US Certification Reasons to Refer a Case to P&A
Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States
(1) There are several circumstances where a case needs to be referred to Planning and Analysis (P&A) to be reviewed before it can be processed. The following list provides situations in which cases need to be sent to P&A:
If:
IRM
IMF/BMF
A return is unpostable
IRM 21.8.4.2(6)
Both
Reconsideration Request
IRM 21.8.4.2(12)IRM 21.8.4.4.12.1.1(12)IRM 21.8.4.4.12.1.2(19)IRM 21.8.4.4.12.1.3(19) IRM 21.8.4.4.12.2 (24) IRM 21.8.4.4.12.4(38)IRM 21.8.4.4.12.6(17)IRM 21.8.4.4.12.9.4(12)
Both
Applicant or Spouse has a Visa
IRM 21.8.4.4.12.5(14)
IMF
There is IDT on the applicant's account
Local Procedures
Both
There are NMF indicators on the account
IRM 21.8.4.4.11(6)
Both
Individual Applicant and/or spouse has an ITIN
Local Procedures
IMF
A Form 2555 or Form 1116 are attached to the return used to verify
Local Procedures
Both
There are invalid FIPS codes
IRM 21.8.4.4.6(2)
BMF
No letter applies when more information is needed
IRM 21.8.4.4.9(7)
Both
Certification is requested for the same country the business is incorporated in
IRM 21.8.4.4.12.1(5)
BMF
Processing foreign claims forms that are not listed in the IRM
IRM 21.8.4.4.14(5)
Both
External Reach-ins
Local Procedures
Both
Exempt Organizations not required to file that can prove residency a different way
IRM 21.8.4.4.12.4(27)
BMF
A trust agreement is not attached and/or there is a question whether the administrator of the employee plan is a qualified custodian bank
IRM 21.8.4.4.12.2(13)
BMF
Any issue that cannot be resolved with the 21.8.4 IRM for Form 8802 Instructions
IRM 21.8.4.2(8)
Both
Unable to determine if applicant is entitled to certification based on provided information
IRM 21.8.4.2.1.5(6)
Both
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