be modified with assistance from the Department of Justice or Counsel. See IRM 5.9.3.12.1(9), Third Party Contact Notification to Taxpayers. The notice must also include the tax period(s) at issue. Note: If continued TPC is planned, please remember employees should issue a Letter 3164 refresher no less than (NLT) 46 days before the expiration of the current TPC one year period. Employees may issue a Letter 3164 refresher at any time, but employees must issue a Letter 3164 refresher NLT 46 days before expiration of the current TPC window to avoid another waiting period. Example: If the current TPC window expires 10/1/24, a Letter 3164 refresher should be issued no later than 8/15/24. This would allow for uninterrupted TPC without an additional waiting period. If a Letter 3164 refresher is not issued until 10/1/24, there would then be another 45-day waiting period. If the Letter 3164 refresher is issued sometime between 8/15/24 and 10/1/24 there would be some additional waiting period, depending on the date it was issued. If the taxpayer has not received prior notification and a third-party contact is necessary, employees should do the following: Prepare and deliver the appropriate Letter 3164. If the tax liability is due to a joint return, each spouse must receive a separate Letter 3164. Specify the contact time period, not to exceed one year and the applicable assigned tax period(s). Hand carry the letter to the taxpayer or the taxpayer's dwelling or usual place of business or; Mail the letter to the taxpayer's (and also to the spouse's, if applicable) last known address. Document the case file with the date of the letter and the method of delivery. Provide a copy of the letter to the power of attorney (POA). In situations where an IRS employee attempts to reach a taxpayer by telephone, but instead reaches someone other than the taxpayer: If the appropriate Letter 3164 has been sent and the requisite waiting period has lapsed, the employee may seek additional information. If the appropriate Letter 3164 has not been sent or the requisite waiting period has not lapsed, the employee may not seek additional information. Note: In (a) and (b) above, merely identifying himself or herself as an IRS employee does not constitute TPC.
Exceptions to IRC 7602(c) Notification Requirements
25.27.1.3.2 (05-06-2026) Exceptions to IRC 7602(c) Notification Requirements IRC 7602(c)(3) provides for four situations when the IRS is not required to give the taxpayer advance notice or to include a particular TPC on the list of TPCs provided to the taxpayer. The exceptions are: Reprisal - the TPC believes that the taxpayer will harm any other person in any way (physical, economic, emotional, or otherwise). Taxpayer authorizes TPC. Jeopardy - the IRS employee making a contact has good cause to believe that either a general pre-contact notice or a record of the specific person contacted may jeopardize the collection of any tax. Pending criminal investigation. Treas. Reg 301.7602-2(f) provides detail on additional exceptions as follows: Governmental entities Confidential informants Non-administrative contacts
Reprisal
25.27.1.3.3 (05-06-2026) Reprisal If an IRS employee determines that providing the advance notice or a record of a specific contact to a taxpayer may result in a reprisal -- an act of revenge or retaliation -- against any person, the notice requirements of IRC 7602(c) do not apply. For examples, see Treas. Reg. 301.7602-2(f)(3), Reprisal, (Link 26 CFR 301.7602-2(f)(3)). Make a reprisal determination for all TPCs. Make a determination on a contact-by-contact basis with no blanket determinations for different types of contact. Note: Form 12175, Third Party Contact Report Form, is not required to record the contact if a fear of reprisal is present. To protect the provider of the information, make any reprisal situation very apparent in the case history with the facts surrounding the reason for the reprisal determination, and consult with his or her manager, if needed. Information that could disclose the identity of the third party should not be in the case history. Caution: Care must be taken to make sure information about persons fearing reprisal is not inadvertently disclosed. Therefore, information in the case file disclosing the identity of the third party should be placed in a confidential envelope and clearly marked.
Reprisal Determinations
25.27.1.3.4 (05-06-2026) Reprisal Determinations Use all available information when making a reprisal determination. In some situations, a reprisal determination can be made based on the case history If reprisal is determined based on the case history, the facts surrounding the determination should be documented in the case history and the advance notice or notice of a particular contact is not required. Note: A potentially dangerous taxpayer (PDT) indicator alone is not a sufficient basis for determining that sending the advance notice may result in reprisal against any person. If the reprisal determination cannot be made based upon the facts already known, during the initial discussion with the third party: Advise them that by law their name will be placed on a list of third parties contacted and, if requested, will be provided to the taxpayer. Ask the third party if they fear reprisal. Do not make the reprisal inquiry in a way that would influence the third party. The following language is suggested. "By law I am required to include your name on a list of parties we have contacted. This list may be sent to (taxpayer's name). If you believe that including your name on the list may result in reprisal against any person, we can exclude you from the list.Do you have any reason to believe that reprisal against any person may occur?" Employees may use Letter 1995, Third Party Contact Letter to Request Information. Letter 1995 contains reprisal language and provides direction to the third party if they fear reprisal. If a letter is sent to an individual third party, include the first part of the suggested language above and add the following:"If you have any reason to believe that reprisal against any person may occur, you should call me at the telephone number listed above by (insert a date that is 10 calendar days from the day the letter is mailed). " Note: Consider including the reprisal script on a case by case basis when a letter is mailed to a business entity. Any concern raised by the third party with respect to reprisal will be taken at face value. If the third party does not indicate a reprisal concern, complete and forward Form 12175 as discussed in IRM 25.27.1.4. If the third party indicates a reprisal concern, document the case history that a reprisal concern exists and do not complete Form 12175. If a third party indicates a reprisal concern after the submission of Form 12175, see instructions for correcting Form 12175 in IRM 25.27.1.4.1.
Taxpayer Authorizes Contact with a Third Party
25.27.1.3.5 (05-06-2026) Taxpayer Authorizes Contact with a Third Party Form 12180, Third Party Contact Authorization Form, may be used to document the taxpayer's authorization. Consent must be obtained prior to the contact being made by the IRS employee. Although taxpayers may give oral authorization, the best practice is to complete Form 12180. If oral authorization is accepted, the case documentation must include the date and method used to authorize the contact. The taxpayer can revoke the authorization at any time. Note: IRC 7602(c)(3)(A) does not require an IRS employee to obtain authorization from the taxpayer in order to contact a third party. IRS employees are not prohibited from making a third- party contact if the taxpayer has not authorized it. The taxpayer may not prevent an IRS employee from contacting a third party by refusing to provide authorization. In some situations, it may be more practical to ensure that the advance notice has been provided to the taxpayer and to record the contact. If the taxpayer authorizes contact with a third party, the IRS employee is NOT required to provide the advance notice (if not already provided) or record the contact. If contacts will be made with other third parties and the taxpayer authorization has not been obtained for these contacts, the advance notice must be provided and a record of these contacts must be kept. The employee must inform the taxpayer that the IRS will not maintain or provide a record of the authorized contacts. For written authorizations, this requirement is met by using Form 12180. If written authorization is to be obtained, do the following: Prepare Form 12180 listing each authorized contact. More than one third party can be listed on the form. Do not accept blanket authorizations. Secure the taxpayer's signature (for joint filing, both spouses must sign). If a POA or an authorized representative authorizes the contact with third parties, he or she must sign and date Form 12180. Retain the signed Form 12180 in the case file. Continue to document the case file with routine case actions. Do not send Letter 3164 nor complete Form 12175 for contacts the taxpayer has authorized. Caution: If there is any reason to believe a concern with reprisal exists, then the employee should not seek authorization from the taxpayer to contact the third party. If a POA signs on behalf of the taxpayer to authorize contact with a third party, they must be properly authorized. Line 5a, Additional acts authorized, of Form 2848, Power of Attorney and Declaration of Representative, must have "Authorize disclosure to third parties" selected. CFINK doesn't provide Line 5a information; employees must research CFINK for a "M" code in the "AUTHS" field and secure a copy of Form 2848 from the taxpayer if not previously secured.
Jeopardy Situations
25.27.1.3.6 (04-07-2021) Jeopardy Situations The employee making contact with a third party may determine that providing the taxpayer with the advance notice or a record of a specific contact would jeopardize the collection of any tax liability, see Treas. Reg. 301.7602-2(f)(2). If a jeopardy situation exists, take the following actions: Document the case file with specific information about the TPC. Document the case file with the basis for the jeopardy determination. Complete Form 12175 but do not forward it to the TPC Coordinator or input personnel. When the jeopardy situation no longer exists, forward Form 12175 to the TPC Coordinator or input personnel. If additional contacts will be made, verify that the taxpayer was properly notified per IRM 25.27.1.3.1. Note: Jeopardy may apply to any type of tax.
Pending Criminal Investigation
25.27.1.3.7 (05-06-2026) Pending Criminal Investigation IRC 7602(c), Notice of Contact of Third Parties, does not apply to contacts made during an investigation (or inquiry to determine whether to open an investigation) when the investigation (or inquiry) is made with respect to a particular taxpayer being evaluated for criminal prosecution by an IRS employee whose primary duties include either identifying or investigating criminal violations. Third Party Contacts made by civil employees to develop the criminal investigation referral are TPCs under IRC 7602(c). The taxpayer must receive the appropriate Letter 3164, Third Party Contact, and the TPC must be recorded on Form 12175, Third Party Contact Report Form, unless another exception applies.
Government Entities
25.27.1.3.8 (05-06-2026) Government Entities IRC 7602(c), Notice of Contact of Third Parties, does not apply to any contact with any office of any local, state, federal or foreign entity unless the contact is concerning the taxpayer's business with the government office contacted, such as the taxpayer's contracts with, or employment by the office. IRC 7602(c), does not apply to the following: Contacts made with a county clerk to obtain lien information. Contacts made with a clerk of the court to obtain publicly available court records. Contacts made with state officials to obtain corporate charters or other publicly available information regarding corporate taxpayers or exempt organizations. Contacts made with the U.S. Postal Service to obtain the taxpayer's current address. Contacts made to respond to a request from a government of a foreign country with respect to a tax imposed by that foreign country.
Confidential Informants
25.27.1.3.9 (05-06-2026) Confidential Informants IRC 7602(c), Notice of Contact of Third Parties, does not apply when the employee making the contact has good cause to believe providing either the pre-contact notice or the record of the person contacted would identify a confidential informant whose identity would be protected under IRC 6103(h)(4), Disclosure in Judicial and Administrative Tax Proceedings.
Non-Administrative Contacts
25.27.1.3.10 (05-06-2026) Non-Administrative Contacts IRC 7602(c), Notice of Contact of Third Parties, does not apply to contacts in the course of pending court proceedings. A non-administrative contact includes a contact made by an IRS employee in the course of a pending court proceeding if the contact relates to a matter and issue being litigated, including, but not limited to, service of a Tax Court subpoena on a third party by an employee. See Treas. Reg. 301.7602-2(f)(7), (Link 26 CFR 301.7602-2(f)(7)), for examples.
Recording and Reporting TPCs
25.27.1.4 (05-06-2026) Recording and Reporting TPCs IRC 7602(c) as amended by Section 3417 of RRA 98 requires the IRS to maintain a record of third parties contacted and provide taxpayers with this record upon request. When a third party is contacted, each reportable TPC must be recorded on Form 12175. Instructions for completion of Form 12175 are on the reverse of the form. The appropriate identification of the third party is important because Form 12175 is the source of the TPC list provided to the taxpayer. Prepare a separate Form 12175 for each third party on each day a contact is made, even if it is with the same person. Note: Some IRS Collection applications such as ICS systemically update the TPC command code database. In these instances, Form 12175 should not be completed. See IRM 5.1.1.12.2 and IRM 5.19.5.14.3. Send the completed Form 12175 to the appropriate TPC Coordinator daily or as soon as possible after it is completed. If the third party is contacted by mail, hold Form 12175 until the time period for addressing reprisal expires. If the third party does not indicate a reprisal concern, forward the completed Form 12175 to the TPC Coordinator or input personnel. Refer to the following link for Exam TPC Coordinators or input personnel. See SBSE Exam Coordinators. Refer to the following link for Collection TPC Coordinators or input personnel. See SBSE Collection Coordinators. Keep a copy with the case file. Document the case history to show action taken. Notify the TPC Coordinator or input personnel when a Form 12175 has been generated and there was no TPC. Recording the TPC on Form 12175 is not required for TPCs of which the taxpayer has already received notice pursuant to another statute, regulation, or administrative procedure (such as a CDP notice or a summons). Example: When a third party summons is issued in accordance with the procedures under IRC 7609, Special procedures for third-party summonses, providing a copy of the third-party summons to the taxpayer satisfies the post-contact recording, record maintenance, and reporting requirements of IRC 7602(c), Notice of Contact of Third Parties.
Correcting Form 12175
25.27.1.4.1 (05-06-2026) Correcting Form 12175 If a Form 12175 is submitted and it is later determined that a TPC did not occur, select "void" on the top left portion of the original Form 12175 and send to the TPC Coordinator (TPCC). If a Form 12175 is submitted and later found to be in error: Prepare a new Form 12175 to reflect the correct information and select "corrected" on the top left portion of the form. Void the original Form 12175 by selecting "void" on the top left portion of the form. Submit the new form with the voided copy of the previously submitted to the TPCC. Retain a copy of the new Form 12175 with the original Form 12175 in the case file. If the correction is to report a reprisal concern, the amended Form 12175 must be completed with Item 7, Reprisal determination, checked and Item 8, Name of third party, left blank. Submit the new form and the voided copy of the previously submitted Form 12175 to the TPCC. The original Form 12175 and any information that could identify the third party must remain confidential and be protected.
Providing Taxpayers with TPC List
25.27.1.5 (05-06-2026) Providing Taxpayers with TPC List Treas. Reg. 301.7602-2(e)(1) states that a taxpayer may request a record of contacts in any manner that the Commissioner permits. Employees are responsible for ensuring that taxpayers understand their rights to receive post third-party contact reports. This may require explanation and assisting the taxpayer with requesting the report. A taxpayer can request a list of TPCs at any time. The request can be made either orally or in writing. A TPC list request must: Include the taxpayer's name, address, TIN (taxpayer identification number), and tax periods requested. Contain the information for only one taxpayer. Joint requests, regardless of filing status, are not valid. If a joint request is received, advise each taxpayer that a separate request is required. Be for a single list of contacts completed prior to the request date. Do not accept a blanket request for a list of future contacts. Be made no less than 90 days from a previous request. If a request is received within 90 days of a prior request, advise the taxpayer of the reason the request cannot be processed and when a new request may be submitted. If the request is received by mail, review the list request for accuracy and completeness and then forward the taxpayer's request immediately to the TPC Coordinator. See IRM 25.27.1.4, Recording and Reporting TPC, paragraph 3 for additional guidance on TPC coordinator or input personnel. Invalid or incomplete requests should be returned to the taxpayer with Letter 6415, Unprocessable TP List Request. If a complete oral request for a list is received, send the taxpayer's name, address, TIN and tax period(s) of the request to your designated TPC Coordinator. Note: With oral requests, taxpayer and POA authentication policy should be followed. See IRM 21.1.3.2.3, Required Taxpayer Authentication and IRM 21.1.3.3, Third-Party (POA/TIA/F706) Authentication. The TPC Coordinator or input personnel will research the request, prepare and mail Letter 3173. Letter 3173 will list all TPCs other than those excluded due to fear of reprisal or other statutory basis: Made after January 18, 1999, or Made since the taxpayer received the last requested report of TPCs.
TPC Coordinators and Input Personnel
25.27.1.6 (05-06-2026) TPC Coordinators and Input Personnel TPC Coordinators and/or input personnel are responsible for: Reviewing Form 12175 to ensure that all appropriate fields are completed before input into the database. These forms will be received from employees via fax, email or by mail. Returning to the originator for clarification any forms that are incomplete, inaccurate, or unclear. Note: If a Form 12175 is received with 'reprisal' selected, return the Form 12175 to the originating examiner and direct them to IRM 25.27.1.3.4 unless the request is accompanied by a voided Form 12175 to correct a prior TPC input as detailed in IRM 25.27.1.4.1 (2). Maintaining Forms 12175. Note: Form 12175 should be retired to the Federal Records Center one year after cutoff (end of processing year). It will be destroyed 10 years after cutoff. See Item 155 in Document 12990, Records Control Schedule. Entering the data from Forms 12175 into the TPC Command Code database. Note: See IRM 2.4.52 for information on relevant command codes TPCIN and TPCOL. Removing and/or correcting erroneous information from the database when notified. Responding to requests for a list of TPCs including preparing Letter 3173 where appropriate. Letter 3173 should be mailed to the taxpayer's address per master file within 14 calendar days from the list request date. Providing guidance regarding IRC 7602(c) TPC procedures to employees. With an emphasis on enhanced computer data/information security, TPC Coordinators and input personnel must secure taxpayer/personal information in their possession. Make sure that any hard copy records/data are secure by keeping these items in a locked drawer or cabinet. This information is not limited to: Form 12175 Taxpayer requests for TPC lists, and TPC error log reports containing personal information Caution: This information, and any other taxpayer information, should not be in full view when you are not at your work site. The same goes for information that may be on your computer screen especially when you are adding TPC information (TPCIN) or compiling information (TPCOL). If you are going to be away from your work site, make sure your computer is secure by locking it so only you or an administrator is able to unlock your computer. For more information and guidance, a TPC Coordinator Guide is available on Knowledge Management. The guide contains useful information for coordinators from all functions. See Coordinator Responsibilities.
Source: official text