Suspension periods for the collection statute (optional)
Enter the dates each event suspended collection, including any statutory tail. Overlapping periods are counted once (IRM 5.1.19.3). The Use detected events button fills the rows from the TC 480, 500, 520 and 971 AC 043/163 lines found; verify each against the closing codes and case history.
| Event | Start | End (including tail) |
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First Time Abate screen (IRM 20.1.1.3.3.2.1)
What the analyzer reads
An account transcript is the ledger of one tax module: a header with the account balance, accrued interest and accrued penalty as of a date, the return data as filed or adjusted, and a transactions table of three-digit code, explanation, posting cycle, transaction date and amount. The IRS describes it as a transcript that “shows basic data such as filing status, taxable income, and payment types. It also shows changes made after you filed your original return.” Paste the text as it comes out of a Transcript Delivery System download or Get Transcript; the analyzer splits it into modules at each TAX PERIOD line and reads every line that begins with a code and ends with a date and an amount. Lines it cannot read are skipped. Codes are classified with the debit and credit flags and titles in Document 6209 (2023 edition), Section 8A, which explains that “Transaction Codes (TC) consist of three digits.” For the full definition of a code, use the transcript code decoder; for reading a module by hand, reading an account transcript.
Dates and statutes
Filing and assessment. TC 150 is “Return Filed & Tax Liability Assessed” and its transaction date is the assessment date of the tax on the return. The filing date is the header line RETURN DUE DATE OR RETURN RECEIVED DATE (WHICHEVER IS LATER); the analyzer adds three years to it for the general assessment statute (IRC 6501(a)) and flags a tax assessment dated after that so you can look for a consent (TC 560), a notice of deficiency (TC 494, IRC 6503(a)) or the longer periods in IRC 6501(c) and (e); see the assessment statute guide.
Collection. IRC 6502(a) allows collection “within 10 years after the assessment of the tax,” and IRM 5.1.19.2 notes that “In addition to Transaction Code (TC) 150 - Tax Assessed, there are certain other TC codes that carry their own CSEDs.” The analyzer uses the list in IRM 5.1.19.2.1 (TC 160, 166, 170, 176, 180, 186, 234, 238, 240, 246, 290, 294, 298, 300, 304, 308, 320, 340, 350), each from its own date, so one module can carry several CSEDs. Suspensions you enter are merged as in the statute date calculator: “Overlapping suspensions run concurrently; they are not cumulative.” Events the transcript shows (TC 480, 500, 520, TC 971 AC 043 and 163) are listed with the IRM rule, and the Use detected events button turns them into rows. Two cautions: “TC 520 with closing code 70 through 75 and closing code 84 does not suspend the CSED,” and closing codes are not printed; and “A TC 971 AC 043 suspends the CSED while an installment agreement (IA) is pending,” not while it is in effect. See the CSED guide.
Penalties, interest and payments
Penalty codes come in assessment and abatement pairs, netted by family: failure to file (TC 160/166 against 161/167), estimated tax (170/176 against 171/177), failure to deposit (180/186 against 181/187), civil penalties (240/246 against 241/247), failure to pay (270/276 against 271/277), dishonored payment (280/286), fraud (320) and negligence (350). A family with a positive net is an unreversed penalty. Interest is netted the same way: TC 196 is “Computer generated interest that is due: at First Notice time; upon issuance of an Account Adjustment Notice resulting from posting of TC 290/300,” TC 336 is interest on an examination deficiency, TC 340 is restricted interest, and 197, 337, 341 and 342 reverse them. The header’s accrued interest and penalty are computed but not yet assessed; the penalty and interest calculator recomputes both to a payoff date. Payments and credits are every transaction Document 6209 flags as a credit, with refunds, transfers out and Treasury offsets (TC 898, a memo entry) listed separately; the sum of all transactions is compared with the account balance line, and a difference usually means lines did not paste.
Freezes, holds and collection status
Each freeze is paired with its release and marked open or released: TC 570/571 (credit hold; TC 570 “Freezes (-R freeze) module from refunding or offsetting credit out”), TC 520/521 (litigation, bankruptcy, CDP), TC 530/531 (currently not collectible), TC 480/481/482 (offer in compromise), TC 810/811 (refund freeze), TC 582/583 (lien), TC 420/421 (examination), TC 494/495 (notice of deficiency) and TC 960/961 (representative on the CAF). TC 971 takes its meaning from an action code that public transcripts replace with a description, so the analyzer maps the common descriptions: pending installment agreement (AC 043), agreement established (AC 063, “Installment Agreement. FTP at ¼%”), agreement terminated (AC 163), the CDP levy notice (AC 069) and a timely CDP request (AC 275). See CNC, installment agreements and CDP hearings.
The First Time Abate screen
IRM 20.1.1.3.3.2.1 waives the failure-to-file, failure-to-pay and failure-to-deposit penalties when the taxpayer “has filed the same return as the penalized return for the 3 years preceding the penalized tax period, unless there is no filing requirement for the applicable tax period,” and those modules “do not have anytype of unreversed penalties (except an estimated tax penalty, TC 17X).” Paste the penalized module and the three preceding years (twelve quarters for Form 941) and the screen reports each look-back period as clean, penalized, missing a TC 150 or not pasted. It disregards TC 17X, flags prior abatements because “penalties manually suppressed or reversed with Penalty Reason Code (PRC) 018 (FTA, RCA not used), 020 (FTA, RCA used), or 021 (Tolerance)” disqualify the module and the reason code is not on the transcript, warns on joint returns that “FTA criteria for both SSNs must be met,” and notes that “penalty relief under the FTA waiver only applies to a single tax period.” Whether a notice issued for a prior penalty, and the business checks for FTD waiver codes and a late-but-unpenalized Form 1120 or 1120-S, are not on any transcript. The FTA checker walks every criterion; the First Time Abate guide and request letter cover the request.
About the sample
The sample is a fictitious joint Form 1040 account for 2023, filed late with failure-to-file and failure-to-pay penalties, a pending and then established installment agreement, an underreporter assessment (TC 922, then TC 290) and three clean prior years, one with an estimated tax penalty. The amounts are illustrative, not computed from current rates.
Questions practitioners ask
Is the date next to TC 150 the filing date?
No. It is the date the tax shown on the return was assessed. The filing date is on the header line that reads return due date or return received date, whichever is later. The assessment statute (IRC 6501) runs from the filing date; the collection statute (IRC 6502) runs from each assessment date.
Why does one year show several CSEDs?
IRM 5.1.19.2.1 lists the codes that carry their own collection statute date: the original tax (TC 150), additional assessments (TC 290, 298, 300, 308) and most penalties (TC 160, 166, 170, 176, 180, 186, 240 and others). Each runs 10 years from its own assessment date.
Does a TC 520 marked Bankruptcy or other legal action filed suspend the CSED?
Only with certain closing codes, which the transcript does not print. IRM 5.1.19.3.1.1 and 5.1.19.3.2 list closing codes 60 to 67, 81, 83 and 85 to 89 (bankruptcy, with a 6-month tail) and 76 to 81 (litigation and CDP) as suspending it, and 70 to 75 and 84 as not. Enter the period after confirming the code.
Can the First Time Abate screen clear a client for FTA?
It shows whether the criteria visible on transcripts are met: a posted return for each look-back period and no unreversed penalty other than estimated tax. It cannot see whether a notice issued for a prior penalty, the penalty reason code behind a prior abatement, or the business-account FTD waiver codes.
What formats does the parser accept?
Account transcripts, or the account portion of a record of account, as plain text. Transaction lines must start with the three-digit code and end with a date and an amount; the cycle is optional.