Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
The Appeals Office Code is 221 for cases going to Tax Court, and the disposal code is 11 on AIMS and 603 in RCCMS - Unagreed - Petition to Tax Court.
If a Tax Court petition is not timely filed, the reviewer will:
Prepare the case for closing as a defaulted case.
Use AIMS disposal code 10 and RCCMS code 604.
If IRS assesses tax on a corporation of $100,000 in any given tax year, IRC 6621(c) imposes additional interest of 2% interest on amounts due.
For EP exam purposes, section 6621(c) applies to Forms 5330 and to Form 1120 discrepancy adjustments.
IRC 6621(c) applies only to "C" corporations.
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