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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

Example:

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

A taxpayer alleges IDT on tax year 2021, 2022 and 2023. The 2021 has a TC 810 with a code 4, the 2022 and 2023 do not contain any FRP indicators, the IDT determination and any necessary account adjustments for 2022 and 2023 must be done before routing to FRP.

If all years included in the IDT allegation have FRP indicators, do not take action on the account. Instead, refer the case directly to FRP for resolution of all years. If research has been completed and you have made a determination prior to identifying the FRP issue, you may input a CII case note to provide that information.

IDTVA referrals to FRP that need to be addressed by multiple functions other than IDTVA will be coordinated with Return Integrity Operation (RIO) HQ to streamline case resolution and will be elevated to ITVA-HQ.

Document your research in a CII case note, and close the case.

(10) Department of Justice (DOJ)

Prepare and email Form 4442 using the subject line: Department of Justice (or similar) to ITVA HQ. Include all DOJ communications and documents received. Document all research completed in a CII case note and/or on Form 4442. Attach Form 4442 to your CII case. Suspend the case for 15 business days.

(7) Prior to referring a case to another function, the documentation submitted by the taxpayer must be reviewed to determine whether the case should be retained or routed to another function. CII case notes will be input to document the reason for routing or reassigning the case. See paragraph (2) of IRM 25.23.2.3.2, Assessing the Scope of the Taxpayer’s Issue.

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▸Contents — Internal Revenue Manual Part 25. Special Topics
Internal Revenue Manual Part 25. Special Topics

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