Internal Revenue Manual
IRM 25.3.7 — Reconciling Non-Insolvency LAMS Reports
Part 25. Special Topics
Chapter 3. Litigation and Judgments Section 7. Reconciling Non-Insolvency LAMS Reports 25.3.7 Reconciling Non-Insolvency LAMS Reports Manual Transmittal August 18, 2025 Purpose (1) This transmits the revised IRM 25.3.7, Reconciling Non-Insolvency LAMS Reports. Material Changes (1) IRM 25.3.7.1.2: Moved block paragraph to a new (3). (2) IRM 25.3.7.2.2(1): Moved bullet list into a table. (3) IRM 25.3.7.5(3): Moved bullet list into a table. (4) IRM 25.3.7.7.1: Moved reminder and note in (2) to a new (3). (5) IRM 25.3.7.7.2: Added in (3) a reminder to avoid use of both Transaction Code (TC) 520 closing code (cc) 82 and cc 80 in the same module. Use of both in the same module causes a Integrated Data Retrieval System (IDRS) unpostable error. (6) IRM 25.3.7.7.4: Updated the note in (2) and added a reminder to avoid use of both Transaction Code (TC) 520 closing code (cc) 82 and cc 80 in the same module. Use of both in the same module causes a Integrated Data Retrieval System (IDRS) unpostable error. (7) IRM 25.3.7.7.8: Moved reminder in (2) to a new (3) and moved the remaining paragraphs to the next higher number. (8) IRM 25.3.7.7.9: Updated the note in (3) and added a reminder to avoid use of both Transaction Code (TC) 520 closing code (cc) 82 and cc 80 in the same module. Use of both in the same module causes a Integrated Data Retrieval System (IDRS) unpostable error. (9) Editorial changes throughout updating references, links, and style guide adherence. Effect on Other Documents This material supersedes IRM 25.3.7 dated August 30, 2022. Audience SBSE Collection Employees and all Operating Divisions Effective Date (08-18-2025) Thomas Kramer Director, Collection Policy Small Business/Self-Employed
Program Scope and Objectives
25.3.7.1 (08-18-2025) Program Scope and Objectives Purpose: This IRM provides procedural guidelines on the timely posting of appropriate case controls to accurately reflect the status of taxpayer accounts. The accuracy of IRS financial statements depends on reconciling the Litigation Accounts Management System (LAMS) TC 520 Non-Insolvency listing (Non-Insolvency LAMS Report) with current inventory on the Integrated Collection System (ICS). This ensures that appropriate case controls have posted to tax modules involved in litigation. Specifically, the purpose of reconciling the Non-Insolvency LAMS Report is to: Verify the accuracy of the Report against open Civil Enforcement Advice and Support Operations (CEASO) Advisory cases on ICS. Ensure that Transaction Code (TC) 520s are properly reversed when warranted. Correct invalid TC 520s. Ensure that TC 550s with proper definer codes are input, when warranted, prior to TC 520 reversals. Facilitate coordination with other CEASO Advisory groups, as needed, to reflect assignment of entities to another CEASO Advisory jurisdiction. Verify that all TC 521, TC 522 and/or TC 550 inputs have posted to the Integrated Data Retrieval System (IDRS) prior to case closing. Audience: Collection CEASO Advisory staff use this IRM in controlling litigation cases and assisting Chief Counsel, Area Counsel, and the Department of Justice (DOJ) prosecuting these cases successfully. Policy Owner: Director, Collection Policy. Program Owner: The program owner is Collection, an organization within the Small Business Self-Employed (SBSE) division. Primary Stakeholders: The primary stakeholders are CEASO Advisory, Chief Counsel, DOJ attorneys and DOJ Financial Litigation Unit (FLU) staff. Program Goals: The goal of the program aligns with IRS Strategic Goal II: Enforce the tax law fairly and efficiently to increase voluntary compliance and narrow the tax gap, and Objective 2: Enhance enforcement efforts to collect unpaid taxes in a fair and impartial manner.
Background
25.3.7.1.1 (08-30-2022) Background The provisions of this section apply in general to all litigation cases controlled by CEASO Advisory. Required actions are to be taken by CEASO Advisory unless otherwise noted. CEASO Advisory is responsible for reviewing the Non-Insolvency LAMS Report on (no less than) an annual basis. See IRM 25.3.6.4.1, Periodic Open Case Reviews, and IRM 25.3.6.5.4, TC 520 Reversals (TC 521). The Non-Insolvency LAMS Report is a tool to be used along with other means of maintaining proper case controls, such as: Matching hardcopy case files against ICS inventory listings, Ensuring Collection Statute Expiration Date (CSED) protection via IDRS reviews, and Utilizing the Automated Lien System (ALS) to ensure timely lien refiles.
Authority
25.3.7.1.2 (08-18-2025) Authority This section covers the various types of authorities for litigation. Authority Title Title 26, Subtitle F, Chapter 76 Judicial Proceedings Treasury Regulations Judicial Proceedings 28 USC 2410 Actions affecting property on which United States has lien Referral Authority: Counsel has the authority to refer suit actions to the Department of Justice. The IRS Collection authority to approve most suit actions is delegated to Collection Field Compliance Manager/Territory Managers (FCM/TM) and CEASO Advisory Territory Managers. However, Area Director approval is required, if the recommendation is to either: Secure judicial approval to seize a principal residence; or Foreclose the federal tax lien against the principal residence of any person. Reminder: See IRM 1.2.65.3.2, SBSE 1-23-9, Approval of Form 4477, Civil Suit Recommendation. Note: An electronic signature is an acceptable method of written approval for these enforcement actions. See also IRM 5.11.2.2.2(10), Preparing the Notice of Levy. Reminder: Counsel has independent authority to refer certain kinds of actions in suits commenced by third parties such as enforcing the federal tax lien against property that is the subject of a mortgage foreclosure. Also, with an intervention in a mortgage foreclosure without naming the United States but where its lien may be affected (e.g., if the lien was filed after the mortgage foreclosure action began). It may involve a cross-claim when the taxpayer and United States are both defendants in an interpleader action. Settlement Authority: When a case has been referred to the Department of Justice (DOJ), either the Tax Division or US Attorney, DOJ has settlement authority (IRC 7122, Compromises). The IRS has no authority to settle these cases. Depending upon the nature of the action, the litigation may be handled by either a civil trial attorney in the Tax Division or an Assistant U.S. Attorney in the local U.S. Attorney's Office. Any actions taken in litigation cases must be coordinated through the Area Counsel Attorney assigned to the case unless the case is of the type that may be handled solely by the local U.S. Attorney's Office. Example: Certain types of cases that are brought against the IRS under section 28 USC 2410 (e.g., foreclosure, quiet title, condemnation), will also be assigned to an Area Counsel Attorney. This IRM provides instructional procedures for CEASO Advisory when controlling litigation cases. See also: IRM 25.3.1, Litigation and Judgments, General Guidelines. Policy Statements for Collection are located in IRM 1.2.1.6, Policy Statements for the Collecting Process. Delegation Orders for Collection are located in IRM 1.2.2.6, Delegations of Authority for the Collecting Process, IRM 1.2.2.15, Delegations of Authority for Special Topics Activities, and in IRM 1.2.65.3, SB/SE Functional Delegation Orders - Collection.
Roles and Responsibilities
25.3.7.1.3 (08-30-2022) Roles and Responsibilities IRM 5.17.1, Legal Reference Guide for Revenue Officers, General Information, provides a list of the parties with an explanation of their role with suits.
Program Management and Review
25.3.7.1.4 (08-30-2022) Program Management and Review Program Reports: Suits are individual to the case and are of a wide variety and scope. CEASO advisors are required to monitor their ongoing litigation and open judgment cases annually and more frequently if appropriate. There are several reporting tools assisting advisors with this task and they notate the status in the Integrated Collection System (ICS) history. CEASO Advisor Sources for Monitoring Status of Litigation and Judgments Source Description Area Counsel Updates from the attorney assigned the case. Department of Justice (DOJ) Updates from the attorney assigned the case Collection updates from the Financial Litigation Unit (FLU). eApproval SharePoint application Provides reports based on the available data points for CEASO Advisory group managers and advisors to monitor that system's litigation inventory after submission to Counsel. Form 14187, Periodic Open Litigation Case Review This report is a best practice as its design assists in keeping an accurate status of assigned open litigation inventory. In its Portable Document Format (PDF) format it can be uploaded to eApproval. If the PDF format is exported to Word, it can be copied into ICS. Form 14188, Judgment Case Checksheet This report is a best practice as its design assists in keeping an accurate status of assigned open judgment inventory. In its PDF format it can be uploaded to eApproval. If the PDF format is exported to Word, it can be copied into ICS. Litigation Accounts Management System (LAMS) Non-insolvency TC 520 reports allow advisors to monitor their litigation inventory open on the Integrated Data Retrieval System (IDRS). Public Access Court Electronic Record (PACER) PACER provides access to millions of case file documents and docket information for all district, bankruptcy, and appellate courts. These are available immediately after they have been electronically filed. Program Effectiveness: Whenever litigation involving collection matters is pending, ongoing, or liabilities are reduced to judgment, advisors are responsible for coordination with stakeholders, maintaining appropriate internal case controls, and monitoring outcomes. CEASO Advisory responds to requests for assistance and queries from Counsel and DOJ.
Program Controls
25.3.7.1.5 (08-30-2022) Program Controls CEASO Advisory monitors open litigation (TC 520s) using the non-Insolvency portion of the Litigation Accounts Management System (LAMS) reports. See IRM 25.3.8.4.1, Litigation Account Management System (LAMS) and IRM 25.3.7, Reconciling Non-Insolvency LAMS Reports. eApproval metadata allows for operational and ad hoc reviews of selected inventory. Collection CEASO Advisory maintains a copy of any suit documentation until the suit is closed. After case closure see Document 12990, Records Control Schedules, under section Internal Revenue Service Records Control Schedule (RCS) 28, Tax Administration Collection, in: PART III - Administrative Records - All Collection Functions, item number 38, Litigation Files, and in PART IV - Delinquent Accounts, Delinquent Returns, And Office Services Records, item 45, Suits to Foreclose Federal Tax Liens, item 53, Civil Suit Recommendation, Form 4477, and in item 54 (a), Special Procedures Function Case Files. Preserving electronically stored information is covered in: IRM 25.3.1.7, Preserving Electronically Stored Information In Litigation Cases, IRM 25.3.1.7.21, References, and Chief Counsel Notice 2016-005. CEASO Advisory Managers verify program and procedural compliance by conducting case reviews, performance reviews, and security reviews. Prescribed internal controls are detailed in IRM 1.4.53, Advisory and Property Appraisal and Liquidation Specialist Group Manager Operational Aid, which communicates responsibility to Civil Enforcement Advice and Support Operations (CEASO) managers for promoting quality case work and required internal controls. The ICS, ENTITY Case Management, Embedded Quality Review, and National Quality Review Systems provide the case access, data and reports used by managers to monitor internal controls.
Terms and Acronyms
25.3.7.1.6 (08-30-2022) Terms and Acronyms The terms and acronym table is below. Term or Acronym Description ACS Automated Collection System AIS Automated Insolvency System ALS Automated Lien System ASED Assessment Statute Expiration Date BAL DUE Balance Due BEARS Business Entitlement Access Request System BMF Business Master File cc Closing Code CDP Collection Due Process CEASO Civil Enforcement Advice and Support Operations CIO Centralized Insolvency Organization CSED Collection Statute Expiration Date Counsel Throughout this IRM section, the term "Counsel" will refer to either the Area Counsel Attorney assigned to the case or the local Assistant U.S. Attorney, if the case is being handled solely by that office. DOJ Department of Justice eApproval SharePoint application for review and approval of suit recommendations EH Equivalent Hearing FDCPA Federal Debt Collection Procedures Act FLU Department of Justice Tax Division Financial Litigation Unit FORT Field Office Resource Team FRC Federal Records Center ICS Integrated Collection System IDRS Integrated Data Retrieval System IMF Individual Master File IRC Internal Revenue Code KM Knowledge Management LAMS Litigation Account Management System Metadata Set of data that describes and gives information about other data and allows report building. Example: Some examples of basic metadata for eApproval include: taxpayer name and TIN, case action, created by, date created, date modified, etc. MOIC Monitoring Offer in Compromise NFOI Non-Field Other Investigation NFTL Notice of Federal Tax Lien OI Other Investigation PACER Public Access Court Electronic Record PDF Portable Document Format RCS Records Control Schedules (Internal Revenue Service) SB/SE or SBSE Small Business / Self-Employed Division TBOR Taxpayer Bill of Rights TC Transaction Code TIN Tax Identification Number Treas. Reg. Treasury Regulation ULC Universal Location Code U.S. United States USC / U.S.C. United States Code
Related Resources
25.3.7.1.7 (08-30-2022) Related Resources For procedural guidelines on recommending, working, and responding to suits and claims for damages both for and against the United States, see: IRM 5.17.1, General Information, IRM 5.17.4, Suits by the United States, IRM 5.17.5, Suits Against the United States, IRM 5.17.14, Fraudulent Transfers and Transferee and Other Third Party Liability, IRM 25.3 series, Litigation and Judgments, IRM 34.1.1, Jurisdiction of the District Courts. Suit Resources page, page which contains program related videos as well as the suit forms User Guides, examples of the most common suit types, the Basis Tool, and Excel version of Form 4477-A, Data Capture Spreadsheet (i.e., contains all the data tables for the narrative report), and eApproval, and the eApproval Information Center on Knowledge Management.. 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 Taxpayer Bill of Rights (TBOR).
Introduction to LAMS Reports
25.3.7.2 (08-30-2022) Introduction to LAMS Reports Insolvency LAMS use: There is an entire series of LAMS Reports, used primarily by Insolvency for their -V freeze TC 520 freeze codes. Each of the Insolvency TC 520 reports contain a listing of taxpayer accounts with open TC 520s (i.e., unreversed TC 520s) along with other criteria based on Insolvency's needs. CEASO Advisory LAMS use: The Non-Insolvency LAMS Report is a listing of -W TC 520 freeze codes for taxpayer accounts with one (1) or more open TC 520s utilizing unique -W freeze closing codes (cc). Various stakeholders use the -W TC 520 freeze codes. See IRM 25.3.7.7 subsections and IRM 25.3.8, TC 520 - W Freeze Servicewide Guide for information on the primary stakeholder for a -W TC 520 freeze code. IRM 25.3.8 identifies the primary stakeholders' input, monitoring, and resolution responsibilities. The following is a list of available cc's on the Non-Insolvency LAMS Reports: 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82 and 84. Closing codes 78 and 79 are currently not in use (reserved). Do not post these codes to any litigation account. Closing codes 81 and 84 are used exclusively by Insolvency. Do not post these codes to any litigation account. The inclusion of taxpayer entities on a LAMS report generated for a particular jurisdiction (geographic area) is based on the current Universal Location Code (ULC) as shown on IDRS for these entities. Generally, the ULC of the taxpayer entity would be within the jurisdiction of the CEASO Advisory group assigned to the case, unless the taxpayer moved after the litigation at issue commenced. LAMS data is extracted from IDRS to the Automated Insolvency System (AIS) on a quarterly basis, generally in cycles 04, 17, 30 & 45. LAMS reports may only be retrieved by employees profiled for access. (See IRM 25.3.8.4.1(3), Litigation Account Management System (LAMS). For those CEASO Advisory groups who do not have access, request a Non-Insolvency LAMS Report through the Insolvency Group Manager in that jurisdiction. The CEASO Advisory group's request must specify the following: The ULCs needed (those within the jurisdiction of the CEASO Advisory group making the request), The TC 520 cc's needed for each respective ULC, and Include a request for the "Multiple closing codes" report for each respective ULC. Regardless of when LAMS reports are printed, until new IDRS data has been extracted to AIS, LAMS reports will continue to show the same accounts information even if subsequent changes have been made to those accounts on IDRS. Also, once a new cycle downloads, the data from the prior cycle will no longer be retrievable from AIS. Therefore, it is important to retain copies of (at least) the most recent Non-Insolvency LAMS Reports, along with the supporting documentation of the reconciliation. Retention of this data will likely be beneficial in analyzing and reconciling the next of Non-Insolvency LAMS reports issued.
Non-Insolvency LAMS Report Output Formats
25.3.7.2.1 (08-30-2022) Non-Insolvency LAMS Report Output Formats LAMS report formats are discussed in IRM 25.3.8.4.1, Litigation Account Management System (LAMS). See: Table titled, Creating a LAMS Report, in (4), the steps starting with Result, and IRM 25.3.8-2, Export LAMS Report to Excel.
Contents of Non-Insolvency LAMS Reports
25.3.7.2.2 (08-18-2025) Contents of Non-Insolvency LAMS Reports The Non-Insolvency LAMS Reports contain fourteen (14) data fields. Listing headers for these fields vary slightly depending on the Report Output Format selected, and portions of some SPREADSHEET (Excel) headers may be hidden unless expanded further for full viewing (where headers vary for SPREADSHEET versus PDF or HTML, the SPREADSHEET header is listed first below). These fields are: LAMS Data Fields Column Title Definition 1 ULC Universal Location Code 2 TIN Taxpayer Identification Number 3 TFS/TFC Taxpayer File Source or Taxpayer File Code - This field may be blank or contain a literal "*, N, V, W, P, or X". 4 NC Name Control 5 DOD Date of Death 6 MFT Master File Transaction 7 Tax Period Tax Period 8 UNREV 520 CYCLE1/520 Cycle 1 IDRS input cycle of the first TC 520 cc listed - see CC1 9 CC1 First TC 520 cc listed, but not always the first TC 520 cc input. 10 Recent CSED Collection Statute Expiration Date indicator: P = Primary; S = Secondary; B = Both 11 UNREV 520 CYCLE2/520 Cycle2 IDRS input cycle of the second TC 520 cc listed - see CC2 12 CC2 Second TC 520 listed, if any, but not always the second TC 520 cc input. 13 Prior CSED Collection Statute Expiration Date indicator: P = Primary; S = Secondary; B = Both 14 Taxpayer Name/Taxpayer Taxpayer name 15 Assessed Balance/Assessed Mod Bal The assessed balance due of the account listed as of the date the data was extracted from IDRS.
Universal Location Codes (ULCs)
25.3.7.2.3 (08-30-2022) Universal Location Codes (ULCs) Taxpayer entities listed on LAMS reports are based on the current geographic location/ULC (primary location or "PRIMARY-LOC>" on IDRS) of the taxpayer. Accordingly, some taxpayer entities listed on the LAMS reports may not be in the same location as the CEASO Advisory group that initiated the TC 520(s) input. Because taxpayer entities shown on LAMS reports are based on the current geographic location of the taxpayer, the Non-Insolvency LAMS Reports may not be all-inclusive for the TC 520 cases that have been initiated and are being controlled in any given area. Coordination with other CEASO Advisory groups is therefore essential for ensuring the timely resolution of TC 520s when an entity appears on the report generated for a particular area, but the case is not being controlled by an advisor in that area. Use Publication 4235 or the SERP (Who/Where Tab) to locate the CEASO Advisory Groups. Access the IRM 5.19.1, Balance Due, at the following link for a complete ULC listing assigned by state: - Universal Location Code (ULC) and Area Office (AO). This listing also includes Area Office (AO) assignments within each BOD code.
CEASO Advisory Responsibility for TC 520s
25.3.7.3 (08-30-2022) CEASO Advisory Responsibility for TC 520s The advisor's responsibility includes reconciling the LAMS report at least annually. While on the look-out for posting errors, pay additional attention where a TC 520 posting has aged six or more years without obtaining a judgment. The CEASO Advisory group that initiates TC 520 input(s) is required to keep an open case on ICS and maintain proper litigation case controls. This includes ensuring that any required TC 550 statute extensions, TC 521 closures, and TC 522 corrections are input correctly, post to IDRS timely, and closed or corrected on IDRS timely and correctly. Therefore, it is critical for CEASO Advisory to open an ICS case for each (TIN driven) entity for which it initiates a TC 520 input. CEASO Advisory's reconciliation responsibility includes taxpayer accounts with TC 520 cc 70, 75, 80, 82, and MFT 55 (TC 240 Penalty Code 618 for TFRP only) accounts for cc 71 and 73. (Campus Refund Litigation Units are responsible for all other MFTs/non-TFRP MFT 55 accounts for TC 520 cc 71 and 73). For more information and a complete listing of all Non-Insolvency cc, see IRM 25.3.7.7, TC 520 Closing Codes, below and IRM 25.3.8.2(4), the tables titled, Closing Code Resulting Actions, and What the Litigation Closing Codes Indicate. Note: Prior to IRM revisions in June 2005, TC 520 cc 81 was also used by CEASO Advisory on all tax periods for which a proof of claim was filed in a probate case. Closing code 80 is now used in probate cases when the collection statute has been suspended under IRC 6503(b), Suspension of running of period of limitation, due to assets of the probate estate being in the control or custody of the court. For additional references for advisor TC 520 responsibilities see: IRM 25.3.5, Judgment Follow-up, IRM 25.3.6, Open Litigation Control, Monitoring and Closing Actions, and IRM 25.3.8, TC 520 - W Freeze Servicewide Guide.
Instructions for Generating Non-Insolvency LAMS Reports
25.3.7.4 (08-30-2022) Instructions for Generating Non-Insolvency LAMS Reports For instructions on generating a Non-Insolvency LAMS report see: IRM 25.3.8.4.1, Litigation Account Management System (LAMS), IRM 25.3.8.4.1(3), table titled, Steps to Gain Access Business Objects for LAMS Reports, IRM 25.3.8.4.1(4), table titled, Creating a LAMS Report, IRM 25.3.8-1, REPORT: LAMS Non-Insolvency Case Listing – ULC & cc Prompts, and IRM 25.3.8-2, Export LAMS Report to Excel.
Reconciliation Process
25.3.7.5 (08-18-2025) Reconciliation Process Research the Integrated Collection System (ICS) to determine if there is an open CEASO Advisory case control for each taxpayer entity. If found: Note the LAMS listing with the case code and ICS assignment for open cases within your CEASO Advisory jurisdiction. Document the ICS history "Open TC 520 ccXX LAMS case" replacing "XX" with the actual cc(s) for each MFT/tax period listed. If you find a case that is not within your CEASO Advisory jurisdiction, note the LAMS listing with the case code and the ICS assignment of the office to which it is assigned and document the ICS history "Open TC 520 ccXX LAMS case," including the MFT/tax periods to which the TC 520(s) have been input. This will generate a notification to the assigned advisor due to your non-assigned case access and will aid in proper TC 520 case controls. If the LAMS listing also has a corresponding presence on eApproval, notate that in the ICS history. If a CEASO Advisory case is not open on ICS, review ICS closed case or archive histories (if any). If the CEASO Advisory case was previously worked on ICS, the history may provide sufficient information to determine the proper status and disposition of the account. Archived case information is available online when connected to the LAN (See Chapter 9 – Entity Detail of the ICS User Guide) and can be requested for cases closed on ICS more than six months but less than three years when needed. If the information to resolve a case within your CEASO Advisory jurisdiction is found to have been closed on ICS, open new ICS case controls, and take the proper action to resolve any unreversed TC 520(s). If a TC 550 is required, it must be input with the proper definer code prior to reversal of the TC 520. If ICS closed case or archive data is found on a case that is not within your CEASO Advisory jurisdiction, send the LAMS case data to the appropriate CEASO Advisory group for resolution. LAMS data can be sent electronically via Secure Message or in hardcopy using Form 3210. Document your copy of the LAMS listing with the disposition and associate any relevant documentation (ICS archive, Form 3210, Secure Message, etc.) with your LAMS listing for future reference. If no open, closed, or archived data is on ICS, review IDRS: Action Item List Item Action 1 Review for any TC 521 closure, or TC 522 correction that has gone unpostable. 2 Review the Document Locator Number (DLN) for each TC 520. Due to centralization, the first two digits of most TC 520 inputs will reflect the DLN of the campus location where the input was made. Due to various campus location centralization projects, the first two digits of TC 520 input DLNs may reflect the ULC of the location that no longer exists, that location initiated the TC 520 inputs prior to being centralized. 3 Also review DLNs of other inputs (TC 300s, etc.) to help identify the location/origin of the TC 520 input. 4 Check for multiple TC 520s. Each TC 520 for which CEASO Advisory has responsibility must be reconciled. 5 Utilize ENMOD and/or INOLES to look for x-ref Taxpayer Identification Numbers (TINs) for spouse, or d/b/a Employer Identification Numbers (EINs) of related entities. A TC 520 may have been input on accounts for all related entities, but a prior TC 521 closure or TC 522 correction may only have been input on one of the x-ref entities. The LAMS Report (or IDRS INOLES, depending on the timing of the IDRS data extraction) may also provide a DOD (date of death) on a decedent case. 6 Check IDRS for TC 52X activity on other tax periods. You may find TC 521 closures input to other tax periods for the cc you are researching. 7 Check the IDRS cycle of the TC 520 for the year of input. The IDRS cycle year may be much more current than the actual date of the TC 520, indicating more recent CEASO Advisory account activity. 8 Check history and control bases (open and/or closed) on IDRS TXMOD and/or ENMOD for data regarding the nature of case activity. 9 Utilize IDRS IRPTRL, RTVUE, and/or BRTVU for other possible address information that may help to identify the origin of the CEASO Advisory group that initiated the TC 520 input. 10 On unidentified cases that are new to your LAMS Report listing (not listed on the last LAMS reports run), but that contain TC 520s prior to the current year, check ENMOD for a recent change of address. On ENMOD, see ADDR-CHG-CYC> (this field is located to the right of the street address of the taxpayer and will contain the IDRS input cycle of the most recent change of address). 11 Look for any and all clues IDRS may provide. If there are current or prior criminal investigation (CI) freeze code inputs (TC 910, TC 914, TC 918), contact the respective CI coordinator for that area for additional information that may assist in the reconciliation process. 12 On imminent CSED, high-dollar, and/or high-profile cases, use IDRS ESTAB (using the DLN of the TC 520) to secure a copy of the document used to request the TC 520 (i.e. Form 3177, Form 4844, etc.) toward identification of the requestor of the input. Use PACER (Public Access to Court Electronic Records) to research suits, judgments, etc. (access requires Business Entitlement Access Request System (BEARS) approval) to locate information on open/closed court cases. Names searches can be done by using various court venues, including the nationwide U.S. Party Case Index. Access the PACER home page to review all available research options. Contact the Department of Justice and/or your local Area Counsel to request a search to identify assignment of an open or closed case on their respective case data bases. If a TC 520 input was requested by another CEASO Advisory group, request reconciliation by that CEASO Advisory group. Note: Do not reverse any TC 520s requested by another CEASO advisor. It is the responsibility of the CEASO advisor who requested input of the TC 520 to ensure that the code is still valid or take proper closing actions to complete and resolve the case. Retain copies of reconciliation information/documents with the Non-Insolvency LAMS Report so discrepancies on future reports can be analyzed more readily.
Reversing or Correcting TC 520 and TC 550 Updates
25.3.7.6 (08-30-2022) Reversing or Correcting TC 520 and TC 550 Updates TC 550 CSED Extension: When a CSED extension is required, prepare Form 4844 for TC 550 input, including the required definer code, prior to requesting input of the TC 521 (e.g., judgments use definer code 04). See IRM 5.1.19.2.3(2), TC 550 Waiver Extension Definer Codes, for a complete list of TC 550 definer codes. On any modules requiring a TC 550 input, the transaction date of the TC 550 must be greater than (after) the transaction date of the open (unreversed) TC 520; the transaction date of the subsequent TC 521 input must be after the transaction date used for the TC 550. The TC 550 new CSED is the date the judgment signed plus 20 years. Resolving TC 520: Prepare Form 4844, Request for Terminal Action, requesting: TC 521 input to CLOSE: For closures of litigation or judgments, use the TC 521 to close the -W freeze. Note: A few -W freeze TC 520 cc(s) require that the cc also be used when the TC 521 is input; most do not. If an incorrect TC 521 (cc or no cc) is used, the transaction will go unpostable on IDRS. All -V bankruptcy freeze TC 520s require a cc when the corresponding TC 521 is input with the exception of cc 83. See Document 6209, IRS Processing Codes and Information, TC 520 Closing Code Chart, for more information. See also IRM 25.3.8, TC 520 - W Freeze Servicewide Guide. Caution: A TC 521 with no cc will close all open TC 520 -W freezes not requiring a cc to resolve. This includes any TC 520 cc 70, 71, 72, 74, 75, 80, 82, and 84. Example: Do not input a TC 521 to close the -W freeze where a TC 520 cc 80 or 82 holds open the CSED unless the action holding the CSED open (e.g., a judgment) has also resolved. TC 522 input to CORRECT: TC 522 input is used to reverse any TC 520 input erroneously (e.g., posted to an incorrect module or incorrect TIN). FORWARD Forms 4844 to the appropriate Centralized Case Processing (CCP) Unit for your area. Form 4844 can be completed using the ICS template, then forwarded to the appropriate area e-mail box using the ICS electronic e-mail box. This is dependent on availability of local tax examiners assisting groups. Also, in accordance with IRM 25.3.6.5.3.1, Assistance from the Field Office Resource Team (FORT), utilize FORT assistance when needed, after securing appropriate managerial approval. MONITOR the input of the TC 550, TC 521, or TC 522 to ensure proper posting and updating on IDRS prior to closing the ICS case. Occasionally, inputs become unpostable. If this happens, IDRS must be analyzed to determine the cause of the problem and initiate the appropriate correction. For unpostable TC 550 inputs, see the Unpostable Codes in Section 8 of the IRS Processing Codes and Information book, Document 6209. Specifically, review UPC 178 reason codes for IMF and UPC 344 for BMF to aid in determining the corrective input action needed.
TC 520 Closing Codes
25.3.7.7 (08-30-2022) TC 520 Closing Codes The characteristics of each cc are specified as per the IRS Processing Codes and Information book (Document 6209). Some IRM references are provided, and procedural recommendations are included for reconciliations. The following subsections list the TC 520 cc for each type of LAMS Non-Insolvency Listing. Follow the procedures in IRM 25.3.7.5, Reconciliation Process, above, for the cc CEASO Advisory has responsibility to reconcile. IRM 25.3.8, TC 520 - W Freeze Servicewide Guide, covers the other stakeholders monitoring the cc within their scope of responsibility. Other stakeholders might utilize their own monitoring processes rather than using LAMS. Not Covered in this IRM: The following closing codes are not covered in this IRM for the reasons indicated. Closing code (cc) 78 and cc 79 - reserved and currently not programmed for use, and Closing code (cc) 81 and cc 84 - used by Insolvency for bankruptcy cases.
TC 520 cc 70
25.3.7.7.1 (08-18-2025) TC 520 cc 70 TC 520 cc 70 is used for suits by or against the United States when the following case controls are appropriate: The CSED is NOT suspended; and Account status IS changed to Status 72 on IDRS. Generally, TC 520 cc 70 is used for the following suits: Foreclosure of Federal tax lien only (cc 80 is used in a suit for both lien foreclosure and reducing assessments to judgment) Open safe deposit box Injunction action (again, cc 80 would also be used in a suit for injunctive relief wherein the suit is also seeking judgment for the underlying taxes involved) Wrongful levy Recent changes in the use of cc 70 and 80 are highlighted below. CC 70 and 80 Reminders Item Description 1 Currently foreclosure suits in addition to judgements use cc 80 when the CEASO advisor preps for Counsel in eApproval or earlier if there is an imminent CSED. Historically, foreclosure suits prior to complaint filing utilized a cc 70. For foreclosures or judgments, when reconciling LAMS, ensure there are no stand-alone cc 70s 2 Generally referrals include both the foreclosure and reduce claims to judgment at the behest of Counsel and Department of Justice (DOJ). It is important to use the TC 520 cc 80 for these referrals. 3 REFERENCE:IRM 25.3.6.3.2.3, TC 520 cc 80 Importance and Input Timing. Note: From January 18, 1999, to January 1, 2000, cc 70 was also designated for use in Collection Due Process (CDP) cases. Any taxpayer account with a TC 520 cc 70 input prior to January 18, 1999, should be researched further by CEASO Advisory as these would not be CDP cases. On cases where CDP TC 520s cc 70 may still be outstanding in error, contact Appeals at *AP Account Resolution, or *AP Inquiries.
TC 520 cc 71
25.3.7.7.2 (08-18-2025) TC 520 cc 71 TC 520 cc 71 is used for Refund Litigation cases when the following case controls are appropriate: The CSED is NOT suspended, and Account status is NOT change to status 72 on IDRS. When a refund claim or suit on a Trust Fund Recovery Penalty (TFRP) case is filed, and it does not meet the criteria for input of TC 520 cc 82, (see IRM 25.3.7.7.9, below), TC 520 cc 71 may be used. Since the MFT 55 account at issue will not be suspended to Status 72 with this TC 520 input, it simply creates a -W freeze on the account. If the claim review indicates that the TFRP assessment is not likely to be sustained due to IRS error, strong consideration should be given to using TC 520 cc 73, see IRM 25.3.7.7.4, below. If Collection action continues on a TFRP assessment that cannot be sustained, the taxpayer may be successful in pursuing additional legal action against the IRS later. If a counterclaim for judgment is filed by the Department of Justice in a TFRP refund suit, a TC 520 cc 80 would would be used to stay the CSED instead of a TC 520 cc 82; see IRM 25.3.7.7.8, below. CEASO Advisory is responsible for reconciling TC 520 cc 71 inputs on MFT 55, TC 240 Penalty Code 618 TFRP accounts only. Note: Employment tax refund litigation other than TFRP would be processed by W&I. See IRM 25.3.7.7.4, TC 520 cc 73. Reminder: If a counterclaim for judgment is filed by the Department of Justice in a TFRP refund suit before input of a TC 520 cc 82, then there is an option to use a TC 520 cc 80 instead of a TC 520 cc 82. If the TC 520 cc 82 posted previously, do not input the TC 520 cc 80. While both stay the CSED, posting both on the same module causes an IDRS unpostable. Avoid use of both TC 520 cc 82 and TC 520 cc 80 in the same module.
TC 520 cc 72
25.3.7.7.3 (12-16-2011) TC 520 cc 72 TC 520 cc 72 is used for Tax Court cases controlled by Appeals, and has the following attributes: The CSED is NOT suspended, and Account status is NOT changed to Status 72 on IDRS. Accounts on this list are controlled by Appeals; therefore, there is no requirement for CEASO Advisory to request or reconcile this listing.
TC 520 cc 73
25.3.7.7.4 (08-18-2025) TC 520 cc 73 TC 520 cc 73 is used for Refund Litigation when the following case controls are appropriate: The CSED is NOT suspended, and Account status IS changed to Status 72 on IDRS. Because this cc suspends the module from active collection to Status 72 on IDRS, but does not suspend the CSED, it is used by W&I Refund Litigation Coordinators. They are responsible for this type of litigation for all MFTs other than MFT 55 and for all non-TFRP MFT 55 accounts. See IRM 25.3.8.3.1, Refund suits. CEASO Advisory only has responsibility for MFT 55, TC 240 Penalty Code 618 TFRP accounts in refund litigation. See IRM 25.3.7.7.2 Refund Litigation. Note: CEASO Advisory should use TC 520 cc 82 on TFRP refund litigation suits if needed to suspend the CSED. See IRM 25.3.7.7.9, for TC 520 cc 82 criteria. Reminder: If a counterclaim for judgment is filed by the Department of Justice in a TFRP refund suit before input of a TC 520 cc 82, then there is an option to use a TC 520 cc 80 instead of a TC 520 cc 82. If the TC 520 cc 82 posted previously, do not input the TC 520 cc 80. While both stay the CSED, posting both on the same module causes an IDRS unpostable. Avoid use of both TC 520 cc 82 and TC 520 cc 80 in the same module.
TC 520 cc 74
25.3.7.7.5 (08-30-2022) TC 520 cc 74 TC 520 cc 74 is used for Tax Court cases controlled by Area Counsel who may request a TC 520 cc 74 be input on modules where they specifically want to restrict Collection notices being issued to a taxpayer. (See IRM 25.3.8.3.2 , Tax Court). The following case controls are appropriate: The CSED is NOT suspended, and Account status IS changed to Status 72 on IDRS. Appeals and Counsel have jurisdiction over Tax Court cases. Sometimes the cc 74 is erroneously input. Generally this is the case if there is no Appeals office code posted to IDRS. Note: CEASO Advisory does not reconcile this listing but if, for any reason, Area Counsel requests CEASO Advisory assistance regarding such a listing, CEASO Advisory should alert Area Counsel to any Appeals office code posted on the module(s) or that the cc may have been input in error. If Counsel wants CEASO Advisory to monitor the case, recommend use of the TC 520 cc 70, which has the same case controls as cc 74 and also restricts Collection notice issuance.
TC 520 cc 75
25.3.7.7.6 (12-16-2011) TC 520 cc 75 TC 520 cc 75 is used for litigation cases when the following case controls are appropriate: The CSED is NOT suspended, and Account status is NOT changed to Status 72 on IDRS. An example of a case where use of TC 520 cc 75 would be appropriate is a Failure to Honor Levy suit, particularly where only a partial satisfaction of a taxpayer's balance due would be realized. In an action of that type, the liability would remain open for additional collection activity as warranted. Input of TC 520 cc 75 simply creates a -W freeze on the account and alerts other IRS employees of the litigation.
TC 520 cc 76 and 77
25.3.7.7.7 (08-30-2022) TC 520 cc 76 and 77 TC 520 cc 76 was created for use in Collection Due Process (CDP) cases under IRC 6320 (filing of Notice of Federal Tax Lien); and TC 520 cc 77 was created for use in CDP cases under IRC 6330 (levies). These cc have the following attributes: The CSED is suspended, and Account status IS changed to Status 72 on IDRS. Note: Historically, TC 520 cc's 76 and 77 were created for use in CDP cases effective January 1, 2000. See IRM 25.3.7.7.7. There may be some older cases where a TC 520 cc 70 continued to be used (in error) in some CDP cases filed after January 1, 2000 TC 520 cc 76 and 77 inputs are requested by Appeals, and these cases are controlled by Appeals in conjunction with Collection. Therefore, there is no requirement for CEASO Advisory to request or reconcile this listing. Exception: The Automated Collection System (ACS) CDP unit inputs the TC 520 cc 76 and 77 for cases within their scope of responsibility. See IRM 5.19.8.4.9(8), Forwarding Cases to Appeals, and IRM 5.1.9.3.3(12), Processing CDP and Equivalent Hearing (EH) Requests. Although, Appeals reverses the TC 520s after making their determination. See IRM 5.1.9.3.11(1), After the Appeals Determination is Final.
TC 520 cc 80
25.3.7.7.8 (08-18-2025) TC 520 cc 80 TC 520 cc 80 is used in a number of different situations when the following case controls are appropriate: The CSED is suspended, and The account status is changed to Status 72 on IDRS. TC 520 cc 80 is most commonly used in a Suit to Reduce Assessments to Judgment. The CSED is suspended upon the filing of the suit under IRC 6502(a), Collection after assessment. Input of the TC 520 cc 80 occurs when the suit is routed to Counsel by the advisor during eApproval's prep for Counsel actions. This prevents an early or unexpected expiration of the CSED. If the CSED is imminent, the TC 520 cc 80 may be input even earlier than the eApproval prep for Counsel action, when necessary. See IRM 25.3.6.3.2.2, Cases With Imminent CSEDS. Caution: Contact the Centralized Insolvency Operation (CIO), if an account is in bankruptcy and risks discharge during litigation or after a judgment or DOJ settlement of litigation. Inform CIO of any litigation in bankruptcy court or district court, including prior litigation implicating DOJ's authority to determine dischargeability or the survival of liens against pre-bankruptcy assets (IRC 7122, Compromises, and IRC 25.3.6.1.2(3), Settlement Authority) Recent changes in the use of cc 70 and 80 are highlighted below. CC 70 and 80 Reminders Item Description 1 Currently foreclosure suits in addition to judgements use cc 80 when the CEASO advisor preps for Counsel in eApproval or earlier if there is an imminent CSED. Historically, foreclosure suits prior to complaint filing utilized a cc 70. For foreclosures or judgments, when reconciling LAMS, ensure there are no stand-alone cc 70s 2 Generally referrals include both the foreclosure and reduce claims to judgment at the behest of Counsel and Department of Justice (DOJ). It is important to use the TC 520 cc 80 for these referrals. 3 REFERENCE:IRM 25.3.6.3.2.3, TC 520 cc 80 Importance and Input Timing. In a successful Suit to Reduce Assessments to Judgment, a TC 550 (definer code 04) must be input prior to reversal of TC 520. TINs on the cc 80 list should be screened against ICS to identify active CEASO Advisory cases. ICS Archive Transcript reviews may also be needed for CEASO Advisory cases that were previously closed but for which there may have been a failure to complete IDRS inputs, including required TC 550 CSED extensions and TC 520 reversals. Reminder: Although a TC 520 cc 80 suspends the CSED on a respective TXMOD to which it is input, it will not systemically extend the CSED when it is reversed. If a CSED extension is warranted (i.e., a judgment is granted), a TC 550 (definer code 04) must be input. The TC 550 must be input prior to input of the TC 521. See IRM 25.3.5.4.2, Additional Procedures for Judgments for Assessed Liabilities. The transaction date of the TC 550 must be after the transaction date of the TC 520, but before the date of the original CSED. The transaction date of the subsequent TC 521 input must be after the transaction date used for the TC 550. TC 520 cc 80 is also used to keep an account open in order to post payments that are received after the CSED. Credits posted to a TXMOD after a TC 520 cc 80 has been input but prior to its reversal, will not refund, even if the collection statute is shown to be expired upon subsequent input of the TC 521. In order to ensure that payments will not refund, TC 520 cc 80 is used in the following circumstances: To suspend the CSED pending application of sale proceeds from a pre-CSED seizure – see IRM 5.1.19.4(3), CSED Payment Application. To suspend the CSED pending application of levy proceeds to expired module(s) from a Notice of Levy that was served pre-CSED – see IRM 5.1.19.4(4), CSED Payment Application. Note: Proceeds from a Notice of Levy on Wages, Salary and Other Income that was served pre-CSED and for which wages were earned pre-CSED may only be applied to modules for which the CSED expires thereafter. TC 520 cc 80 is also used in probate cases when the collection statute is suspended due to assets of the probate estate being in the control or custody of the court – see IRC 6503(b).
TC 520 cc 82
25.3.7.7.9 (08-18-2025) TC 520 cc 82 TC 520 cc 82 is used in cases involving the divisible employment tax such as Trust Fund Recovery Penalty (TFRP) when the following case controls are appropriate: The CSED is suspended, and The account status is changed to Status 72 on IDRS. References: IRM 5.7.7.5.2 Withholding Collection — IRC 6672(c), Policy Statement P-5-16 in IRM 1.2.1.6.4(5), Forbearance when refund suit is pending on a divisible assessment, IRM 25.3.6.3.2.1, Trust Fund Recovery Penalty (TFRP) Litigation, for more information regarding the situations where the IRS is required to withhold collection of a TFRP assessment. IRC 6672(c), Extension of period of collection where bond is filed, IRC 6331(i), No levy during pendency of proceedings for refund of divisible tax, and Exceptions to levy suspense in IRC 6331(i)(3)(A), Exceptions, Certain unpaid taxes. The transaction date of a TC 520 cc 82 input would be either the date the taxpayer complied with the requirements of IRC 6672(c), or the date of the filing of a civil suit for refund in a district court case. TC 520 cc 82 is used to stay collection until the final resolution of court proceedings and the taxpayer's claim for a refund. See also IRC 6331(i)(6), Pendency of proceeding. Note: Although a TC 520 cc 82 suspends the CSED on the respective TXMOD to which it is input, it will not systemically extend the CSED when it is reversed. If the Government is not successful in its defense of a TFRP refund suit, the TFRP assessment must be abated or adjusted in accordance with the court's ruling. Generally, the Government will file a counterclaim for judgment of the divisible employment tax TFRP. If the TC 520 cc 82 has posted to stay the CSED, there is no need to input another CSED stay (i.e., TC 520 cc 80) as the TC 520 cc 80 will go unpostable. If a judgment is obtained, a TC 550 with definer code 04 will be input to extend the CSED for 20 years from the date the judgment was entered prior to input of any TC 521. See IRM 25.3.5.4.2, Additional Procedures for Judgments for Assessed Liabilities.
Bankruptcy Closing Codes
25.3.7.8 (08-30-2022) Bankruptcy Closing Codes Note that input of a -V freeze bankruptcy (or other) TC 520 cc might supersede a CEASO Advisory or other -W freeze Non-Insolvency TC 520 for purposes of the Non-Insolvency LAMS Report. In other words, a case that is still open as a suit might drop from a TC 520 cc 70 report if the taxpayer subsequently files a bankruptcy petition for which a TC 520 cc 85 (or other bankruptcy cc) is input. These cases should then appear on the "Multiple closing codes" Non-Insolvency LAMS Report for a given ULC. See the instructions in IRM 25.3.8.4.1, Litigation Account Management System (LAMS). Whenever a taxpayer entity is identified as having both an open CEASO Advisory-controlled (TC 520) case and an open bankruptcy case, CEASO Advisory and Insolvency personnel should closely coordinate with one another to ensure that neither CEASO Advisory nor Insolvency erroneously reverses the TC 520 inputs of the other. Note: When a taxpayer files bankruptcy, the automatic stay prohibits the commencement or continuation of a judicial or other civil action against the debtor (taxpayer). Accordingly, relief from the automatic stay must be obtained before any pending actions against the debtor may proceed. Caution: Contact the Centralized Insolvency Operation (CIO), if an account is in bankruptcy and risks discharge during litigation or after a judgment or DOJ settlement of litigation. Inform CIO of any litigation in bankruptcy court or district court, including prior litigation implicating DOJ's authority to determine dischargeability or the survival of liens against pre-bankruptcy assets (IRC 7122, Compromises, and IRC 25.3.6.1.2(3), Settlement Authority)
Source: official text