Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
Manager reviews and sends the signed electronic Form 5666 (and attachments) in a secure email to the TE/GE Referral Group email box at *Manager EO Classification. See IRM 4.70.6.4 for more details.
Don’t use the "Change due to Correction of Operations" disposal code in situations such as:
The examiner could use a higher applicable priority disposal code (for example: change to related return, delinquent related return secured, etc.).
The taxpayer failed to file a related return and based on the facts and circumstances in the case the examiner didn’t secure the delinquent related return but told the taxpayer to file the delinquent return. Close the examination as a "No Change" (assuming there are no other issues).
The taxpayer filed an incomplete or inaccurate primary return or schedules, which has no impact on a compliance issue (for example: exempt status, plan qualification, tax, penalties, etc.). The correct disposal code is a "No Change" if not assessing penalties (assuming there are no other compliance issues).
The following EP examples would result in a no change (i.e., DC 02/107) (assuming there are no other issues), not a change due to correction of operations (i.e., DC 52/214), in situations such as:
The sponsor improperly reported the pension plan deduction on their tax return. However, the plan sponsor did not take an improper deduction; they merely completed the form improperly.
The examiner found assets that hadn’t been reported correctly on the Form 5500 series return or schedules.
The examiner found that for the plan under examination the plan exceeded the allowable deduction by a de minimis amount. The examiner decided with group manager concurrence, to neither pursue a discrepancy adjustment, nor complete a referral to SB/SE. The over-deduction was an isolated error and didn’t result from a systemic error.
The plan sponsor didn’t timely deposit elective deferrals per DOL Regulation Section 2510.3-102(b)(1). However, the lost interest per participant was de minimis. The examiner, with group manager concurrence, decided to neither require correction nor request delinquent Forms 5330.
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