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1082 - English/Spanish›Note:

Litigation

Internal Revenue Manual Part 5. Collecting Process · 2026-10-03 edition · updated 2026-10-04 · United States

Taxpayers in litigation status are identified by a literal "-W" freeze.

These taxpayers may be locked in if they meet lock-in criteria.

Each "-W" freeze redetermination case will need to be considered on its own merits.

The litigation TC 520 closing codes are 75-81 and 84.

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▸Contents — Internal Revenue Manual Part 5. Collecting Process
Internal Revenue Manual Part 5. Collecting Process

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