Internal Revenue Manual
IRM 4.29.5 — PCS TEFRA/ILSC Notices and Cover Letters
Part 4. Examining Process
Chapter 29. Partnership Control System (PCS) Section 5. PCS TEFRA/ILSC Notices and Cover Letters 4.29.5 PCS TEFRA/ILSC Notices and Cover Letters Manual Transmittal August 15, 2019 Purpose (1) This transmits a revision for IRM 4.29, Pass-Through Control System (PCS), Section 5, PCS TEFRA/ILSC Notices and Cover Letters Material Changes (1) Change to Title. Changed title from Partnership Control System (PCS) to Pass-Through Control System (PCS). PCS is used to manage S-corporations as well as partnerships. Pass-through control is more reflective of the systems function. (2) IRM 4.29.5.1 - Program Scope and Objectives. Added acronyms to the first use of commonly used terms. Added paragraph (8) for contact information and removed the contact information from IRM 4.29.5.1.1 paragraph (2). (3) IRM 4.29.5.1.1. - Background. Remove paragraph (2) and moved the contact information to IRM 4.29.5.1 paragraph (8). (4) Editorial changes made throughout. Updated terminology used, and removed italics from titles. Changed Campus TEFRA Function (CTF) to Campus Pass-through Function (CPF). Spelled out first use of acronyms. Updated name changes to applicable forms and letters. Effect on Other Documents This material supersedes IRM 4.29.5, dated 11/27/2017. Changes to this IRM will also affect the Pass-Through Entity IRM 4.31 Sections 1 through 8. That IRM is currently being rewritten and will include the changes contained in this IRM. Audience Field and campus personnel working TEFRA and ILSC pass-through entities and/or their investors. Effective Date (08-15-2019) Maha H. Williams, Director, Examination - Field and Campus Policy Small Business/Self-Employed (SB/SE) Division
Program Scope and Objectives
4.29.5.1 (08-15-2019) Program Scope and Objectives This Internal Revenue Manual (IRM) section provides an explanation of the different notices available through the Partnership Control System database. Purpose: This IRM is to describe the Pass-Through Control System (PCS) generated notices and settlement letters. Audience: Field Examination Revenue Agents (RAs) and campus RAs, Tax Compliance Offers (TCOs), Tax Examiners (TEs) and Clerks working pass-through entities and/or their investors linked on the PCS. Policy Owner: Director, Small Business/Self-Employed (SB/SE), Headquarters, Examination - Field and Campus Policy (SE:S:E:HQ:EFCP) Program Owner: Program Manager, Campus Examination and Field Support (SE:S:E:HQ:FCP:CEFS) Primary Stakeholders: SB/SE, Large Business and Industry (LB&I), and Appeals Program Goals: PCS is a database used to create an electronic linkage between pass-through entities and their underlying partners. Linking in some instances is mandatory. Linkage allows for the proper control of statutes and ensures all relevant partners are processed. Contact Information: To recommend changes or make any other suggestions related to this IRM section, see IRM 1.11.6.6, Providing Feedback About an IRM Section - Outside of Clearance.
Background
4.29.5.1.1 (08-15-2019) Background PCS was created to monitor and control pass-through entity investors. Pass-through entities can have many partners and many levels of tiering. Tiering occurs when an investor in a pass-through entity is also a pass-through entity. This complexity can make it difficult to keep track of statutes and monitor all the investors.
Authority
4.29.5.1.2 (11-27-2017) Authority PCS control is a policy that was established in response to the partnership provisions of the Tax Equity and Fiscal Responsibility Act (TEFRA) of 1982. It has been expanded to cover other pass-through entities that fall outside of TEFRA.
Responsibilities or Roles and Responsibilities
4.29.5.1.3 (11-27-2017) Responsibilities or Roles and Responsibilities The Director, SB/SE, Headquarters, Examination Field and Campus Policy (SE:S:E:HQ:EFCP) is responsible for: Coordinating and implementing PCS enhancements; Coordinating resolutions for PCS systemic problems; and Updating this Handbook. The SB/SE Program Manager, Examination Field and Campus Policy, Campus Exam & Field Support (SE:S:E:HQ:EFCP:CEFS) is responsible for: Ensuring that PCS procedural changes and computer program changes are implemented and coordinated with area office and campus examination personnel; and Monitoring and evaluating area office and campus examination PCS quality control procedures. Field Territory Managers, Field Area Directors, Director over LB&I Ogden and Director, Examination - Brookhaven, are responsible for ensuring that: An accurate database is established by designating PCS responsibilities and activities; and A PCS quality control system is implemented. This includes timely action on PCS record establishments, PCS reports, and AIMS TC424 Reject Registers. It also includes timely processing of TEFRA notices and Appeals settlement letters (campus only). Area office Examination Managers and campus Field Support Operations managers are responsible for: Maintaining an updated copy of IRM 4.29, Pass-Through Control System (PCS) Handbook, in their respective functions; Ensuring the training of technical and clerical employees in PCS procedures; and Establishing PCS records and acting on PCS reports in a timely manner to assure an accurate PCS database. The campus PCS Coordinator works with: The other PCS coordinator(s) Technical Services TEFRA Coordinators Their local employees Other campus functional areas to ensure timely processing of PCS related activities The campus PCS Coordinator is charged with: Identifying and resolving technical problems Identifying and coordinating the resolution of PCS systemic problems Following are specific campus PCS Coordinator responsibilities: Coordinate PCS operations among areas, Campus Pass-through Functions (CPFs), and other campus functions; Ensure timely processing and distribution of PCS output; Ensure that all requests for establishment and linkage on PCS are reviewed for accuracy, completeness, and timeliness; Maintain accuracy of the PCS database by ensuring that action and error reports are worked in required time frames; Resolve AIMS problems; Assist in the training of examination personnel in PCS procedures and the system; Establish and update CPF and Appeals parameter files; Review completed Form 8346, PCS Notice Parameters, prepared by the CPF; Create, load, print, proofread, and edit parameter file data using Form 8346, PCS Notice Parameters; Coordinate with Computer Systems Analyst (CSA) whenever a change is made to parameters; Review and input all campus Command Code (CC) Mass Change (MSCHG) and linkage deletion (TSDEL) requests; Coordinate requests for PCS IVLs with campus computer services and the requesting function.
Program Management and Review
4.29.5.1.4 (11-27-2017) Program Management and Review Program Reports: PCS generates a variety of reports used to monitor the inventory and related statutes. These reports are explained in detail in IRM 4.29.4, PCS Reports. Program Effectiveness: PCS is used to help identify the effectiveness of the CPF program. PCS shows the number of partners linked within a partnership structure. Failing to link partner returns timely can result in barred statutes or the need to follow burdensome procedures such as manual assessments or untimely notice procedures.
Program Controls
4.29.5.1.5 (11-27-2017) Program Controls PCS is a Integrated Data Retrieval System (IDRS) based system. Access to command codes are restricted based upon need. For example, generally only the PCS Coordinator is allowed to delete records from the system.
Terms/Definitions/Acronyms
4.29.5.1.6 (11-27-2017) Terms/Definitions/Acronyms There are several terms unique to PCS. Examples of these words: Defined Terms Word Definition Key Case A linked pass-through entity that is being examined. This entity is where any pass-through adjustments will originate. Linkage The electronic relationship between a pass-through entity and its investor. One-Year Date This is a statute date applicable only to TEFRA partnerships. Adjustments to the partner returns must be made within one year of a final partnership determination that finalizes the key case adjustments. Record Information stored on the PCS database for a key case or an investor. Tier A pass-through entity that is a partner of a pass-through entity. An S-corporation would be a tier partner of a partnership. See IRM Exhibit 4.29.1-1 for a list of acronyms.
Related Resources
4.29.5.1.7 (11-27-2017) Related Resources The following Internal Revenue Manual cross references may be helpful to PCS coordinators: Terminal Operator Instructions: IRM 2.2 Sections 1–10 Processing: IRM 3.30.123, Processing Timeliness Cycles, Criteria and Critical Dates Handbook Handling of Output: IRM 3.13.62, Media Transport and Control Handbook Management of Interrelated and Related Cases: IRM 4.31, Pass-Through Entity Handbook AIMS: AIMS/Processing Handbook, IRM 4.4
TEFRA Notices
4.29.5.2 (09-02-2008) TEFRA Notices PCS generates all TEFRA notices to TEFRA notice investors. Procedures for processing these notices are contained in IRM 4.31, Pass-Through Entity Handbook.
TEFRA Notice Generation (TSLOD and TSNOT)
4.29.5.3 (01-01-2004) TEFRA Notice Generation (TSLOD and TSNOT) The sub-sections below discuss the various notices required by the statute, and the various notices provided for administrative proceedings. PCS CCs TSLOD and TSNOT are used to generate notices. CC TSLOD is used to establish investors on the PCS database, and will generate a Notice of Beginning of Administrative Proceeding (NBAP) with the proper definer. CC TSNOT will generate a variety of notices depending on the definer used. The generation of the different notices is explained in the following sub-sections.
General Information on Notices and Form 886–Z Investor Listing
4.29.5.3.1 (11-27-2017) General Information on Notices and Form 886–Z Investor Listing Form 8342, PCS Notice Generation, is used to generate TEFRA investor notices (60-Day Letters, Notices of Final Partnership Administrative Adjustment (FPAAs), and Appeals Settlement Letters. Exhibit 4.29.5-2, Instructions for Form 8342, PCS Notice Generation, provides instructions for completing Form 8342. To generate notices, the key case and investor records must both be present on PCS. In addition, the investor must be linked to the TEFRA key case and the investor's TEFRA indicator must be present. If there is a one-year assessment statute date present on the linkage, a letter will not generate for the investor. Notices and forms which can be generated by PCS are: NBAP, 60-Day Letter (investor settlement package), FPAA, Appeals Settlement Letter for non-docketed cases with affected items, to all linked investors, Appeals Settlement Letter for non-docketed cases, to all TEFRA linked investors, Appeals Settlement Letter for docketed cases, Form 886-Z, TEFRA Partners' Shares of Income, Tax Matters Partner (TMP) Settlement Letter Investor Level Statute Control (ILSC) Pass-through Audit Notification Letter, and Administrative Adjustment Request (AAR) 60-Day Objection Letter Exhibit 4.29.5-1, TEFRA Output Generated by the PCS, (Form 8340, PCS Establish or Add with Notice Generation, and Form 8342, Partnership Control System (PCS) - PCS Notice Generation)
Notice of Beginning of Administrative Proceeding (NBAP)
4.29.5.3.2 (11-27-2017) Notice of Beginning of Administrative Proceeding (NBAP) The NBAP is a letter which notifies each notice investor or notice group that the TEFRA key case is under examination. It is generated via CC TSLODK (Form 8340, PCS Establish or Add with Notice Generation, Form 14090, TEFRA Electronic Linkage Request Check Sheet (LB&I), or Form 14091, TEFRA Electronic Linkage Check Sheet (SBSE)) using information on the Schedules K-1. Input of CC TSLODK generates: Letter 1787-C, Notice of Beginning of Administrative Proceedings, for partnership investors A mail listing. A cover sheet After the partnership is established on PCS, CC TSCHG must be used to add the address of the partnership. The address is needed for the generation of investor NBAPs. CC TSCHG items 31, 32 and 33 will be used to enter the partnership address information. Review all NBAPs to insure the partnership address was correctly printed within the body of the letter. If no address was printed, a new letter must be generated manually. The NBAP notices are sent by regular mail. The CC TSLOD generates two Mail Lists: One listing is sent to the area or Appeals Processing Manager as proof of mailing of the notices. The other listing is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed. (Exhibit 4.29.5-3, Certification of TEFRA NBAP Letters) Two copies of the letter, (2)(a) above, are generated for each notice investor. One copy of an NBAP is be mailed to the investor, and one copy is filed in the key case administrative file. A copy of the mail listing is sent (via mail or email) to the agent, and one copy is filed in the key case administrative file.
60 Day Letter
4.29.5.3.3 (08-15-2019) 60 Day Letter The 60-Day Letter is generated by input of CC TSNOT, notice type 2. Letters and forms generated for partnership investors are: Letter 1829-C, TEFRA Partnership 60 Day Letter for Penalties and Adjustments, and Form 870-LT, Agreement to Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax, and Additional Amounts and Agreement for Affected Items. Letter 1827-C, TEFRA Partnership 60 Day Letter, and Form 870-PT, Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts. Forms 870-LT/PT generated with a 60-Day Letter will have "60" displayed in the upper left hand corner, to denote that the agreement form was generated with a 60-day letter. Note: The generation of the correct notice is dependent upon the tax year end and the input of the penalty/affected item code on the key case record. Below is a table explaining when each notice will be generated: P/AI Code Package type Notice Attachment Blank 60 Day 870-PT N/A Blank FPAA 870-PT N/A A (for affected item) 60 Day 870–LT N/A A (for affected item) FPAA 870-PT E Note: The D removes the current designation, and allows a new designation to be entered. See IRM 4.29.3.5.8, TEFRA Penalty/Affected Item Code. Note: The attachments are generated with FPAAs where partner level affected items or penalties apply. Attachment E explains that affected items are applicable at the partner level and will be assessed through a separate notice. IRM 4.29.3.5.8(7) explains the attachments. This notice is issued upon receipt of a 60-day Letter TMP package from Technical Services. Three copies of the 60-day Letter, Form 870-PT or Form 870-LT, and applicable attachments are generated for each investor. Two copies are mailed to the investor, one is a customer service in case the taxpayer requests a conference, and one copy is filed in the key case administrative file. Two copies of the 60-Day Letter Certification List are generated. One copy is sent to the Technical Services TEFRA Coordinator, and one copy is filed in the key case administrative file, (Exhibit 4.29.5-4, Certification of 60–Day Letters).
Notice of Final Partnership Administrative Adjustment (FPAA)
4.29.5.3.4 (11-27-2017) Notice of Final Partnership Administrative Adjustment (FPAA) The FPAA is generated by input of CC TSNOT, notice type 3. A separate spousal notice is generated on jointly filed returns. The spousal notice is generated based upon there being a spousal record on the TIF file. The letters and forms generated for partnership investors are: Letter 1830-C, Notice of Final Partnership Administrative Adjustment, Form 870-PT , Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, and The appropriate attachment as required if the key case penalty/affected item notice code is on. Forms 870-PT generated with an FPAA will have "FP" displayed in the upper left hand corner, to denote that the agreement form was generated with an FPAA. Note: The attachments are provided to notify taxpayers of pending partner level penalties, affected items, or both. Three copies of each FPAA, Form 870–PT, and any applicable attachments are generated for each investor. Two copies are mailed to the investor, one as a customer service in case the taxpayer files a petition, and one copy is filed in the key case administrative file. The FPAA notices are sent by certified mail. Input of CC TSNOT, notice type 3, also generates three Certified Mail Lists: Version A (two copies): One listing is sent to the area or Appeals Processing Manager as proof of mailing of the notices. The other list is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed. (Exhibit 4.29.5-5) Version B (one copy): This list is certified by the post office and returned to the CPF as proof of certified mailing. (Exhibit 4.29.5-6) The certified list is filed in a permanent reference book, not in the administrative file, as was previously done. The need for this information usually comes about after the key case administrative file was destroyed. A cover sheet is necessary for certified mailing.
Letter 2064 - No Change FPAA
4.29.5.3.5 (01-01-2004) Letter 2064 - No Change FPAA The No Change FPAA is generated by input of CC TSNOT, notice type 9. A Letter 2064, Notice of Final Partnership Administrative Adjustment, will be generated for each partner. The no change FPAA is generally used to no-change a TEFRA case after the initial 45 day period. It is also used when a taxpayer believes there are adjustments in their favor, but the Service does not agree. The No-Change FPAA allows the taxpayer to petition the court regarding the adjustments.
Electing Large Partnership – Final Notice
4.29.5.3.6 (01-01-2003) Electing Large Partnership – Final Notice For an electing large partnership a Notice of Partnership Adjustment is the final document instead of an FPAA.
Appeals Settlement Letter for non-Docketed Cases with Affected Items to ALL Linked Investors
4.29.5.3.7 (11-27-2017) Appeals Settlement Letter for non-Docketed Cases with Affected Items to ALL Linked Investors The Appeals Settlement Letter to all linked investors in a TEFRA partnership is generated by input of CC TSNOT, notice type 4. Letters and forms generated for partnership investors are: Letter 3394(NO), Transmittal Letter for Form 870-LT(AD) for nondocketed TEFRA partnership cases, and Form 870-LT(AD), Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, and Agreement for Affected Items. Note: The generation of the correct notice is dependent upon the input of the penalty/affected item code on the key case record. Below is a table explaining how each notice is generated: P/AI Code Letter Notice Attachment Blank 3395(NO) 870-PT(AD) N/A A (for affected item) 3394(NO) 870-LT(AD) E Note: The D removes the current designation, and allows a new designation to be entered. See IRM 4.29.3.5.8, TEFRA Penalty/Affected Item Code. Note: The attachments are generated with FPAAs where partner level affected items or penalties apply. • Attachment E explains that affected items are applicable at the partner level and will be assessed through a separate notice. This notice is issued upon receipt of a TMP package and request to issue the settlement letter from the Appeals office. Three copies of each letter package are generated. Two copies are mailed to the investor and one copy is filed in the key case administrative file. Two copies of the Appeals Letter Certification List are also generated. One copy is sent to the Appeals office Appeals Processing Manager for the Appeals office that has the key case, and one copy is filed in the key case administrative file.
Appeals Settlement Letter for Non-Docketed Cases to All TEFRA Linked Investors
4.29.5.3.8 (11-27-2017) Appeals Settlement Letter for Non-Docketed Cases to All TEFRA Linked Investors Appeals Settlement Letters to all linked investors with a TEFRA indicator present on the linkage record are generated by input of CC TSNOT, notice type 5. Letters and forms generated to partnership investors are: Letter 3395(NO), Transmittal Letter for Form 870-PT (AD) for nondocketed TEFRA partnership cases, and Form 870-PT (AD), Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts. Note: The letter and forms generated depends on the penalty/affected item code input on the system. See IRM 4.29.3.5.8, TEFRA Penalty/Affected Item Code, for further explanation. Below is a table explaining how the notice is generated: P/AI Code Letter Notice Attachment Blank 3395(NO) 870-PT(AD) N/A Note: The D removes the current designation, and allows a new designation to be entered. See IRM 4.29.3.5.8, TEFRA Penalty/Affected Item Code. This notice is generated upon receipt of a TMP package and request from the Appeals office. Three copies of each letter package are generated for each investor. Two copies are mailed to the investor, and one copy is filed in the key case administrative file. Two copies of the Appeals Letter Certification List are generated. One copy is sent to the Appeals office Appeals Processing Manager for the Appeals office that has the key case, and one copy is filed in the key case administrative file.
Appeals Settlement Letters for Docketed Cases
4.29.5.3.9 (11-27-2017) Appeals Settlement Letters for Docketed Cases The Appeals Settlement Letter for docketed cases to all investors is generated by input of CC TSNOT, notice type 6. Letters and forms generated for partnership investors are: Letter 2607 (NO), Transmittal Letter for Form 870-LT (AD) for docketed TEFRA partnership cases, and Form 870-LT (AD), Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts, and Agreement for Affected Items, Letter 2606 (NO), Transmittal Letter for Form 870-PT (AD) for docketed TEFRA partnership cases, and Form 870-PT (AD), Settlement Agreement For Partnership Items and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts. Note: The letter and forms generated depends on the penalty/affected item code input on the system. See IRM 4.29.3.5.8, TEFRA Penalty/Affected Item Code, for further explanation. Below is a table explaining how each notice is generated: P/AI Code Letter Notice Attachment Blank 2606(NO) 870-PT(AD) N/A A (for affected item) 2607(NO) 870-LT(AD) E Note: The D removes the current designation, and allows a new designation to be entered. See IRM 4.29.3.5.8, TEFRA Penalty/Affected Item Code. Note: The attachments are generated with FPAAs where partner level affected items or penalties apply. • Attachment E explains that affected items are applicable at the partner level and will be assessed through a separate notice. Three copies of each letter package are generated for each investor. Two copies are mailed to the investor, and one copy is filed in the key case administrative file. Two copies of the Appeals Letter Certification List are generated. One copy is sent to the Appeals Processing Manager for the Appeals office that has the key case, and one copy is filed in the key case administrative file. The docket number and TMP name and address must be present on the key case record for PCS to accept a request for notice type 6. It is extremely important that the literal "Tax Matters Partner" is NOT included as part of the TMP name.
Schedule of Adjustments
4.29.5.3.10 (03-01-2006) Schedule of Adjustments The functionality of generating the schedule of adjustments via PCS has been removed. The campus or PTE should use a copy of the schedule of adjustments provided by the field when sending notices to investors. Sending the copy eliminates any transcription errors that can occur when inputting that data in PCS for the purpose of having PCS generate the schedule.
Form 886–Z, Partners' Shares of Income
4.29.5.3.11 (11-27-2017) Form 886–Z, Partners' Shares of Income The Form 886-Z is a listing of all investors linked to a particular key case. The form lists each investor with their name, address, TIN, and Schedule K-1 income/loss percentage. Subsequent Form 886-Z may be generated via CC TSNOT, notice type Z.
AAR 60-Day Objection Letter, Letter 3904
4.29.5.3.12 (04-01-2007) AAR 60-Day Objection Letter, Letter 3904 Letter 3904 is generated to all investors using notice type "A" . The Letter 3904 is used when the TMP files an AAR requesting substituted treatment. The law requires all partners be given the opportunity to object to the partnership changes if those changes will result in additional tax to them. The letter is generated to all linked partners. If a partner objects, a determination needs to be made as to whether that partner is subject to an assessment and therefore allowed to object. See IRM 4.31.4 for more information of substituted AARs.
TMP Settlement Notification Letter
4.29.5.3.13 (11-27-2017) TMP Settlement Notification Letter The Letter 2513, TMP Settlement Notification Letter, provides the TMP with a list of investors that have entered into a settlement agreement. The letter and list of investors are generated weekly and includes investors that have had a settlement date input with CC TSCHG during the prior week cycle. Letter 2513, will generate for partnership key case records.
ILSC
4.29.5.4 (03-01-2006) ILSC PCS generates audit notification letters to all ILSC investors. Procedures for processing these notices are contained in IRM 4.31, Pass-Through Entity Handbook.
ILSC Notice Generation
4.29.5.5 (03-01-2006) ILSC Notice Generation The sub-sections below discuss the ILSC letters and consents that can be generated using PCS. PCS generates letters to investors in an ILSC pass-through to notify them of an examination.
ILSC Pass-Through Audit Notification Letters
4.29.5.5.1 (11-27-2017) ILSC Pass-Through Audit Notification Letters PCS will generate a letter to notify ILSC investors of an audit of an ILSC pass-through entity in which they invested. The Letter 3457, Pass-Through Audit Notification Letter, is used for pass-through examinations of partnerships not subject to TEFRA, partnerships electing out of the Bipartisan Budget Act (BBA) and S-corporations. The letter is not required by law, but was created to inform investors when an examination is beginning. This way, the investors first contact from us will not be an audit report or a request to extend the statute. It is recommended that the letter be issued to all investors controlled by the campuses, and all field controlled investors that may not be aware of the pass-through examination. The letter should not be sent by certified mail. PCS will generate the letter by using CC TSLODK. The CPF will send letters to all partners if requested when the linkage package is submitted. CC TSLODK is also used to issue the NBAP on TEFRA investors. PCS recognizes the PICF Code of 2 on the ILSC key case and will generate the appropriate Letter 3457.
Notice Suppression Due to Disaster
4.29.5.6 (06-13-2005) Notice Suppression Due to Disaster PCS will automatically suppress any notices that would normally be generated to investors in a disaster area. Investors in a disaster area receive a disaster code on their module. The disaster code is set based upon the taxpayers zip code. Notice suppression will not apply to FPAAs (CCs TSNOT3 or TSNOT9). If CC TSNOT encounters a disaster code on a partner record, an error condition will occur with "DI" in column 41-42 on the terminal, and a message displayed that a disaster code exists for that partner. Alternately, the operator may over-write the "DI" with "OV" to override the suppression, and TSNOT will then transmit the request. If the disaster suppression indicator is not overridden, a Disaster Notice will be generated to put in the file. Note: If a CC TSNOTP is used, the operator will not be given the opportunity to override the notice suppression.
Notice Letterhead/ Signature Changes and Employee Contact Changes
4.29.5.7 (04-01-2007) Notice Letterhead/ Signature Changes and Employee Contact Changes Each notice contains several parameters that can be changed using Form 8346, PCS Notice Parameters. The Form 8346 is used to change the letterhead and signature information. Form 8346 is also used to add or change the employee contact information. The completed form needs to be signed by the person requesting the change, approved by their manager. To change the signature, see IRM 4.29.3.6.16, Changing Name of Director on Notices.
TEFRA Output Generated by the PCS (Form 8340 and Form 8342 Inputs) (Text 4.29.5.3.1)
Exhibit 4.29.5-1 TEFRA Output Generated by the PCS (Form 8340 and Form 8342 Inputs) (Text 4.29.5.3.1) Type of Output Input Document Command Code Investor Notice of Beginning of an Administrative Proceeding Letter 1787-C Mailing List of TEFRA NBAP Letters Form 8340 or Form 14090 or Form 14091 and Schedule K-1 TSLODK Investor 60-Day Letter Packages: Partnership (with penalty) Letter 1829-C and Form 870-LT Partnership (without penalty) Letter 1827-C and Form 870-PT Mailing List of 60-Day Letters Form 8342 TSNOT2 Investor FPAA Packages: Partnership Letter 1830-C and Form 870-PT Attachments A, P or X, if applicable Certified Mail Listings Form 8342 TSNOT3 Appeals Settlement Letter for Non-Docketed Cases with affected items to all linked investors Partnership with Penalty Letter 3394 & Form 870-LT(AD) Certified Mail Listings Form 8342 TSNOT4 Appeals Settlement Letter for Non-Docketed Cases to all TEFRA linked investors Partnership Letter 3395 and Form 870-PT(AD) Certified Mail Listings Form 8342 TSNOT5 Appeals Settlement Letter for Docketed Cases Partnership (with penalty/affected items) Letter 2607 & Form 870-LT(AD) Partnership Letter 2606 & Form 870-PT(AD) Certified Mail Listings Form 8342 TSNOT6 No Change FPAA Letter 2064 Form 8342 TSNOT9 AAR 60-day Objection Letter Letter 3904 Form 8342 TSNOTA Form 886-Z Form 8342 TSNOTZ
Instructions for Form 8342, PCS Notice Generation (Text 4.29.5.3.1)
Exhibit 4.29.5-2 Instructions for Form 8342, PCS Notice Generation (Text 4.29.5.3.1) Part A—Key Case Entity Item Title of Item Instructions 2 TIN Enter the key case EIN. If the key case is established on non-Master File (NMF), indicate one of the following after the TIN: N = non-Master File; —D = Dummy TIN 3 MFT Enter the key case MFT Code 4 Tax Period Enter the key case tax period in "YYYYMM" format 5 Notices to be Issued Enter "P" if notices will be issued to all investors. Enter "I" if notices will be issued to investors specified in Part B only 6 Notice Type Enter 2 for 60 day letter Enter 3 for FPAA Enter 4 for Appeals settlement letter to all linked investors Enter 5 for Appeals settlement letter to all TEFRA linked investors Enter 6 for Appeals settlement offers for docketed cases Enter 9 for generation of No Change FPAA, Letter 2064 Enter A for generation of an Letter 3904, AAR 60-day Objection Letter. Enter Z to generate Form 886–Z 7 Employee Indicator (IRM 4.29.3.6.15) Three character field - (ANN) Must enter a "B" or an "O" in the alpha field to designate the campus where the notices will be printed. Two numeric characters may be entered (01-99) to generate specific contact information on the letter. If no number is entered, 99 will be used for default contact information. Part B—Related Investor THIS PART WILL BE COMPLETED ONLY IF "I" IS SPECIFIED IN ITEM 5 Item Title of Item Instructions 8 TIN Enter the related investor's TIN. If the investor is established on non-Master File , indicate one of the following after the TIN: N = non-Master File; —D = Dummy TIN 9 MFT Enter the related investor's MFT Code 10 Tax Period Enter the related investor's tax period in "YYYYMM" format 11 Requestor Name Enter requestor's name 12 PBC Enter requestor's PBC 13 EGC Enter requestor's EGC 14 Approved by Enter team leader's name 15 Title Enter team leader's title 16 Signature Requestor's signature 17 Date Date signed by requestor 18 Signature Team leader's signature 19 Date Date signed by team leader 20 Name of Input Operator Enter name of input operator 21 Title Enter input operator's title 22 Signature Input operator's signature 23 Date Date form is input by operator
TEFRA NBAP Letter Mailing List (Text 4.29.5.3.2)
Exhibit 4.29.5-3 TEFRA NBAP Letter Mailing List (Text 4.29.5.3.2) Example of TEFRA NBAP Letter Mailing ListThe top section of the mailing list contains the name and address of the sender and the date on which the NBAPs are sent. The middle section of the mailing list shows the key case partnership, it's tax period and EIN. Below is a listing of the partners sent NBAPs by the campus. This sample letter lists three partners. Each partner is numbered, and their address and tax period is also displayed. The bottom section of the listing shows the total count sent as well as a space for the employee issuing the notices to sign and date to verify the notices were sent. Please click here for the text description of the image.
Certification of 60–Day Letters (Text 4.29.5.3.3)
Exhibit 4.29.5-4 Certification of 60–Day Letters (Text 4.29.5.3.3) Example of a 60-Day Letter Mailing ListThe top section of the mailing list contains the name and address of the sender and the date on which the 60-day letters are sent. The middle section of the mailing list shows the key case partnership, it's tax period and EIN. Below is a listing of the partners sent 60-day letters by the campus. This sample letter lists three partners. Each partner is numbered, and their address and tax period is also displayed. The bottom section of the listing shows the total count sent as well as a space for the employee issuing the letters to sign and date to verify the letters were sent. Please click here for the text description of the image.
FPAA Certified Mail Listing A (Text 4.29.5.3.4)
Exhibit 4.29.5-5 FPAA Certified Mail Listing A (Text 4.29.5.3.4) Example of an FPAA Certified Mailing List AThe top section of the mailing list contains the name and address of the sender and the date on which the FPAAs are sent. The middle section of the mailing list shows the key case partnership, it's tax period and EIN. Below is a listing of the partners sent FPAAs by the campus. This sample letter lists three partners. Each partner's certified mail number, address and tax period is displayed. The bottom section of the listing shows the number of notices. There is are spaces for the post office to show the total number they received and for the name of the Postmaster and date. Certified Mailing List A is not signed by the post office. Please click here for the text description of the image.
FPAA Certified Mail Listing B (Text 4.29.5.3.4)
Exhibit 4.29.5-6 FPAA Certified Mail Listing B (Text 4.29.5.3.4) Example of an FPAA Certified Mailing List BThe top section of the mailing list contains the name and address of the sender and the date on which the FPAAs are sent. The middle section of the mailing list shows the key case partnership, it's tax period. Certified Mailing List B does not display the partner TINs. The post office signs this version so the TIN is removed to avoid unnecessary disclosure. Below is a listing of the partners sent FPAAs by the campus. This sample letter lists three partners. Each partner's certified mail number, address and tax period is displayed. The bottom section of the listing shows the number of notices. There is are spaces for the post office to show the total number they received and for the name of the Postmaster and date. Certified Mailing List B is signed by the post office. Please click here for the text description of the image.
Instructions for Form 8346, Notice Parameters
Exhibit 4.29.5-7 Instructions for Form 8346, Notice Parameters A. Letterhead Information Item Title of Item Instructions 1 IRS Signature Name 35 positions. The first position must be "B" , followed by the name of the signing official 2 IRS Signature Title 40 positions. The first position must be "C" , followed by the title of the signing official. 3&4 IRS Address Line 70 positions. The first position must be "D" , followed by the complete return address. B. Employee Contact Information 5 Employee Indicator 4 positions. The first position must be 1. The second position must be B if the employee resides at the Brookhaven campus, or O if the employee resides at the Ogden PTE. Positions 3 and 4 are the employees assigned identification number for purposes of generating their contact information on the letters. Each organization must use 99 for default contact information. 6 Employee Name 35 positions. Entry of the employee name begins in position 5 of line beginning with 1 in position 1. 7 Employee ID Number 15 positions. Entry begins in position 40 of line beginning with 1 in position 1. This is were the employee enters their badge number. 8 Mail Stop 13 positions. Entry begins in position 55 of line beginning with 1 in position 1. 9 Employee Office Hours 35 positions. The first position must be 2. 10 Employee Phone Number 24 positions. Entry begins in position 37 of line beginning with 2 in position 1. 11 Name of Requester Name of person requesting changes. 12 PBC Requester's Primary Business Code. 13 EGC Requester's Employee Group Code. 14 Signature Requester's Signature 15 Date Date the form is signed by the requester. 16 Approved by Name of approving official. Either the employees manager, the PCS Coordinator, or both. 17 Title The title of the approving official. 18 Signature The signature of the approving official. 19 Date Date the form is signed by the approving official. 20 Name of Input Operator Name of the MITS employee inputting the change. 21 Title Title of the Input Operator. 22 Signature The signature of the input operator. 23 Date Date the information is input on the system.
Source: official text