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Litigation Pending Freeze (-W)

Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States

A TC 520 with various closing codes sets this freeze.

Follow normal review procedures.

If during review it is decided that the Territory Office Special Procedures function or the Appeals Office needs to be contacted:

Give the case to the work lead.

The work lead will contact the Special Procedures function and/or Appeals Office for case resolution. (To inquire about the status of a case in Appeals Office, call the Appeals Customer Service Line at (559) 233-1267 ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡.)

The work lead will return the case to the tax examiner with instructions to resolve the case.

The tax examiner will resolve the case.

The following defines a Department of Justice (DOJ) case:

Any module in Status 72 and/or an unreversed TC 520 with closing codes 70, 75, 80 and 82.

Any module with a TC 550 and definer code 04.

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