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Dear Ms. Green.

1
Part 1. The 6020(b) in the IMF claims TDO 182 as authority. 2
Part 2. The SFR 150 in my IMF was created by computer fraud. 3
Details: 4
Background. 4
Heres the process in detail: 4
This provides three important results favoring the Service. 6
How the ASFR SFR 150 Computer Scheme Worked in My Case. 6
We find the following: 6
The Upshot?. 7
Summary. 8
Afterword. 9
Glenns Notes. 11
Excerpts from Transcripts Article. 12
Court Cases on Value of IRS Transcripts. 13

Ms. Maureen Green


1973 North Rulon White Blvd.
Mail Stop 4388
Ogden, Utah 34201-0040
Re: Your Letter Dated January 9, 2012 concerning Tax Year 201012
February 7, 2012
Dear Ms. Green,[1]
As an initial matter, I would like you to know I am always seeking to learn the law,
from those more knowledgeable than I. When I understand it, I am dedicated to
obeying the law. I simply seek the truth and want to know my duty. To that end, I
have been diligently seeking information from the Service regarding the Individual
Master File (IMF) account assigned to me by IRS.

It turns out that you, Ms. Green, have already sent me almost precisely similar
letters regarding the years 2007 and 2008.[2] After receiving various transcripts
and documents via FOIA/Privacy Act, and by studying various IRS manuals and other
sources, there are two issues which MUST be brought to your immediate attention
regarding all the years for which you have corresponded with me. I believe the info
I have discovered proves that not only have I have been victimized by IRS
employees, but that you may have been deceived in some ways, too.
And as a result of this letter, I will be very interested to hear from you, Ms. Green,
that you are either withdrawing your letters, or that you are so kind as to help me
understand any flaws in my analysis of the information presented herein. I think
you may find this valuable.
My letter focuses on two issues: 1.) the 6020(b) and 2.) the SFR 150 in the IMF
which the Service keeps concerning me.
Part 1. The 6020(b) in the IMF claims TDO 182 as authority
Although your current letter addresses 2010 but you did not include the 6020(b)
you hold in your computer regarding me for that taxable year, lets look at Doc. A
which forms the basis of the Services claim against me for 2007.[3] (The
procedure outlined here is exactly the same for any SFR created for any taxable
year for any non-filer in the nation, since I have observed the same steps in
records of other non-filers.) Doc. A. is the 6020(b) Certification on a standard
Form 13496 you, Ms. Green, supposedly created for me regarding 200712.
A substitute for return (SFR 150) generated for a 1040 non-filer, (as the Service
has labeled me),[4] is based upon a correctly prepared 6020(b)[5] with a standard
set of accompanying documents.[6] The 6020(b) form is the basic accounting
document concerning any taxable year for any non-filer, and if you look closely it
(as always) specifies Treasury Delegation Order 182 as the purported source of
authority to create an SFR. However, it turns out that TDO 182 does not now grant,
nor has it ever granted, authority to complete a substitute 1040.
I have discovered that the list of returns an IRS agent is empowered to complete
does not include a 1040 form. Here is the relevant section from the IRS Manual
discussing the 6020(b):
5.1.11.6.7 (03-01-2007) IRC 6020(b) Authority
The following returns may be prepared, signed and executed by revenue officers
under the authority of IRC 6020(b),
A. Form 940, Employers Annual Federal Unemployment Tax Return
B. Form 941, Employers Quarterly Federal Tax Return

C. Form 943, Employers Annual Tax Return for Agricultural Employees


D. Form 944, Employers Annual Federal Tax Return
E. Form 720, Quarterly Federal Excise Tax Return
F. Form 2290, Heavy Vehicle Use Tax Return
G. Form CT1, Employers Annual Railroad Retirement Tax Return
H. Form 1065, U.S. Return of Partnership Income
Pursuant to IRM 1.2.44.3 Delegation Order 52 (formerly DO-182, Rev 7) dated
5/5/1997, revenue officers GS-09 and above, and Collection Support Function
managers GS-09 and above, have the authority to prepare and execute returns
under IRC 6020(b).
Anyone can see there is no mention of authority to create a substitute for a 1040
income tax return.
[Link here: www.irs.gov/irm/part5/irm_05-001-011r-cont01.html]
I have also recently discovered that Revenue Officers have been, or should have
been, trained to realize there is no authority to perform a 6020(b) for income tax
non-filers:
The IRM restricts the broad delegation shown in figure 23-2 to employment, excise
and partnership tax returns because of constitutional issues. You have already
studied audit referrals as a means to enforce compliance[7]on income tax returns.
See Doc. D. Attached, Revenue Officer Training Manual, Lesson 23 Re: IRC Section
6020(B).[8] *** [http://www.synapticsparks.info/evidence/c10/misc/Lesson23-3.pdf]
Accordingly, I believe you know or should have known that no authority exists
requiring an individual to file an income tax return, (see Footnote 8 above), nor
allowing anyone in the Service to create a substitute for return for income tax nonfilers. And I believe you can now see that your Letter 1862
[http://taxhelplaw.com/Nonfiler-IRS_Letter_1862.html] was issued wholly without
authority. But there is more.
Part 2. The SFR 150 in my IMF was created by computer fraud
Because no one is authorized to create a 1040 substitute for return, no OMBapproved form exists upon which an IRS employee can create such a Substitute for
1040 return, hence no transaction code exists which could be entered into the
IMF software to reflect existence of an SFR 1040. It appears that IRS personnel
resort to using the 4549 Income Tax Examination Change form upon which to
record their INITIAL assessment, (as you did in my case, as shown below). Thus the
Master File software must be fooled by creating the appearance that

an initial return was made in order to get MF to accept later changes via the
standard Additional Tax change form: which is always entered into an IMF as a
Transaction Code 300, a.k.a. TC300.[9] [Afterwards, for purposes of court cases,
an IRS employee will falsely certify that numbers derived from the 6020(b)
Change exam were supposedly created as part of the original SFR 150
procedure entered into every non-filers IMF.] So, the ASFR-generated SFR 150
turns out to be a mere placeholder imported into my IMF from a non-master file
data base, and has no supporting documentation whatsoever.
Based on various IRS manuals, my IMF and the documents Disclosure provided, I
can now prove that someone created the SFR 150 in my IMF by first
requisitioning/opening a skeletal record in the Audit Information Management
System (AIMS) data base, then imported that record into my IMF using a Push
Code, and finally removed the evidence by using a TC AM424D. This creates the
appearance that a substitute for return was created via the ASFR process, when in
fact no original SFR was ever done, that there exists no actual SFR to change, and
that all TC 300 changes were made to a non-existent ghost record.
Details:
Background
There are two principal databases used in this discussion. One is called the Audit
Information Management System (AIMS); the other is the Individual Master File,
(IMF).[10] The AIMS data base is used by Appeals, Examination Division and
TE/GE to control returns, input assessment/adjustments to the Master File and
provide management reports. And while the return is charged to Examination,
the AIMS data base tracks its location, age, and status. [11]
[http://www.irs.gov/irm/part4/irm_04-004-001.html] A non-master file account
established on AIMS is not subject to many of the same computer checks to which a
master file account is subjected. (AIMS Reference Guide 4.4.1-1 (05-19-2009),
Definition under Non-Master File (NMF)). [Link to the AIMS Reference Guide:
http://www.irs.gov/irm/part4/irm_04-004-001.html#d0e10.]
However, inputs to the AIMS system can cause substantive changes to a Master File.
[12] My research into the IRS documentation and training manuals shows that a
non-master file account created on the AIMS data base can be used to create
the appearance in a Master File that an initial substitute for return (SFR 150)
was made when it wasnt, without any IRS employee thus being liable for creating a
1040 substitute return which no one has authority to make.
Heres the process in detail:
In the AIMS Reference Guide 4.4.1-1, (2009), we read:

Skeletal Accounts: -AIMS creates a skeletal record when a Command Code


AM424 is input, showing the requisition and limited taxpayer information. Once the
request goes to Master File and is matched, Master File sends an opening record to
AIMS and the account becomes fully established. Once fully established, AIMS
sends a TC 420 back to Master File. [http://www.irs.gov/irm/part4/irm_04-004001.html]
Translation: The AIMS system queries IMF for matching data and if found, (taxpayer
information), sends other details back to AIMS to create a complete AIMS record.
In the IRS Processing codes and Information Manual, (the 6209 Manual), more
definition is given. In Section 13-17, (11) EP AIMS Push Codes we read:
When a request is made through AIMS to post a transaction code, TC424, to the
Master File (BMF, IMF, EPMF), if the Master File does not reflect the posting of the
return (TC 150), entering a Push Code will post the TC424 and 3 digit PUSH Code
on AIMS and the MF. The Push Code will allow the skeletal AIMS account (TC424) to
remain active and will hold at MF for up to 26 months. NOTE: using a Push Code
036 will automatically generate a TC 150 and TC 420 on Master File.
[Emphasis Added]
In AIMS Reference Guide Introduction, Exhibit 4.4.1-1 (05-19-2009) Reference
Guide, under the definition of TC 424 Code), we see that a TC 424 Code
Identifies whether a case was opened on AIMS using AM424. (P1-L17/A-CIS).
http://www.irs.gov/irm/part4/irm_04-004-001.html#d0e10
In AIMS Reference Guide at Exhibit 4.4.1-14 (05-19-2009) Push Codes, it states
that when a 036 Push Code is used for a Non-filer, (this code) will computergenerate a substitute for return TC 150 at Master File two cycles after
input. Can delete using AM424D 30 days after input.
http://www.irs.gov/irm/part4/irm_04-004-001.html (036 Non-filer will computer
generate a substitute for return TC 150 at Master File two cycles after input. Can
delete using AM424D 30 days after input.)
Thus we see that a TC 424 AIMS transaction can also be reversed and eliminated
from the Master File database by use of an AM424D transaction. (I think D
probably stands for Delete.) That procedure, however, leaves three indelible
footprints.

First, it results in creation of the RET RCVD DT field in the IMF. That field is
defined thusly:

Return Received Date (RET-RCVD-DT) For timely filed returns it is the due date
of the return. Example: Form 1040 due April 15 will be displayed as April 15 of the
appropriate year even if the return was filed before the due date. For late filed
returns it is the received date stamped on the return. For SFR cases it is the date

the examiner entered on the SFR 1040. http://www.irs.gov/irm/part4/irm_04004-001.html (Return Received Date (RET-RCVD-DT) For timely filed returns
it is the due date of the return. Example: Form 1040 due April 15 will be displayed
as April 15 of the appropriate year even if the return was filed before the due date.
For late filed returns it is the received date stamped on the return. For SFR cases
(Push Code 036), it is the date of the TC 424 that contained the Push Code 036.
(P1-L16/SSIVL)) (September 10, 2013).
Hence, for SFR cases the RET RCVD Date reflects the date someone
purportedly created an SFR 1040, (but which is not authorized by TDO 182,
despite IRS employees claims to the contrary).

The second footprint left behind in the IMF after an AM424A creates a TC
150 in an IMF is the TC 420, which often is generated by the computer
several days after the 424/425 transactions actually occurred.

The third footprint of the scheme is the otherwise inexplicable entry TC


425 which is computer-generated when an AM424D reverses an AM424A.
[In the 6209 Manual a TC 425 is defined as A TC 424 which was reversed.
What was reversed? The deleted AM424A]

In sum, the presence of a TC 420, a TC 425 and the RET-RCVD-DT in an IMF


proves an SFR 150 in an IMF was created using the AIMS data base and
a Push Code 036 to establish it in the IMF; then an AM424D was used to
reverse and conceal that process, but left behind markers which MF
software wont allow to be deleted.
So, despite the fact that there is no OMB-approved form upon which a substitute
1040 can be created, (thus no Transaction Code to memorialize it), IRS fools the
Master File software to think a substitute 1040 return has been filed, which then
allows the fraudulent use of a TC 300 Additional Tax or Deficiency Assessment
(which is invariably based upon an 4549 Income Tax Examination CHANGES form)
as the basis for prosecuting income tax non-filers.
Said differently, IRS Collections staff fabricates (perhaps unknowingly) the
appearance that a substitute for return was accomplished on a certain date, when
no return was ever created and the SFR 150 entry itself has no documentary
support whatsoever. It is a mere placeholder. The AIMS database (which is
supposed to be used by Examinations, not Collections, per AIMS Reference
Guide Processing, 4.4.1.2) can be manipulated, (importing the skeletal
record into an IMF using Push Code 036), then the evidence deleted via a
manually-entered AM424D transaction.
This provides three important results favoring the Service.

First, a victims IMF reflects that an SFR 1040 has supposedly been created,
when it hasnt been.

Second, there will be no documents responsive to an IRS victim seeking, via


FOIA/PA, the foundation docs used to prosecute them because the document
locator numbers are computer generated.

But most importantly for IRS, no IRS staffer can be held accountable for
creating, without authorization, a substitute for 1040 return for a non-filer.
The computer done it all!

How the ASFR SFR 150 Computer Scheme Worked in My Case


Looking at my IMF, (Doc F.) or the more complete transcript TXMODA, (Doc. G.), we
see the scheme unfolded exactly as laid out above.
Only eight transactions supposedly occurred in my IMF before the TC 300 (regarding
your 6020(b) and related supporting documents) were filed into my IMF on
November 15, 2010.[13]
That means that we only have to look at the first eight chronological entries before
that date to see the evidence of my liability, (since logically it must have been
determined by someone with authority to create it before the TC 300, since that
type of transaction regards an Additional Tax or Deficiency).
We find the following:
1. On November 17, 2008 (11172008) someone in Collections entered a
Transaction Code 140 (TC 140)[14]into my IMF, creating the appearance I
had a delinquency and a Fiscal Year[15] which required a new tax module
for 2005.
2. On January 13th, 2010 (01132010) we see a Transaction 425, (TC 425).
Even though there is no TC 424 now visible in my IMF, we now know the TC
425 is evidence that an AM424D reversed, thus concealed, an AIMS TC
AM424A, and is proof that the SFR 150 in my case for 2005 was opened on
AIMS and established in my IMF via Push Code 036.[16] This sequence is
precisely confirmed in the TXMODA transcript of my account, Doc. G. [See
TXMODA info at end of this document Glenn]
3. Also, on January 13, 2010, we see RET RCVD DT, (Return Received Date)
01132010. Since the dates of the TC 425 and RET RCVD DT match, we are
led to the inescapable conclusion that a TC 424, which was first entered
remotely, then deleted remotely via AIMS, was the actual source of the
pretended SFR 150 entry, made several weeks before you or someone
claiming to be a Maureen Green completed the initial 6020(b) Certification

form with the supporting documents, (which included the 4549 Income Tax
Examination CHANGE form) on April 12th, 2010. (See Docs. A and I.)
4. On January 28th, 2007 (01282010), we see a TC 420, which is defined in
the 6209 Manual thusly Computer generated at the SC (Service Center)
when an opening record is posted but more precisely means [AIMS
Reference Guide 4.4.1-1, (2009)] Once the request from AIMS goes to Master
File and is matched, Master File sends an opening record to AIMS and the
account becomes fully established. Once fully established, AIMS sends a TC
420 back to Master File. [See AIMS Reference Guide 4.4.1-1, (2009)]
http://www.irs.gov/irm/part4/irm_04-004-001.html (under Skeletal
Accounts). This transaction is merely an un-erasable confirmation marker of
the AIMS, Push Code 036 sequence.
5. On February 8th, 2010 (02082010) someone entered a TC 595, which is a
satisfying transaction meaning the module was Referred to Exam.[17]
(Defining TC 595: Referred to Examination. Satisfies this module and all
subsequent modules for same MFT. Requires a two digit closing code for IDRS
input. Updates FRC to zero. See Section 11 for appropriate closing codes.)
(6209 Doc).
6. Also on February 8th, 2010 (02082010) someone entered a TC 570 code,
which freezes the module from refunding or offsetting credit out, a
precaution to prevent any inadvertent refund regarding that tax year.[18]
(Defining TC 570: Indicates additional liability pending. Freezes (R freeze)
module from refunding or offsetting credit out.) (6209 Doc)
7. Also February 8th, 2010, someone (likely from Exams, since they also
acknowledged taking the module via the TC 595 on this date) overwrote the
Transaction Code SFR 150 established by Collections via AIMS on
01132010, thus purporting that a return was filed and tax liability was
assessed, when in fact no so-called SFR 1040 was ever created. (There was
nothing, Ms. Green, which you could change in April 2010).
8. Importantly, by sheer coincidence, (or act of God), I filed a Privacy Act
request in April 2010 for my IMF. The disclosure office responded with an IMF
complete for 2007 on May 28th, 2010. [See Doc. H.] That date is AFTER the
SFR 150 was entered into my IMF on February 8th, 2010, but BEFORE the TC
300 was entered on November 15th, 2010 (which TC memorialized your
6020(b) and the numbers stated on your 4549 CHANGE form). As you can
see, as of May 28th, 2010, the module balance, interest and penalties
fields of my 2007 IMF all show 0.00 due, despite the fact it shows a SFR
150 Substitute for Return had supposedly already completed back on
February 8th, 2010.
The Upshot?

The documents we have received from the Disclosure Office prove that the initial,
primary assessment document in my 2007 module, i.e., the 6020(b) Certificate, was
created ostensibly by you (or someone labeling themselves as Operations
Manager, Examination Maureen Green) in Ogden, Utah on April 12, 2010, (referring
to an Income Tax Examination Changes Form 4549), several weeks AFTER the SFR
150 entry was made by the Examination Division in my IMF on 02082010, and
even longer after the RET RCVD DT created by Collections on 01132010 via AIMS.
[After having filed numerous PA Requests, I know that when a Document Locator
Number contains a large number of eights and zeros, such as that associated
with the SFR 150 for the 2007 module in my IMF (29210-888-00000-0), there will be
no paper documents associated with them. The DLN is a mere computer
generated placeholder, just like the SFR 150 entry itself with which the DLN is
associated.]
There are no entries in my IMF for 2007 that could explain away the problem that
no INITIAL substitute for 1040 return exists.
The Automated Substitute For Return program is computer fraud, a scheme to
create unsubstantiated placeholders in an IMF of a non-filer, since no one in IRS
has authority to issue/create an SFR for a non-filer. No INITIAL SFR was ever done
for me.
Recently, when I sought via Privacy Act a Certificate of Assessments, Payments and
Other Specified Matters (Form 4340) regarding the tax period ending December
2007, I received a transcript from Accounting Operations Manager Denise Bradley
(See Doc. J.), referring to the 6020(b) (Doc. A) and the 4549 Change form (Doc. I.)
which you, Ms. Green, created on April 12th, 2010.
But Ms. Bradleys Certification falsely attributed the numbers you generated on April
12th, 2010 to January 13th, 2010, the date of the pretended Return Received
Date, which in reality is the date the SFR entry was fraudulently created by IRS
Collections Division staff via AIMS and Push Code 36.
In other words, for purposes of any court action, IRS produces certified documents
pretending that numbers established on an Examination Change Form 4549 were
supposedly determined earlier than they actually were, and supposedly as part of
what we now know is the wholly fictitious SFR 150 computer fraud.
I contend that the reason for this scheme (that there never is an initial substitute
for return created by IRS, but numbers are generated later on Change forms,
then attributed to the earlier SFR 150 date), is because no one has authority to
issue an SFR for income tax non-filers, thus there is no OMB-approved form, or
related transaction number.

Although you or someone using the name Maureen Green entered a 6020(b) into
my IMF at one point, the first TC 300[19] entered on 11152010 in my IMF literally
changed nothing, since no SFR 150 was ever created that could be changed.
Summary
A jury will be able to hear from the IRS Manuals that a taxpayer cant be compelled
to prepare delinquent returns,[20] [I very much doubt this statement; see fn. 20,
my added info Glenn] and that because of constitutional issues the delegation of
authority under TDO 182 does not empower IRS employees to file an income tax
SFR for anyone.
It can be proven, in other words, that no one is authorized, or can ever be
authorized, to create a 6020(b) certification to be used as an SFR 1040. DOJ
attorneys know or should know that IRS computer manipulation gives the false
appearance a lawful SFR 1040 was accomplished. And now you know, Ms. Green,
that no SFR 150 actually occurred on Feb 8th, 2010, thus you could not have
changed it via your 4549 Income Tax Examination Changes Form on April 12th,
2010.
Afterword
Do you see any flaws in my analysis, Ms. Green? Does it matter to you that there is
no lawful primary liability document upon which you are basing your inquiries to
me, and that my liability has resulted from computer fraud?
It has taken painstaking research to puzzle this out, with the help of the IMF, IRS
source documents and many other dedicated researchers. So I hope this
information is beneficial for you, because I believe the fraud perpetrated upon me,
has also been perpetrated at least in some measure on you. (But my family and I
have been put through a great deal of inconvenience for years because of it!)
Of course, I am not through analyzing and sifting; this is still a work in progress. I
am daily accumulating more data on both the SFR process and every other entry in
my IMF. And after my research is complete, I will then appropriately request
erroneous field code entries be removed from my IMF.[21] But I believe you
needed to know what my ongoing work with the Service has turned up, because
your investigation must be built upon a validly-created documentary foundation. I
will keep you apprised from time to time of my progress.
In the meantime, would you please take time, Ms. Green, to make a written reply to
this particular letter, since it appears to me that you also may be a victim of
deliberate, multiple instances of fraud which should impact the course of your work
on my case? Should this matter ever become subject of a suit in federal or state
court, it would obviously be important to have your written response regarding the
issues I raise, and which you are now aware.

I thank you in advance for your time and your earliest return correspondence.
Sincerely Yours,
Michael Ellis
P.O. Box ???
Corsicana, Texas 75151
List of Appended Documents
Doc. A.

6020(b) Certification

Doc. B.

AMIDSA transcript labeling me non-filer

Doc. C.
non-filer

DOJ Pretrial Memorandum prepared and filed in a Tax Court case of a

Doc. D.
(1983)

Revenue Officer Training Manual, Lesson 23, IRC Section 6020(b)

Doc. E.

Revenue Officer Training Manual, Lesson 14, Summons

Doc. F.

IMF Complete regarding 2007 module

Doc. G.

TXMODA transcript for 200712

Doc. H.
2010.

IMF specific for 2007, from PA response by Disclosure on May 28th,

Doc. I.
2010

Form 4549 Tax Examination Change by Maureen Green on 4/12/

Doc. J.
Certificate of Assessments, Payments, and other Specified Matters
concerning the 2007 module of my IMF by Ms. Denise Bradley on June 9th, 2011.

[1] I do not know whether the name Maureen Green is a pseudonym, or whether
1000099936 is a correct IRS employee number. But since both identifiers appear in
the recent notice Ms. Green supposedly sent me, I will refer to her/your name. It is
on many other documents related to me, as noted below.
[2] We will only focus on 2007, but the procedural scheme discussed in this letter
applies to every other year as well.
[3] Every other tax year I have investigated from every other year was created in
the same sequence as that of 2007, so I can assume its the same for 2010 and
beyond and never materially varies for any module regarding a non-filer.

[4] See Amdisa transcript for 2007, Doc B. attached.


[5] We know that a completed 6020(b) is foundational to the case IRS builds against
non-filers because when anyone enters Tax Court the DOJ attorney involved
invariably states: Petitioner did not file a tax return for the taxable year 2005.
Respondent (the IRS) prepared a substitute for return on (petitioners) behalf per
I.R.C. 6020(b). No other document is referenced by the DOJ, thus the 6020(b)
alone is critical. See Doc. C., page 2, for an example.
[6] With the 6020(b) you sent in 2010 for the year 2007, and with the 1862 Letter
you sent last month, the supporting documents consist of a Form 4549, Income Tax
Examination Changes or equivalent and Form 886-A Explanation of Items. The
very word Changes in the title of the Form 4549 should tell you something is
wrong. What document is the Form 4549 proposing to Change? None exists, as
we will see in Part 2. which follows.
[7] What happened to voluntary compliance?
[8] In Lesson 14, TM 2280-2, Page 14-5 trainers of Revenue Officers concede that
taxpayers cant be compelled to furnish returns: Since the taxpayer cant be
compelled to prepare delinquent returns, it is only the information to prepare those
returns that you are summonsing. See Doc. E, page 2.
[9] A TC 300 is defined as an Additional Tax or Deficiency Assessment by
Examination or Collection Division, per 6209 Manual, page 8-15.
[10]
IMF System Overview The Individual Master File (IMF) consists of a series
of runs, data records and files. The IMF receives individual tax submissions in
electronic format, and processes them through a preposting phase, posts the
transactions, analyzes the transactions, and produces output in the form of Refund
Data, Notice Data, Reports, and information feeds to other entities. IMF is the
authoritative data source for individual tax account data. All the other IRS
information system applications that process IMF data depend on output from this
source. IMF is a critical component of IRSs ability to process tax returns. See IRS
Privacy Impact Statement link here: http://www.irs.gov/pub/irs-pia/imf_pia.pdf. IMF
is now being merged with the Customer Account Data Engine, or CADE.
[11] See IRM Part 4. Examining Process, Chapter 4, AIMS Processing, 4.4.1.2(0519-2009).
[12] See IRM 4.4.1.2 Description of AIMS.
[13] Please bear with my explanation following. If you will put either Doc. F. or G.
beside you, you can track my research. The IMF version is made a bit more difficult
by the fact that the dates of various transactions are not in chronological order.
This means the transactions were originally in date order, but someone has gone
back and overwritten the dates and other information.

[14] Per the 6209 Manual, a TC 140 Establishes an Entity and/or tax module and
status code 02 as a Delinquency Inquiry within the affected tax module.
[15] A fiscal year implies a corporation, which I am not. I am studying the issues
related to the BOD field codes in the Entity Portion of my IMF, and plan to provide
you data concerning that subject in future updates.
[16] As explained in preceding page 4, Background above.
[17] 6209 Manual Section 8-26. Although the TC 595 is insignificant, we can guess
it may have been entered by the Exam staff to acknowledge the transfer of the
module to them.
[18] 6209 Manual, Section 8-24.
[19] A TC 300 is defined as an Additional Tax or Deficiency Assessment by
Examination or Collection Division
[20] For additional support for that contention, see Conklin v. United States, cite
unnecessary, where a paralegal proved it impossible for a taxpayer to file a 1040
without waiving his Fifth Amendment right. [Kasey v. Commissioner, 457 F.2d 369
(9th Cir. 1972), cert. denied, 400 U.S. 864 (1972) (The appellants finally argue that
the record-keeping requirements and the requirement that taxpayers shall prepare
and file their tax returns, as established by the Internal Revenue Code and the
Internal Revenue Service, violate their privilege against self-incrimination under the
Fifth Amendment and amount to involuntary servitude, prohibited by the Thirteenth
Amendment. There is no merit to these arguments. United States v. Sullivan, 1927,
274 U.S. 259, 47 S.Ct. 607, 71 L.Ed. 1037; Abney v. Campbell, 5 Cir., 1953, 206 F.2d
836, cert. denied, 1954, 346 U.S. 924, 74 S.Ct. 311, 98 L.Ed. 417.)]
[21] FYI, changes to errant entries in the Entity portion of my IMF are mandatory
pursuant to the Privacy Act of 1974, (5 USC 552a(d)(2)(A) and (B), and (d)(3), as
well as 31 CFR Part 1, Subpart C, appendix B and 1.27, (which are regulations
issued by the Office of Management and Budget). So far I have discovered several
field codes in that portion which should be amended, but my work continues
[End of Michael Ellis Letter]
Glenns Notes

424

I/B/E

Examination
Request
Indicator

7
7

Return referred to Examination or Appeals


Division. Generates Examination opening
inventory information. Deletes record, if
present, from DIF file. This transaction can
also be generated for IMF when an IRP
Underreported Case is referred to Exam.
Generated as a result of input through PCS

036 Non-Filer: Will computer generate a substitute for return TC150 at Master File 2
cycles after input. Will cause a TC 150 to post to Master File 1 cycle after
input. Can delete using AM424D 30 days after input. [6209 Doc]
13-18
(13) EP AIMS Push Codes
020 Delinquent Return 5330/940/941/945/1040/1041/1065
021 Substitute 5330
025 Inadequate Records Notice
036 Substitute for Return
041 Current Return Pick-up
081 Future Year Return [6209 Doc]
Excerpts from Transcripts Article
If the transcript includes a Transaction Code 420, this indicates that a return (Forms
1120, 1120X or 1139 for corporations) has been referred to the Examination unit in
the Service Center where the return or claim was processed. Transaction Code 424
also indicates that the return has been referred to Examination but generally in the
field. The Taxpayer should expect to receive correspondence opening the field
examination if the Account Transcript includes Transaction Code 424. If Transaction
Code 420R, 421, 424R or 425 is reflected in the account, the particular examination
(service center or field) has been closed.
The data included in the TXMODA is numerically coded and there are very few
English descriptions of any entry in the account. The codes can be identified in the
IRS Document 6209, ADP and IDRS Information, on the IRS website. The
TXMODA . . . must be printed and faxed to the requester and thus, it is not delivered
through the electronic Transcript Delivery System. The TXMODA contains five
distinct sections.

A recent case in the Tax Court underscores the importance to the IRS in
knowing what is in its own transcript records. In Rosenbloom v. Commr, T.C.
Memo 2011-140, the taxpayer sought to prove that an installment agreement was
in place when he signed extensions of the collection statute. If the installment
agreement was in place when the statute extensions were signed, the IRS would be
barred from collection activities under a policy established to correct past collection
function misconduct whereby taxpayers were coerced to extend the collection
statute under threat of the IRS revoking their installment agreements. The taxpayer
sought review of the coerced extension at a Collection Due Process (CDP) hearing.
The hearing officer concluded that the statute extensions were valid because IRS
collection activities were consistent with a revoked installment agreement. Fn. 12
(An over-zealous revenue officer levied on the bank account, attempted to
repossess used office furniture and even attempted to seal off Mr. Rosenblooms
office elevator on two separate occasions.) The court reviewed the taxpayers
transcripts and allowed expert testimony from the IRS. It determined that the
installment agreement had never been terminated because a Code 64, which
indicates a terminated or defaulted installment agreement, never appeared on
the transcript. This finding supported the conclusion that the collection statute
had expired and the tax liability was discharged.
The Rosenbloom case not only illustrates that transcript data can play a significant
role in a courts findings, but also the complexity of the information contained in
them. Most IRS employees are not skilled in the nuances of transcript data.
Transcripts are generally presumed to be correct unless proven otherwise
and courts will rely on them to make factual determinations. See Roberts v.
Commr, T.C. Memo 2004-100 ([W]e have repeatedly approved respondents
reliance on TXMODA transcripts as verification of the information and actions
reflected therein.)
While transcripts and generally presumed to be correct, they can be
rebutted by evidence to the contrary. In U.S. v. Forma, 71A AFTR 2d 93-3694
(S.D. NY 1989), the court denied the governments motion for summary judgment
because it found there was a genuine issue of fact in question.
Though rarely used in litigation, transcript data can make or break a partys case. It
can shine a light on account mistakes, that once corrected, can reduce or eliminate
interest and penalties. It can also provide a path of documentation surrounding a
taxpayers actions. Even though the data is coded and the codes are often difficult
to parse, the Rosenbloom court said it best, transcripts [T]ranscripts are troves of
information, but they are also almost completely incomprehensible Rosenbloom
v. Commissioner, T.C. Memo 2011-140.
IRS Transcripts Essential Tool for Tax Practitioners http://bit.ly/17NowJ1
(September 10, 2013).

Court Cases on Value of IRS Transcripts


The solution to this puzzle lies in the tax transcripts that the parties produced at
trial. These were the same tax transcripts that the settlement officer had access to
before making her determination. These transcripts are troves of information, but
they are also almost completely incomprehensible to one not skilled at interpreting
the various numerical codes they use. See Roberts v. Commissioner, T.C. Memo.
2004-100 (admitting evidence that helped identify entries in a transcript). Whether
or not our scope of review is limited to the administrative record, taking testimony
to explain that record is allowed. Fn. 20 (E.g., Yale-New Haven Hosp. v. Leavitt, 470
F.3d 71, 82 (2d Cir. 2006) (courts may consider extrarecord evidence to illuminate
agencys record); Franklin Savings Association. v. Director, Office of Thrift
Supervision, 934 F.2d 1127, 1137 (10th Cir. 1991) (discussing exceptions to record
rule); Bunker Hill Co. v. EPA, 572 F.2d 1286, 1292 (9th Cir. 1977) (courts can go
beyond the administrative record to explain technical terms or complex subject
matter)).
Rosenbloom v. Commr, T.C. Memo 2011-140 http://www.leagle.com/decision/In
%20TCO%2020110621C38 (September 10, 2013).