SECRETS OF THE IRS ACCOUNT TRANSCRIPT
the transcripts with a code 150, there is, sometime later, at least one entry coded 599 with the description“ tax return filed.” [ The IRS witness ] Kirkpatrick testified that a code 599 is entered whenever an SFR is filed. Kirkpatrick testified that a code 599 will be entered again whenever a taxpayer files a tax return to replace the SFR.” However, other IRS experts have indicated to the author that it also denotes a taxpayerfiled return.”
To identify the meaning of code 599, it should be cross-referenced to another set of codes, the“ closing codes.” Like transaction codes, the closing codes are more or less spelled out in IRS publication 6209. 19 However, the author in recent conversation with an IRS insolvency officer regarding code 599 has been advised that the closing codes may no longer be applicable in this context, and hence it may be unsafe to rely on the closing codes to determine it is the client’ s return, or an SFR.
Caveat, it may require a phone call to the IRS“ Practitioner’ s Priority Hotline” to get a handle on what, exactly a code 599 on your client’ s transcript may mean. 20
Conclusion
There are more issues involving account transcripts, including the many“ 971” codes that typically appear, the transcript that shows zero owed but the IRS has been trying to levy on your client for something, the Assessment Statute Extension Date(“ ASED”), and other more arcane matters. These will be addressed
As may be seen, getting and understanding account transcripts can be a challenge. Professionals who do not feel confident that they understand them exactly may get an analysis of his / her client’ s tax discharge eligibility from the author. Visit MorganKing. com and click on RequestTaxOpinion. com near the top of the page.
( Endnotes)
1 Those states having income taxes will have their equivalent forms of returns, called by different names, that will be subject to the same rules that apply to IRS transcripts.
2 |
And avoiding malpractice. |
3 |
Discussed at length in the |
author’ s book, Discharging Taxes in |
Bankruptcy, ¶ 2.4. For information, |
visit MorganKing. com and click on |
“ Books” at the top of the page. Or, go to |
TaxPublishing. com. |
4 |
The |
Bankruptcy |
Abuse |
Prevention and Consumer Protection |
Act of 2005(“ BACPA”) added these |
and other words to 11 U. S. C. § 523( a) |
( 1)( B). |
5 |
11 U. S. C. § 507( a)( 8)( A)( i). |
6 |
( 11 U. S. C. § 523( a)( 1)( B)( ii). |
7 11 U. S. C. § 507( a)( 8)( A)( ii). 8 IRM § 4.12.1.8.1( 10-05-2010), IRM 4.4.9.2.3.2.1( 05-08-2012)).
9 But excluding“ trust-fund” penalties. 10 11 U. S. C. § 523( a)( 7)( B). 11 11 U. S. C. § 507( a)( 8)( G). 12 If the original assessment has satisfied the 3-year rule, the 240-day rule, and the 2-year rule, a subsequent assessment does no trigger these again; the additional assessment need only satisfy its own 240 period. 13 Two more rules for tax discharge, no fraud, and no evasion. 11 U. S. C. § 523( a)( 1)( C). 14 The author invented this expression. 15 In re Lamborn, 204 B. R. 999( Bankr. N. D. Okla., 1997), Maitland v. N. J. Div. of Tax.
531 B. R. 516( Bankr. N. J., 2015).
16( 11 USC § 507( a)( 8)( A)( ii)( I)), or 90 days( 11 U. S. C. 507( a)( 8)( G)).
17 11 U. S. C. 507( a)( 8)( G). 18 McGrew v. Internal Revenue Serv.( In re McGrew), 559 B. R. 711( Bankr. N. D. Iowa, 2016)
19 The 2017 edition of 6209 may be found at MorganKing. com, top of page, 4 – Tax Discharge, item TaxJustice & Research. 20 This number may be found at MorganKing. com, top of page, link # 4 Tax Discharge, and link TaxJustice & Research.
28 CONSUMER BANKRUPTCY JOURNAL Winter 2018 National Association of Consumer Bankruptcy Attorneys