4 - Erroneous AbatementThe timely filed TC 150 return for TY 2018 is determined to be a nullity. The valid taxpayer filed a return reporting tax of $.00 and withholding of $2,500 which posted as a TC 976. Form 14039 is included with the return. The ASED for the valid return is expired. Based on the original return, the account shows TC 150 tax of $5,000, and withholding of $6,000. A CP 2000 proposing a tax increase of $2,000 based on unreported income is issued to the valid taxpayer’s last known

Caution:

Internal Revenue Manual Part 25. Special Topics · 2026-10-03 edition · updated 2026-10-04 · United States

The ASED does not apply on a case that has been determined a nullity. The return must be considered verifiable/consistent with the taxpayer’s filing history (non-streamline for IDT) in order for the ASED to apply. Refer to paragraph (3)(b) of IRM 25.6.1.6.14, Criteria for Establishing a Statute of Limitations Period, for additional information.

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▸Contents — Internal Revenue Manual Part 25. Special Topics

Internal Revenue Manual Part 25. Special Topics

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