Internal Revenue Manual § 4.10.16 - Examination Operational Automation Database (eoad)

Section 16 - Examination Operational Automation Database (eoad)

4.10.16 Examination Operational Automation Database (EOAD)

Manual Transmittal

July 23, 2024

Purpose

(1) This transmits revised IRM 4.10.16, Examination of Returns, Examination Operational Automation Database (EOAD).

Material Changes

(1) Minor editorial changes have been made throughout this IRM. Also, website addresses and IRM references were reviewed and updated as necessary.

(2) Updated exhibits to reflect current codes in effect.

(3) IRM 4.10.16.1 added to conform to the new internal control requirements described in IRM 1.11.2, Internal Controls.

(4) IRM 4.10.16.2 Wage & Investment division renamed to Taxpayer Services.

(5) IRM 4.10.16.2.1 deleted and moved to internal controls.

(6) IRM 4.10.16.2.2.1 (2) added telephone number.

(7) IRM 4.10.16.2.2.2 (1) added Administrative Issues, Statutory Issue, General Income Issue, and Declassified Issue.

(8) IRM 4.10.16.2.2.2 (2) bullet list changed to a table.

(9) IRM 4.10.16.2.2.3 (3) a added note for NRP cases.

(10) IRM 4.10.16.2.2.3 (3) c added Agreed amount.

(11) IRM 4.10.16.2.2.4 (1) added see IRM 4.10.15 for additional information on Form 5344.

(12) IRM 4.10.16.2.3 (1) deleted verbiage related to IMS standup and copying cases to external media.

(13) IRM 4.10.16.2.4 (1) added state for clarity.

Effect on Other Documents

This material supersedes IRM 4.10.16, dated March 23, 2016.

Audience

Employees in the Small Business and Self-Employed (SB/SE), Large Business and International (LB&I), Tax Exempt and Governmental Entities (TE/GE), and Taxpayer Services operating divisions who conduct examinations of income tax returns (Forms 1040, 1120, 1120S, and 1065).

Effective Date

(07-23-2024)

Timothy J. Bilotta
Director, Examination Operations, Performance Planning and Analysis
Small Business/Self-Employed Division

4.10.16.1 (07-23-2024)

Program Scope and Objectives

  1. Purpose: This IRM section provides guidance on record keeping for examination results and tracks the effectiveness of the examination classification process. Examination Operational Automation Database (EOAD) provides data that tracks examination results by issue. This data is used to enhance the ability to identify specific areas of non-compliance based on examination results and track the effectiveness of the examination classification process. EOAD is used to track examination results for National Research Program (NRP) examinations and analyzed by the Government Accountability Office (GAO) and Treasury Inspector General for Tax Administration (TIGTA) as part of their audits of IRS examination activities. In addition, EOAD data is used to fulfill disclosure of examination results under agreements with state and local taxation agencies.

  2. Audience: These procedures apply to all examinations of Individual (Form 1040), Corporate (Form 1120), S Corporation (Form 1120S), and Partnership (Form 1065) returns.

  3. Policy Owner: The Director, Examination Planning Performance and Analysis – Small Business/Self Employed is responsible for EOAD.

  4. Program Owner: Examination Planning Performance and Analysis – Small Business/Self Employed is the program owner of EOAD.

  5. Primary Stakeholders:

    • Taxpayer Services

    • SB/SE

    • LB&I

    • TE/GE

    • Independent Office of Appeals (Appeals)

  6. Program Goals: Identify specific areas of non-compliance based on examination results and track the effectiveness of the examination classification process.

4.10.16.1.1 (07-23-2024)

Background

  1. EOAD electronically extracts data from Report Generating Software (RGS), collected by Correspondence Examination Automation Support (CEAS) and the Issue Management System (IMS) at the time cases are closed electronically.

4.10.16.1.2 (07-23-2024)

Authority

  1. Authority and purpose is pursuant to IRC 6103(h)(1) which provides for disclosure of returns and return information to officers and employees of the Department of the Treasury (including IRS) whose official duties require access for tax administration.

4.10.16.1.3 (07-23-2024)

Responsibilities

  1. Capture of EOAD data is mandatory for all examinations of Individual (Form 1040), Corporate (Form 1120), S Corporation (Form 1120S), and Partnership (Form 1065) returns.

  2. EOAD data must be entered for all examined issues, both adjusted and non-adjusted items, as well as all classified issues including those that are no-changed or subsequently declassified.

4.10.16.1.4 (07-23-2024)

Program Management and Review

  1. Program Reports include:

    • Issue Frequency Report

    • Issue Report

    • No-Change Analysis Report

    • Penalty Amount Report

    • Tax Credit Amount Report

    • Taxpayer Report

  2. Program Effectiveness: The data collection process from RGS is tested annually. The closed cases on EOAD are matched against closed cases on the Audit Information Management System (AIMS) monthly to determine the rate of collection of EOAD data. Collection rates below 95% are investigated further to determine if systemic issues are preventing data collection.

4.10.16.1.5 (07-23-2024)

Program Controls

  1. EOAD relies on the General Support Systems (GSS) common controls associated with the IRS Enterprise Active Directory domain structure to uniquely identify and verify the identity of each user. Direct access to the server is currently limited to the System Administrators and EOAD programmers.

  2. Dissemination of EOAD data to internal customers is done via a shared drive controlled by Information Technology (IT). Password protected data files for respective business operating divisions are placed in separate folders on the shared drive. Each data file has a unique password. Requests to access the data are submitted via WebAD\Qwert system and are reviewed by the EOAD business contact. Upon approval, the internal customer is approved for access to the drive. Once access is approved, the mapping instructions and password are shared with the customer.

4.10.16.1.6 (07-23-2024)

Terms/Acronyms/Definitions

  1. The following table defines terms relevant to this program that are used throughout this IRM section:

    Terms

    TermDefinition
    Audit Information Management System (AIMS)The Audit Information Management System is a computer system used by Appeals, Examination, and TE/GE to control returns, to input assessment/adjustments into the Master File and to provide management reports. IRM 4.4 covers Examination’s use of AIMS and describes the data elements for AIMS.
    Internal Revenue Code (IRC)The Internal Revenue Code is prepared and published by the Office of the Law Revision Counsel (“OLRC”) of the U.S. House of Representatives pursuant to 2 U.S.C. 285b. The Code contains the general and permanent laws of the United States, organized into titles based on subject matter.
    Issue Management System (IMS)The Issue Management System is an electronic case management application for examiners, specialists, managers and others. IMS is a program that uses 2 different interfaces. One is a Web based application that requires no program installation and the other is a client-based application requiring installation by Information Technology. It supports existing and new examination processes. The application provides the Estate and Gift Tax program with case management tools needed to support planning, selection and examination. IMS is an official electronic record-keeping system used to store federal electronic records.
    Report Generating Software (RGS)RGS is a audit software program that is used by Examination, it supports an electronic case file and is used from pre-audit through case closure.
    Standard Audit Index Number (SAIN)The SAIN is a numbering system for examination issues.
    Uniform Issue List (UIL)The Uniform Issue List is a list of codes used to track examination issues for various reports.

     

  2. The following table defines acronyms frequently used throughout this IRM section:

    Acronyms

    AcronymDefinition
    AIMSAudit Information Management System
    BMFBusiness Master File
    CCPCentralized Case Processing
    CEASCorrespondence Examination Automation Support
    EOADExamination Operational Automation Database
    GAOGovernment Accountability Office
    GSSGeneral Support Systems
    IICInternational Individual Compliance
    IMFIndividual Master File
    IMSIssue Management System
    ITInformation Technology
    LANLocal Area Network
    LB&ILarge Business & International
    MFTMaster File Tax
    NAICSNorth American Industry Classification System
    NRPNational Research Program
    PBAPrimary Business Activity
    PODPost of Duty
    RGSReport Generating Software
    SAINStandard Audit Index Number(s)
    SB/SESmall Business/Self-Employed
    SSSNSecondary Social Security Number
    TE/GETax-Exempt and Government Entities
    TIGTATreasury Inspector General for Tax Administration
    TINTaxpayer Identification Number
    UILUniform Issue List

     

4.10.16.1.7 (07-23-2024)

Related Resources

  1. The following IRMs are related to workpapers and reports:

    • IRM 4.10.9, Workpaper System and Case file Assembly

    • IRM 4.10.15, Examination of Returns, Report Generation Software (RGS)

    • IRM 4.46.6, LB&I Examination Process, Workpapers and Reports Resources

    • IRM 1.1.16.6.1.6, Examination System and Projects

    • IRM 1.1.16.5.4.3, Examination Data Management (EDM)

4.10.16.2 (07-23-2024)

Examination Operational Automation Database (EOAD)

  1. EOAD provides data that tracks examination results by issue. This data is used to enhance the ability to identify specific areas of non-compliance based on examination results and track the effectiveness of the examination classification process. EOAD is used to track examination results for NRP examinations and analyzed by GAO and TIGTA as part of their audits of IRS examination activities. In addition, EOAD data is used to fulfill disclosure of examination results under agreements with state and local taxation agencies. Therefore, it is important that data inputs are accurate.

  2. Data is captured by Small Business/Self-Employed (SB/SE), Large Business & International (LB&I), and Taxpayer Services examiners for examinations of all Forms 1040, 1120, 1120S, and 1065 using Report Generation Software (RGS) and Issue Management System (IMS) software.

  3. The focus of this IRM is on data entries in RGS and IMS that are captured by EOAD but generally do not affect tax computations. It is very important that examiners take great care in properly entering EOAD data since there is no subsequent review process to correct EOAD errors.

4.10.16.2.1 (04-26-2011)

Capture of EOAD Data Using RGS

  1. EOAD data is captured by RGS from examiners' inputs on the following screens in RGS:

    • Create Case screen

    • Case Information screen

    • Contacts screen

    • Issue screen

    • Tax Computation (IMF) and Create Report (BMF) screens

    • Form 5344

    • Compliance Evaluation screen

4.10.16.2.1.1 (07-23-2024)

Create Case, Case Information, and Contacts Screens
  1. Create Case screen - the following data is captured:

    • Taxpayer identification number (TIN)

    • Secondary social security number (SSSN)

    • Form type

    • Master file tax (MFT) code

    • Tax period

    • Source code

    • Activity code

    • Project code

    • Tracking code

    • Post of duty (POD) code

    • Audit Information Management System (AIMS) assignee codes

  2. Case Information screen - the following data is captured:

    • Name

    • Telephone number

    • Address

    • Filing state code

    • Filing zip code

    Based on the examiner's inputs in:

    • Return due date

    • Extended due date

    • Received date

    • Substitute for return checkbox

    RGS will generate a delinquency indicator for EOAD to indicate:

    • The return was filed timely

    • A valid extension was filed

    • The return was delinquent (filed late)

    • A return was not filed (i.e. substitute for return cases)

  3. Contacts screen - captures identification and contact information for the return preparer and representative(s). The proper completion of this information allows the ability to identify and address egregious return preparers.

4.10.16.2.1.2 (07-23-2024)

Issue Selection Screen
  1. The examiner creates issues in RGS using the drop down "Actions" menu to select the option that best describes the issue. The menu options are:

    • Administrative Issues - Are automatically created by RGS (can also be added manually if necessary). Administrative lead sheets automatically insert into administrative issues.

    • New Issue – This is an issue that has been identified by the examiner who has determined that it warrants additional inspection. New Issues are not Classified Issues nor are they directly related to a Classified Issue.

    • Classified Issue – This is an issue that has been identified through the issue classification process and appears on a Classification Check Sheet. All Classified Issues must be added and commented upon even if they are subsequently declassified. If a Classified Issue is declassified, check the declassified box on the issue adjustment screen. Add an adjustment record with the issue categorized as though it was examined. Enter the issue amount from the return in both the Per Return and Per Exam fields and select a Declassified Issue Reason Code.

    • New Issue Resulting From Classified Issue – This is an issue that can be directly traced back to a classified issue. For example, a classified balance sheet item could lead to one or more profit and loss items. These subsequent Profit and Loss issues would be identified as New Issue Resulting From Classified Issue.

    • Statutory Issue – This issue is created by RGS when a tax computation is run. These issues cannot be deleted and are assigned a "Reference" code of 599.

    • General Income Issue -This issue is created by RGS from examiner entries in "General Income" on the 1040 workcenter. These issues are assigned a "Reference" code in the 5xx series.

    • Declassified Issue - This issue is created by the examiner declassifying a classified issue.

    Note:

    Issues from different lines on a tax return must be created separately using the appropriate issue code and should not be combined.

  2. Once an issue is added, the examiner uses a pull-down menu in the IMF Code field to identify the issue. See Exhibit 4.10.16-1 for a complete list of IMF Issue Codes. The initial drop down menu selections are:

    Menu SelectionDefinition
    Form 1040 Exemptions and IncomeSelf-explanatory
    Form 1040 Taxes and CreditsSelf-explanatory
    Premium Tax Credit and Health CareSelf-explanatory
    Schedule ASelf-explanatory
    Schedule CSelf-explanatory
    Schedule DSelf-explanatory
    Schedule ESelf-explanatory
    Schedule FSelf-explanatory
    Form 2106Self-explanatory
    Generic Income, Expense and Tax CreditsSelf-explanatory
    999999 - Statutory AdjustmentSelf-explanatory
    699999 - Impact of DeMinimus IssuesSelf-explanatory
    Campus/Service CenterSelf-explanatory
    4NRP - Q TableSelf-explanatory
    99999 - Change/No ChangeSelf-explanatory
    Miscellaneous IssuesSelf-explanatory
  3. BMF issues are identified using the drop down menus in the SAIN, Standard Audit Index Number, field. See Exhibit 4.10.16-2, and Exhibit 4.10.16-3, respectively, for complete lists of sub-chapter S and partnership SAIN Codes. See IRM 4.46.6, LB&I Examination Process, Workpapers and Reports Resources, for a complete list of Corporate SAIN codes.

4.10.16.2.1.3 (07-23-2024)

Issue Adjustment Screen
  1. Once issues are identified, the Issue Adjustment screen is accessed using the "Add" function box.

  2. To promote accuracy and reduce time spent, EOAD fields should be completed concurrently with the examination of issues to the greatest extent possible.

  3. The following fields are captured by EOAD on the Issue Adjustment screen:

    1. Categorization - this selection determines how RGS will calculate the tax resulting from the adjustment. "The RGS Issue Reference Guide" is available for download at the Exam System Knowledge Base. This guide provides detailed instructions to examiners on how to properly categorize an adjustment based upon the IMF Issue Code selection to ensure RGS performs a proper tax calculation and that accurate EOAD data is captured.

      Note:

      For NRP Cases follow the NRP Issue Reference Guide located on the NRP Website -https://nrp.web.irs.gov/training.html#tab=tab1.

    2. Per return, Per exam amounts.

    3. Agreed amount - is the amount of the adjustment the taxpayer agrees with. If the taxpayer does not agree to all or part of the adjustment, modify or remove the agreed amount.

    4. Reason Code – a two-digit code that identifies the reason for the adjustment, why the issue was no changed, or declassified. The examiner should follow the drop down menus in RGS to select the code that best describes the reason the issue was or was not adjusted. See Exhibit 4.10.16-4.

      Note:

      Adjustments to Earned Income Credit issues or originating from Flow Through Entities require the selection of specific Reason Codes. Reason Codes for adjustments from Flow Through Entities are further divided to identify the Flow Through case as either NRP or Non NRP. For all other issues, select the code that best fits the reason the issue was or was not adjusted.

    5. Uniform Issue List (UIL) Code - SB/SE examiners are not required to complete this field.

    6. Rental Type Code – This field is completed for Form 1040 - Schedule E Rental Issues only in RGS. The drop down menu for this field is only activated on issues with Schedule E Rental IMF Issue Codes. Select the code that best describes the rental from the categories Residential, Vacation, or Commercial Rental. See Exhibit 4.10.16-5 for a complete list of Rental Type Codes.

    7. PBA/NAICS Code Per Return (Issue) – For all Form 1040 Schedule C or F and all Forms 1065, 1120, and 1120S issues, this field should be completed to reflect the code as reported by the taxpayer. The North American Industry Classification System (NAICS) will be used for returns for tax periods after 199811. The Primary Business Activity (PBA) Codes will be used for tax periods prior to 199812. The four-digit PBA Code should be expanded to six digits by placing two zeroes (00) before the code.

    8. PBA/NAICS Code Per Exam (Issue) – For all Form 1040 Schedule C or F and all Forms 1065, 1120, and 1120S issues, enter the NAICS code from the series of pull-down menus that best identifies the type of business for the issue being examined. NAICS codes will be used for returns for tax periods after 199811. PBA codes will be used for tax periods prior to 199812. The four-digit PBA code should be expanded to six digits by placing two zeroes (00) before the code. Code "000000" should be selected for issues involving Form 1040 Schedule E income subject to self-employment tax.

      Note:

      If the examiner is fully disallowing the schedule or return, such as in an IRC 183 adjustment, they should choose "D" to remove the NAICS code.

4.10.16.2.1.4 (07-23-2024)

Completion of RGS Tax Computation and Form 5344
  1. Before the Compliance Evaluation Screen can be completed certain RGS actions must be taken. The tax computation must be completed using RGS and all required fields in the RGS Form 5344 must be completed. Then the Form 5344 must be validated. See IRM 4.10.15, Examination of Returns, Report Generation Software (RGS) for additional information on Form 5344.

4.10.16.2.1.5 (01-02-2013)

Completion of the Compliance Evaluation Screen
  1. PBA/NAICS Code Per Return – This code reflects the principal business of the taxpayer and can be found on the return. In the case of Forms 1040 with multiple Schedules C or F, it is the code for the schedule with largest gross receipts per the return. North American Industry Classification System (NAICS) codes will be used for returns for tax periods after 199811. Primary Business Activity (PBA) codes will be used for tax periods prior to 199812. The four-digit PBA code should be expanded to six digits by placing two zeroes (00) before the code.

  2. PBA/NAICS Code Per Exam – This is the corrected code, based on the examiner’s determination for the principal business of the taxpayer. In the case of Forms 1040 with multiple Schedules C or F, it is the code for the schedule with largest gross receipts after completion of the examination. RGS provides a series of pull-down menus to assist the examiner in selecting the correct code. NAICS codes will be used for returns for tax periods after 199811. PBA codes will be used for tax periods prior to 199812. The four-digit PBA code should be expanded to six digits by placing two zeroes (00) before the code.

  3. Primary Occupation Code (Form 1040 only) – This is a three-digit code that identifies the occupation of the taxpayer with the largest source of wage income for the year being examined. This code should be selected based on the taxpayer’s largest source of wage income per exam regardless of whether the largest source is from the primary or secondary taxpayer. This field will be completed where the taxpayer is both a wage earner and self-employed. If no wages are earned, no code is entered. RGS provides a series of pull-down menus to assist the examiner in selecting the correct code.

  4. Amount Paid at Closing – This is the total amount paid for the applicable tax period at the time the examination was concluded or before the examination case is closed from the group.

  5. Study Type – This field will be left blank currently. It is a three-digit field that will be used to track cases for special surveys or research studies (not the same as current project codes).

  6. Upon completion of all fields, the Compliance Evaluation screen must be validated, saved, and printed. The printed copy must be placed in the case folder on top of the case file.

4.10.16.2.1.6 (03-23-2016)

Forwarding EOAD Data using RGS
  1. SB/SE and LB&I, International Individual Compliance (IIC) examiners will forward all closed cases by Local Area Network - Report Generating Software (LAN-RGS) unless that functionality is unavailable. The EOAD data is included in the electronic case file by the forwarding process.

  2. Forms 1040, 1120, 1120S, and 1065 examinations which could not be completed using LAN-RGS must be notated as such on the Form 3198, Special Handling Notice for Examination Case Processing. Any cases not fulfilling the requirements of IRM 4.4.12.11, EOAD Data Capture Procedures, will be returned to the originating examination group.

4.10.16.2.2 (07-23-2024)

Capture of EOAD Data Using IMS

  1. The IMS system captures the EOAD data in a format that can be shared with state and local taxation agencies.

  2. EOAD data is automatically extracted by IMS at case closure based upon examiners' inputs on various IMS screens. Instructions detailing the proper input of data in IMS can be found in the IMS Client program.

  3. For cases completed using IMS, EOAD data is included in the electronic case file by the forwarding process.

4.10.16.2.3 (07-23-2024)

Forwarding EOAD Manually - Centralized Case Processing (CCP) Responsibility

  1. If a disclosure is made to a state agency whose code is manual or not compatible with AIMS, or if the disclosure is of Non-Master File (NMF) information, the reporting will be done manually by preparing Form 5466-B, Multiple Record of Disclosure. Additional information regarding disclosure reporting requirements can be found at IRM 11.3.37, Record keeping and Accounting for Disclosures.

  2. State agency codes can be found in IRM Exhibit 11.3.37-4, State Agency Codes.

  3. Instructions for Form 5466-B, preparation can be found at IRM Exhibit 11.3.37-6, Multiple Record of Disclosure.

Exhibit 4.10.16-1

IMF Issue Codes

CodeIssue
41007Wages, Salaries and Tips, etc.
41008Taxable Interest
41009aOrdinary Dividends
41009bQualified Dividends
41010State Refunds, Credits, or Offsets
41011Alimony Income
41014Other Gains or Losses From Form 4797
41015IRA Distributions
41016Pensions and Annuities
41019Unemployment Compensation
41019aUnemployment Compensation Exclusion
41020Social Security Benefits
41021Other Income
41021aForm 2555 Foreign Income
41021bNOL Carryback
41021cNOL Carryforward
41021dMSA Taxable Payments
41021eMED+MSA Taxable Payments
41021fLTC Taxable Payments
41021gForm 4563 Income
41021hIncome Excluded from Puerto Rico
41021iHSA Taxable Distributions
41021jHSA Qualified Distributions
41021kGambling Winnings
41021ISection 461(I) Excess loss
41021mNet Section 965 Inclusion
41021nGILTI (Global Intangible Low-Taxed Income)
41021oSection 962 Election
4CX01Sch C - Gross Receipts or Sales
4CX01aSch C - Gross Receipts/Sales Merch/3rd Party
4CX01bSch C - Other Gross Receipts or Sales
4CX01cSch C - Income Reported on Form W-2
4C101zSch C-EZ - Gross Receipts
4CX02Sch C - Returns and Allowances and Oth. Adj.
4CX06Sch C - Other Income
4CGLSchedule C Net Gain/Loss
4D001Sch D - Short-Term Gain/Loss
4D004Sch D - ST Gain/Loss - Forms 6252/4684/6781/8824
4D005ST Gain/Loss-Prtnrship/S-Corp/Estate/Trust - Sch K1
4D006Sch D - Short-Term Capital Loss Carryover
4D008Sch D - Long-Term Gain/Loss
4D011Sch D - LT Gain/Loss-4797/2439/6252/4684/6781/8824
4D012LT Gain/Loss-Prtnrship/S-Corp/Estate/Trust - Sch K1
4D013Capital Gain or Loss Where Sch D Not Required
4D013dCapital Gain Distribution
4D014Sch D - Long-Term Capital Loss Carryover
4EX03Sch E - Rents Received
4EX03aSch E - Merchant Card/3rd Party Payments Received
4EX03bSch E - Other Payments Received
4EX04Sch E - Royalties Received
4EX23Sch E - Real Estate Loss After Passive Limitation
4E131Sch E - Inc/Loss-Prtnrship/S Corps-Passive/Non-Passive
4E136Sch E - Inc/Loss-Estates/Trusts-Passive/Non-Passive
4E138Sch E - REMIC Income or Loss
4E139Sch E - Net Farm Rental Income or Loss
4FX01Sch F - Sales-Livestock/Oth. Items Purch for Resale
4FX01aSch F - Specified Sales-Livestock/Other Resale
4FX01bSch F - Other Sales-Livestock/Other Resale
4FX02aSch F - Specified Sales of Raised Products
4FX02bSch F - Other Sales of Raised Products
4FX04Sch F - Sales-Raised Livestock/Produce/Grains/etc.
4FX05Sch F - Cooperative Distributions
4FX06Sch F - Agricultural Program Payments
4FX07aSch F-Commodity Credit Corporation Loans Reported
4FX07bSch F-Commodity Credit Corporation Loans Forfeited
4FX08Sch F - Crop Insurance and Disaster Payments
4FX08aSch F - Spec. Custom Hire (Machine Work) Income
4FX08bSch F - Other Custom Hire Income
4FX09Sch F - Custom Hire (Machine Work) Income
4FX09aSch F - Other Specified Income
4FX10Sch F - Other Income
4FGLSchedule F Net Gain/Loss
4NRPQ Table
4TH01Other Write in Income
4Z101aSch C-EZ-Gross Receipts/Sales Merch/3rd Party
4Z101bSch C-EZ-Other Gross Receipts or Sales
4Z101cSch C-EZ-Income Reported on Form W-2
51006aExemptions-Self/Spouse
51006cDependent Children-Live with Taxpayer
51006dDependent Children-Do Not Live with Taxpayer
51006eDependent-Parents
51006fDependent-Other
51006gDependent-Other Displaced Individual
51023IRA Deduction
51024Student Loan Interest Deduction
51025Archer MSA Deduction
51026Moving Expenses
51027Deductible Part of SE Tax
51028Self-Employed Health Insurance
51029Self-Employed SEP, Simple, and Qualified Plans
51030Penalty on Early Withdrawal of Savings
51031Alimony Paid
51032Educator Expenses
51033Tuition and Fees Deduction
51035Domestic Production Activities Deduction (F8903)
51036Standard Deduction
51036aCharitable Contributions for Standard Deduction
51037Other Adjustments Affecting AGI
51037a"WBF" for the Deduction for Whistleblower Fees
51037bJury Duty Fees
51037cForeign Income Housing Deduction
51037dPersonal Property Rental Expenses
51037eReforestation Amortization
51037fRepayment of Supplement Unemployment Benefits
51037gContributions to Section 501(c) Plans
51037hContributions to Section 403(b) Plans
51037iDeduction for Clean-fuel Vehicles
51037jUnlawful Discrimination Claim Fees
51038Certain Business Expenses from F2106(EZ )
51039Health Saving Account Deduction (F8889)
51040Qualified Business Income Deduction (QBID)
52101Vehicle Expense
52102Parking/Tolls/Transportation - Not Away From Home
52103Travel Expense - Away From Home Overnight
52104Other Business Expenses
52105Meals and Entertainment
52107Expense Reimbursement – Not Reported
5A001Medical and Dental
5A003Medical and Dental AGI Percentage
5A005aState and Local Income Taxes
5A005bState and Local General Sales Taxes
5A006Real Estate Taxes
5A007Personal Property Taxes
5A008Other Taxes
5A009Qualified Motor Vehicle Taxes
5A010Home Mortgage Interest and points From Form 1098
5A011Home Mortgage Interest Not From Form 1098
5A012Points Not From Form 1098
5A013Investment Interest
5A014Qualified Mortgage Insurance Premiums
5A015Cash Contributions
5A016Non-Cash Contributions
5A017Contributions Carryover
5A019Casualty and Theft Loss
5A020Other Unreimbursed Employee Expenses
5A021Tax Preparation Fees
5A022Other Expenses Subject to 2% AGI Limitation
5A027Other Miscellaneous Deductions
5A028Gambling Losses
5CX04Sch C - Cost of Goods Sold
5CX08Sch C - Advertising
5CX09Sch C - Bad Debts From Sales or Services
5CX10Sch C - Car and Truck Expenses
5CX11Sch C - Commissions and Fees
5CX12Sch C - Depletion
5CX13Sch C - Depreciation and Sec. 179 Expense
5CX14Sch C - Employee Benefits Programs
5CX15Sch C - Insurance (Other Than Health)
5CX16aSch C - Interest - Mortgage
5CX16bSch C - Interest - Other
5CX17Sch C - Legal and Professional Services
5CX18Sch C - Office Expenses
5CX19Sch C - Pension and Profit-Sharing Plans
5CX20aSch C - Rent/Lease - Vehicles/Machinery/Equip.
5CX20bSch C - Rent/Lease - Other Business Property
5CX21Sch C - Repairs and Maintenance
5CX22Sch C - Supplies
5CX23Sch C - Taxes and Licenses
5CX24aSch C - Travel
5CX24bSch C - Meals and Entertainment
5C124cSch C-EZ-Optnl Non-Deductible Meals/Entertainment
5C124zSch C-EZ-Optional Meals & Entertainment
5CX25Sch C - Utilities
5CX26Sch C - Wages
5CX27Sch C - Other Expenses
5CX30Sch C - Expenses for Business Use of Home
5CX35Sch C - Beginning Inventory
5CX36Sch C - CGS - Purchases
5CX37Sch C - CGS - Cost of Labor
5CX38Sch C - CGS - Materials and Supplies
5CX39Sch C - CGS - Other Costs
5CX41Sch C - Ending Inventory
5C150Sch C-EZ - Total Expenses – Lines 2a/2b not used
5C150zSch C-EZ - Optional Other Expenses
5CX60Sch C - Contract labor
5EX05Sch E - Advertising
5EX06Sch E - Auto and Travel
5EX07Sch E - Cleaning and Maintenance
5EX08Sch E - Commissions
5EX09Sch E - Insurance
5EX10Sch E - Legal and Other Professional Fees
5EX11Sch E - Management Fees
5EX12Sch E - Mortgage Interest
5EX13Sch E - Other Interest
5EX14Sch E - Repairs
5EX15Sch E - Supplies
5EX16Sch E - Taxes
5EX17Sch E - Utilities
5EX18Sch E - Other Expenses
5EX20Sch E - Depreciation Expense or Depletion
5EX21Sch E - Royalty Expenses
5FX01dSch F - Cost/Other Basis of Livestock/Other
5FX02Sch F - Cost/Oth. Basis of Livestock&Oth. Items-Ln1
5FX12Sch F - Car and Truck Expenses
5FX13Sch F - Chemicals
5FX14Sch F - Conservation Expenses
5FX15Sch F - Custom Hire (Machine Work)
5FX16Sch F - Depreciation and Section 179 Expense
5FX17Sch F - Employee Benefit Programs
5FX18Sch F - Feed Purchases
5FX19Sch F - Fertilizer and Lime
5FX20Sch F - Freight and Trucking
5FX21Sch F - Gasoline, Fuel, and Oil
5FX22Sch F - Insurance (Other Than Health)
5FX23aSch F - Interest - Mortgage
5FX23bSch F - Interest - Other
5FX24Sch F - Labor Hired
5FX25Sch F - Pension and Profit-Sharing Plans
5FX26aSch F - Rent/Lease - Vehicles/Machinery/Equipment
5FX26bSch F - Rent or Lease - Other
5FX27Sch F - Repairs and Maintenance
5FX28Sch F - Seeds and Plants Purchased
5FX29Sch F - Storage and Warehousing
5FX30Sch F - Supplies Purchased
5FX31Sch F - Taxes
5FX32Sch F - Utilities
5FX33Sch F - Veterinary, Breeding and Medicine
5FX34Sch F - Other Expenses
5FX46Sch F - Beginning Inventory
5FX49Sch F - Ending Inventory
5TH01Other Deduction/Expense
61001Filing Status
61040aTax from Form 8814
61040bTax from Form 4972
61040cOther Write-ins to Tax
61041Alternative Minimum Tax
61042Additional Taxes
61043Foreign Tax Credit
61044Child or Dependent Care Credit
61045Elderly or Disabled Credit
61046Education Credit - Issue Name must be a SSN
61047Rate Reduction Credit
61048Child Tax Credit
61048aCredit for Other Dependents
61049Adoption Credit From Form 8839
61050Other Credits Not From Forms 3800, 8396, 8801, 8859
61050aOther Credits From Form 3800
61050bOther Credits From Form 8801
61050cOther Credits From Form 8396
61050dOther Credits From Form 8859
61050eSection 45R Credit for Health Care
61050fClean Vehicles Credit (Form 8936)
61050gPreviously Owned Clean Vehicles Credit (Form 8936)
61051Retirement Savings Contribution Credit
61052Residential Energy Credit From Form 5695
61052aResidential Clean Energy Credit (Form 5695)
61052bEnergy Efficient Home Improvement Credit (Form 5695)
61053Self-Employment Tax
61054SS and Medicare Tax on Tip Income From Form 4137
61055Tax on Qualified Plans
61056Advance Earned Income Credit payments
61057Household Employment Taxes
61058Uncollected SS & Medicare Tax on Wages (F8919)
61059W-2/1099 Federal Income Tax Withholding
61060Est. Tax Pymts/Pr Yr Overassessment - not posted
61061Earned Income Tax Credit
61061bNonTaxable Combat Pay Election
61062Excess Social Security and RRTA Tax Withheld
61063Additional Child Tax Credit
61063aRefundable Child Tax Credit
61064Amt Paid w/Extension to File - not posted to TP’s Acct
61065Frozen Refund
61065aForm 2439
61065bForm 4136
61065cForm 8885
61065dForm 8801, Refundable Credit
61065eOther Write-ins to Refundable Credits
61065fQualified Sick/Family Leave Credits
61065gDeferral for Certain Sch H or SE filers
61065hRefundable Child or Dependent Care Credit
61065iClaim of Right Credit
61066Other Taxes
61066aFTHBC Recapture
61066bTaxes from Form 8959
61066cTaxes from Form 8960
61066dSection 965 Net Tax Liability from Form 965-A
61066eAdditional Tax from Schedule 8812
61067Making Work Pay/Govt Retiree Credit
61068Refundable American Opportunity Credit
61069First-time Homebuyer Credit From Form 5405
61070Recovery Rebate Credit
61070aRecovery Rebate Credit (CARES Act)
61071Federal Telephone Excise Tax Credit
61072Refundable Adoption Credit
62001Health Care - Shared Responsibility Payment
62002Premium Tax Credit (PTC)
62003Excess Advance PTC (APTC) Repayment
62401Accuracy Related Penalty - 6662
62402Fraud Penalty - 6663
62403Delinquency Penalty - 6651
62404Estimated Tax Penalty - 6654
62405Promoter Penalties
62406Erroneous Claim for Refund or Credit Penalty - 6676
62410Other Penalties (includes FBAR)
699999Impact of DeMinimus Issues
6TH01Other Tax/Credit
76150User Specified 1 (Issue name and 4318 description required)
76200User Specified 2 (Issue name and 4318 description required)
76250User Specified 3 (Issue name and 4318 description required)
76300User Specified 4 (Issue name and 4318 description required)
76350User Specified 5 (Issue name and 4318 description required)
76400User Specified 6 (Issue name and 4318 description required)
76450User Specified 7 (Issue name and 4318 description required)
7C10XSch C-1 - IRC 183
7C1FSch C-1- Accounting Method
7EX0XSch E - IRC 183
7FX0XSch F - IRC 183
7FXCSch F - Accounting Method
99999Change/No Change
999999Statutory Adjustment

Note:

For all the Schedule C, Schedule E, and Schedule F issues, the IMF Code displays an X to indicate the number of the schedule being adjusted, for example, 4C101, 4C201 or 4C301.

Exhibit 4.10.16-2

Sub Chapter S SAIN Codes

CodeIssue
000Issue does not exist
001Precontact Analysis
002Pre - Exam Conference
003Preliminary Examination Time
004Preparing Examination Plan
005Coordination
006Travel Time
007Report Preparation
008Examination Critique
009Meetings
010Review Protest / Prepare Rebuttal
010-01Fast Track
011Penalty Consideration
012Form 5699 (Information Document Request Log)
013Issue Control Sheet - Form 5701 (Notice of Proposed Adjustments)
014Referrals to Specialists
015Financial Interest
016Correspondence
017POA / Form 8821 (Tax Information Authorization)
018Statute of Limitations
020Prior Revenue Agent Report
021Prior Appeals Report
022Joint Committee Reports
024Risk Analysis
030Administrative Lead Sheet
031LB&I Quality Measurement System Check Sheet
032LB&I Joint Audit Planning Process Tool
033Pre-audit Interview History Lead Sheet
034Examiner's RRA 98 Compliance Guide
035Team Manager Check Sheet
060Claims
061Self-Audit Adjustments (Affirmative Adjustments)
080Planning File
100Balance sheet (no balance sheet attached)
101Cash
102Trade notes & accounts receivable
102-01Allowance for Bad Debts
103Inventories
104U.S. government obligations
105Tax-exempt securities
106Other current assets
107Loans to shareholders
107-01Loans to persons related to shareholders
108Mortgage & real estate loans
109Other investments
110Buildings & other depreciable assets
110-01Accumulated depreciation
111Depletable assets
111-01Accumulated depletion
112Land (net of any amortization)
113Intangible assets
113-01Accumulated amortization
114Other assets
216Accounts payable
217Mortgages, notes, bonds payable in less than 1 year
218Other current liabilities
218-01Related Party Accruals
219Loans from shareholders
219-01Loans from persons related to shareholders
220Mortgages, notes, bonds payable in 1 year or more
221Other liabilities
322Capital stock
323Additional paid-in capital
325Retained earnings
325-01Reconciliation of retained earnings
326Cost of treasury stock
327Adjustment to shareholders' equity
401Gross receipts or sales
401-01Sales to related entities
401-02Merchant card and third party payments
402Returns and allowances
409Net gain (loss) from Form 4797, Part II
410Other income (loss)
410-01Partnership income (loss) (Tiered Entity)
410-02Cancellation of Debt Income
502Cost of goods sold (No Sch. A or F1125-A detail)
502-01Inventory (Beginning)
502-02Purchases
502-03Cost of labor
502-04Additional IRC 263A costs
502-05Other costs
502-10Inventory (Ending)
512Compensation of officers
513Salaries & wages
514Repairs & maintenance
515Bad debts
516Rents
517Taxes & licenses
518Interest
519Charitable contributions
520Depreciation
521Depreciation (other than page 1 Form 1120S)
522Depletion
523Advertising
524Pension, profit sharing plans, etc. plans
525Employee benefit programs
526Other deductions (no schedule attached)
526-01Administrative fees
526-02Amortization
526-03Automobile expense
526-04Bonus expense
526-05Consulting fees
526-06Contract labor
526-07Commissions
526-08Computer expense
526-09Dues & subscriptions
526-10Education expenses
526-11Equipment rental
526-12Fringe benefits
526-13Fuel expense
526-14Gifts & awards expenses
526-15Insurance expenses
526-16Janitorial services
526-17Leasing expense
526-18Legal & professional fees
526-19License & permit expenses
526-20Maintenance & cleaning
526-21Management & director fees
526-22Meals & entertainment
526-23Meeting, seminars & conventions
526-24Miscellaneous expenses
526-25Other expenses
526-26Outside services
526-27Postage & courier expense
526-28Proposal or bidding expense
526-29Public relations expense
526-30Publication expense
526-31Recruiting & training
526-32Research & development
526-33Royalty expense
526-34Security expense
526-35Shipping, freight & handling
526-36Supplies - office
526-37Supplies - tools & factory
526-38Telephone expense
526-39Travel expense
526-40Utility expense
527Domestic Production Activities
528Schedule M-1 (Book vs. Tax)
528-01Schedule M-2 (AAA Analysis)
528-02Schedule M-2 (Other Adjustments Account Analysis)
528-03SH Undistributed PTI
531Energy Efficient Commercial Buildings
604-10IRC 45R credit for health care
610-04Lookback Interest
622-01Excess net passive income tax
622-02Tax from Schedule D (Built-In Gains)
622-03Additional taxes - LIFO reserve recapture tax
622-04Qualified opportunity fund - Form 8996
623-01Payments
623-02Tax deposits
623-04Refundable credit - Form 8827, Line 8c
623-05Other write-ins to refundable credits
623-06Fuel tax credit
623-07Telephone Excise Tax credit
624-01Accuracy Related Penalty - IRC 6662
624-02Fraud Penalty - IRC 6663
624-03Delinquency Penalty - IRC 6699
624-04Estimated Tax Penalty - IRC 6655
624-05Promoter Penalties
624-10Other penalties (includes FBAR)
625BBA AAR imputed underpayment
633Interest due under the look-back method - completed long term contracts
634Interest due under the look-back method - income forecast method
701Minutes & other records
703Acquisitions, mergers & reorganizations
703-01Schedule M-2
706IRC 482 potential
707Method of accounting
708Initial return
709Final return
710Related party transactions
713Mandatory compliance checks
713-01Related returns
713-02Prior & subsequent returns
713-03Minimum inventory checks
713-04Minimum income probe
713-05Other filing checks
723Changes in ownership
724TEFRA/BBA/ILSC
725Character of income (separately stated items)
726Potentially abusive schemes
726-01Form 8275 disclosure statement
726-02Form 8886 reportable transaction
726-03Transaction lacks economic substance
727Termination or Invalid S Election
728Reconcile Schedule K-1 to Schedule K
729Losses and deduction claimed in excess of stock and debt basis
730Passive activity losses and material participation
731IRC 465 - at risk limitation
732Corporate level limits
743IRC 183 - hobby loss
801Statistical sampling procedures
802–01Computer audit specialist (CAS)
802–02Employment tax examiner
802–03International examiner
802-04Engineer
802–05Exempt organization examiner
802–06Excise tax examiner
802-07Financial products examiner
802-08Economist
802–09Actuary
802–10Employee Plans
802-11Appraisers
802–12Exam Tech/Audit Aides
802–13Contracting Officer's Technical Representative (COTR)
802–14Tax Computation Specialist
803–01Life insurance examiner
803–02Property & Casualty insurance examiner
804Other Classified Issue 1
805Other Classified Issue 2
806Other Classified Issue 3
807Other Classified Issue 4
808Other Classified Issue 5
809Other Classified Issue 6
901-01Ordinary income (loss) from trade or business
902Net income (loss) from rental real estate
903Other Gross Rental Income
903-01Expenses from other rental activities
904-01Interest income
904-02Dividend income
904-03Qualified dividend income
904-04Royalty income
904-05Net short-term capital gain (loss)
904-06Net STCG / loss (>5-3-03) '03 only
904-07Net long-term capital gain (loss)
904-08Net LTCG / loss (28%)
904-09Net LTCG / loss (5 Year)
904-10Net LTCG / loss (>5-3-03) '03 only
904-11Other portfolio income (loss)
904-12Unrecaptured IRC 1250 gain
905Net IRC 1231 gain (loss) from Form 4797
905-01Net IRC 1231 gain (loss) (>5-3-03) '03 only
906Other income (loss)
908IRC 179 expense deduction
909Deductions related to portfolio income
910Other deductions
911Interest expense on investment debts
911-01Investment income (portfolio income)
911-02Investment expenses (portfolio income)
912-01Credit for alcohol used as a fuel
912-02Low income housing credit IRC 42(j)(5)
912-03Low income housing credit - other
912-06Qualified rehab expense - rental activity
912-07Credits - rental real estate activities
912-08Credits - other rental activities
913Other credits and credit recapture
914-01AMT - Depreciation adjustment
914-02AMT - Adjusted gain (loss)
914-03AMT - Depletion (other than oil and gas)
914-05AMT - Gross inc. - oil/ gas/ geothermal properties
914-06AMT - Deductions - oil/ gas/ geothermal properties
914-07AMT - Other adjustments / tax preference items
915Name of foreign country or U.S. possession\`
915-01Gross income from all sources
915-02Gross income sourced at SH level
915-03Foreign gross income - passive
915-04Foreign gross income - general
915-05Foreign gross income - other
915-06Allocable deductions SH - interest
915-07Allocable deductions SH - other
915-08Allocable deductions corp - passive
915-09Allocable deductions corp - general
915-10Allocable deductions corp - other
915-11Total foreign taxes paid
915-12Reduction in taxes available for credit
915-13Total foreign taxes accrued
915-14Foreign gross income - section 951A category
915-15Foreign gross income - foreign branch category
915-16Allocable deductions corp - section 951A category
915-17Allocable deductions corp-foreign branch category
916-01IRC 59(e)(2) expenditures
916-02Type of expenditures
917Tax-exempt interest income
918Other tax-exempt income
919Non-deductible expenses
920Distributions
920-01Non-cash distributions
920-02Disproportionate distributions
920-03Repayments of Loans from Shareholders
920-04Distributions of Earnings & Profits
920-05Distribution in Excess of Basis
920-06Distribution of Property or Bargain Sale
921Other items & amounts to be reported separately
922Total dividend distributions from E & P
923Investment income
924Investment expenses
925Qualified business income deduction - Section 199A
76150User Specified 1 (Issue name and 4318 description required)
76200User Specified 2 (Issue name and 4318 description required)
76250User Specified 3 (Issue name and 4318 description required)
76300User Specified 4 (Issue name and 4318 description required)
76350User Specified 5 (Issue name and 4318 description required)
76400User Specified 6 (Issue name and 4318 description required)
76450User Specified 7 (Issue name and 4318 description required)

Exhibit 4.10.16-3

Partnership SAIN Codes

CodeIssue
000Issue does not exist
001Precontact Analysis
002Pre - Exam Conference
003Preliminary Examination Time
004Preparing Examination Plan
005Coordination
006Travel Time
007Report Preparation
008Examination Critique
009Meetings
010Review Protest / Prepare Rebuttal
010-01Fast Track
011Penalty Consideration
012Form 5699 (Information Document Request Log)
013Issue Control Sheet - Form 5701 (Notice of Proposed Adjustments)
014Referrals to Specialists
015Financial Interest
016Correspondence
017POA / Form 8821(Tax Information Authorization)
018Statute of Limitations
020Prior Revenue Agent Report
021Prior Appeals Report
022Joint Committee Reports
024Risk Analysis
030Administrative Lead Sheet
031LB&I Quality Measurement System Check Sheet
032LB&I Joint Audit Planning Process Tool
033Pre-audit Interview History Lead Sheet
034Examiner's RRA 98 Compliance Guide
035Team Manager Check sheet
060Claims
061Self-Audit Adjustments (Affirmative Adjustments)
080Planning File
100Balance sheet
101Cash
102Trade notes & accounts receivable
102-01Allowance for bad debts
103Inventories
104U.S. government obligations
105Tax-exempt securities
106Other current assets
107Loans to partners
107-01Loans to persons related to partners
108Mortgage & real estate loans
109Other investments
110Buildings & other depreciable assets
110-01Accumulated depreciation
111Depletable assets
111-01Accumulated depletion
112Land (net of any amortization)
113Intangible assets
113-01Accumulated amortization
114Other assets
216Accounts payable
217Mortgages, notes, bonds payable in less than 1 year
218Other current liabilities
218-01Related party accruals
219-01All nonrecourse loans
220Mortgages, notes, bonds payable in 1 year or more
220-01Loans from partners
220-02Loans from persons related to partners
221Other liabilities
321Partners' capital accounts
321-01Final Schedule K-1 with Unresolved Negative Capital Account
321-02Analysis of partner's capital account (Sch M-2)
400Profit & loss statement
401Gross receipts or sales
401-01Sales to related entities
401-02Merchant card and third party payments
402Returns and allowances
403Ordinary income (loss) from partnerships, etc.
403-01Net farm profit (loss)
409Net gain (loss) from Form 4797, Part II
410Other income (loss)
410-01Partnership income (loss) (Tiered entity)
410-02Cancellation of debt income
502Cost of goods sold (No Sch. A or F1125-A Detail)
502-01Inventory (beginning)
502-02Purchases
502-03Cost of labor
502-04Additional IRC 263A costs
502-05Other costs
502-10Inventory (ending)
510Guaranteed payments to partners
510-01Capital versus ordinary expense
510-02Character of payment to retiring partner
513Salaries & wages
514Repairs & maintenance
515Bad debts
516Rent
517Taxes & licenses
518Interest
519Charitable contributions
520Depreciation
521Depreciation (other than page 1 Form 1065)
522Depletion
523Advertising
524Retirement plans, etc.
525Employee benefit programs
526Other deductions (no schedule attached)
526-01Administrative fees
526-02Amortization
526-03Auto & truck expenses
526-04Bonus expense
526-05Consulting fees
526-06Contract labor
526-07Commissions
526-08Computer expense
526-09Dues & subscriptions
526-10Education expenses
526-11Equipment rental
526-12Fringe benefits
526-13Fuel expense
526-14Gifts & awards expenses
526-15Insurance expenses
526-16Janitorial services
526-17Leasing expense
526-18Legal & professional fees
526-19License & permit expenses
526-20Maintenance & cleaning
526-21Management & director fees
526-22Meals & entertainment
526-23Meeting, seminars & conventions
526-24Miscellaneous expenses
526-25Other expenses
526-26Outside services
526-27Postage & courier expense
526-28Proposal or bidding expense
526-29Public relations expense
526-30Publication expense
526-31Recruiting & training
526-32Research & development
526-33Royalty expense
526-34Security expense
526-35Shipping, freight & handling
526-36Supplies - office
526-37Supplies - tools & factory
526-38Telephone expense
526-39Travel expense
526-40Utility expense
527Domestic Production Activities
528Schedule M-1
531Energy efficient commercial buildings
604Credits
604-10IRC 45R credit for health care
609-10Corporate Alternative Minimum Tax (CAMT)
610-02Other taxes
610-04Lookback Interest
623-01Payments
623-07Telephone Excise Tax credit
624-01Accuracy Related Penalty - IRC 6662
624-02Fraud Penalty - IRC 6663
624-03Delinquency Penalty - IRC 6698
624-04Estimated Tax Penalty
624-05Promoter Penalties
624-10Other Penalties (includes FBAR)
625BBA AAR imputed underpayment
633Interest due under look-back method - completed long term contracts
634Interest due under the look-back method - income forecast method
700-01Administrative
700-02Pre-Audit/Interview/History
700-03Required Filing Checks
700-05Cost of Sales
700-06Penalties
700-08TEFRA Consideration
701Partnership agreement & other records
703Acquisitions, mergers & reorganizations
703-01Schedule M-2
706IRC 482 potential
707Method of accounting
708Initial return - IRC 195, 246, 1060
709Final return - distributions
710Related party transactions
712Distributions in excess of basis
713Mandatory compliance checks
713-01Related returns
713-02Prior & subsequent returns
713-03Minimum inventory checks
713-04Minimum income probe
713-05Other filing checks
720Initial return
721Final return
722Related party transactions
723Changes in ownership
724TEFRA/BBA/ILSC
725Character of income (separately stated items)
726Potentially abusive schemes
726-01Form 8275 Disclosure Statement
726-02Form 8886 Reportable Transaction Disclosure Statement
726-03Transaction lacks economic substance
728Reconcile Schedule K-1 to Schedule K
729IRC 704(d) - losses and or deductions claimed in excess of basis
730IRC 469 - passive activity losses and material participation
731IRC 465 - At risk limitation
735IRC 707 - disguised sales
736IRC 704(c) & IRC 737
737IRC 754 - election
737-01IRC 743(b) - basis adjustment
737-02IRC 734(b) - basis adjustment
738IRC 708 - partnership terminations
739IRC 704(b) - special allocations
739-01Use of tax neutral partners (i.e. tax exempt or foreign)
740Family partnership inconsistent with IRC 704(e)
741IRC 752 - partner's share of liabilities
741-01Nonrecourse
741-02Qualified nonrecourse
741-03Recourse/Other
742IRC 741 - sale of partnership interest / Form 8308
742-01IRC 751 Ordinary income recapture
742-02IRC 755 - Allocation basis
743IRC 183 - hobby loss
801Statistical sampling procedures
802Other Classified Issue 2
802–01Computer audit specialist (CAS)
802-02Employment tax examiner
802–03International examiner
802-04Engineer
802–05Exempt organization examiner
802–06Excise tax examiner
802-07Financial products examiner
802-08Economist
802–09Actuary
802–10Employee Plans
802-11Appraisers
802–12Exam Tech/Audit Aides
802–13Contracting Officer's Technical Representative (COTR)
802–14Tax Computation Specialist
803Other Classified Issue 3
803–01Life insurance examiner
803–02Property & Casualty insurance examiner
804Other Classified Issue 1
805Other Classified Issue 2
806Other Classified Issue 3
807Other Classified Issue 4
808Other Classified Issue 5
809Other Classified Issue 6
901-01Ordinary income (loss) from trade or business
902Net income (loss) from rental real estate
903Other gross rental income
903-01Expenses from other rental activities
903-02Portfolio income (loss) from ordinary dividends
903-03Portfolio income (loss) from royalty income
903-04Net short-term capital gain (loss)
903-05Net long-term capital gain (loss)
903-06Other portfolio income (loss)
904-01Portfolio income (loss) from interest income
904-02Portfolio income (loss) from ordinary dividends
904-03Portfolio income (loss) from qualified dividends
904-04Portfolio income (loss) from royalty income
904-05Net short-term capital gain (loss)
904-06Net STCG / loss (>5-3-03) '03 only
904-07Net long-term capital gain (loss)
904-08Net LTCG / loss (28%)
904-09Net LTCG / loss (5 year)
904-10Net LTCG / loss (>5-3-03) '03 only
904-11Other portfolio income (loss)
904-12Unrecaptured 1250 gain
904-13Dividend equivalents
905Net IRC 1231 gain (loss) from Form 4797
905-01Net IRC 1231 gain (loss) (>5-3-03) '03 only
906Other income (loss)
906-01Cancellation of indebtedness (COD) - IRC 61(a)(12)
908IRC 179 expense deduction
908-01Section 179 expense deduction
908-02Deductions related to portolio income
908-03Other deductions
909Deductions related to portfolio income
910Other deductions
911Interest expense on investment debts
911-01Investment income included in portfolio income
911-02Investment expense-deductions related to portfolio income
912-01Credit for income tax withheld
912-02Low income housing credit IRC 42(j)(5)
912-03Low income housing credit - other
912-04Credits related to rental real estate activities
912-05Credits related to other rental activities
912-06Qualified Rehabilitation Expenses - rental real estate activities
912-07Credits related to rental real estate activities
912-08Credits related to other rental activities
913Other credits and credit recapture
914Other credits
914-01AMT - Depreciation adjustment
914-02AMT - Adjusted gain (loss)
914-03AMT - Depletion (other than oil and gas)
914-05AMT - gross inc. - oil/gas/geothermal properties
914-06AMT - Deductions - oil/ gas/ geothermal properties
914-07AMT - Other adjustments / tax preference items
915Name or foreign country or U.S. possession
915-01Gross income from all sources
915-02Gross income sourced at partner level
915-03Foreign gross income - passive
915-04Foreign gross income - listed categories
915-05Foreign gross income - general limitation
915-06Allocable deductions partner - interest
915-07Allocable deductions partner - other
915-08Allocable deductions partnership - passive
915-09Allocable deductions partnership - listed
915-10Allocable deductions partnership - general
915-11Total foreign taxes paid
915-011Net earnings (loss) from self-employment
915-12Reduction in taxes available for credit
915-13Total foreign taxes accrued
915-14Foreign gross income - section 951A category
915-15Foreign gross income - foreign branch category
915-16Allocable deductions partnership - section 951A category
915-17Allocable deductions partnership - foreign branch category
915-18Other foreign tax information
915-021Gross farming or fishing income
915-031Gross nonfarm income
916-01IRC 59(e)(2) expenditures
916-02Type of expenditures
917Tax-exempt interest income
918Other tax-exempt income
919Non-deductible expenses
920Distributions
920-01Distributions of property other than money
920-02Distributions in excess of basis
920-03Distributions of money (cash & securities)
920-04Distribution of property or bargain sale
920-05Distribution of cash and securities
921Other items & amounts to be reported separately
923Investment income
924Investment expenses
925Qualified business income deduction - Section 199A
76150User Specified 1 (Issue name and 4318 description required)
76200User Specified 2 (Issue name and 4318 description required)
76250User Specified 3 (Issue name and 4318 description required)
76300User Specified 4 (Issue name and 4318 description required)
76350User Specified 5 (Issue name and 4318 description required)
76400User Specified 6 (Issue name and 4318 description required)
76450User Specified 7 (Issue name and 4318 description required)

Exhibit 4.10.16-4

Reason Codes

CategorizationCodeDescriptionExample/Definition
Issue Changed - No Issue Penalty Asserted02Taxpayer unaware of tax laws or record keeping requirementsTaxpayer may lack formal education or have a language barrier that prevents understanding requirements.
Issue Changed - No Issue Penalty Asserted03Disregarded record keeping rulesTaxpayer understood law and requirements but taxpayer's poor record keeping contributed to the errors and inability to substantiate amounts claimed on the return.
Issue Changed - No Issue Penalty Asserted05Action or advice of Return Preparer - No Penalty assertedThe error resulted from action or advice of paid preparer. The nature or amount of adjustment was not sufficient to warrant a penalty.
Issue Changed - No Issue Penalty Asserted06Inadvertent understatement or overstatement of income or deductionsTaxpayer understood the law but inadvertently misstated items on the return.
Issue Changed - No Issue Penalty Asserted14Taxpayer entered item on the wrong form, schedule, or lineSelf-explanatory.
Issue Changed - No Issue Penalty Asserted17Intentional disregard of tax laws - No penalty assertedTaxpayer made intentional decision to understate income or overstate deductions, credits, or prepayments. However, the nature or amount of the adjustment was not sufficient to warrant a penalty.
Issue Changed - No Issue Penalty Asserted18Relied on advice of IRS Staff or PublicationsTaxpayer indicates the error was based upon advice from IRS personnel or information in IRS publications.
Issue Changed - No Issue Penalty Asserted20Taxpayer relied on tax preparation softwareThe error resulted from taxpayer's improper data entry in software program.
Issue Changed - No Issue Penalty Asserted21Used 'gray area' in the law or regulationsTaxpayer/return preparer took position on issue on interpretation of law.
Issue Changed - Issue Penalty Asserted07Intentional misstatement of income, deductions, credits, or prepaymentsSelf-explanatory.
Issue Changed - Issue Penalty Asserted10Income/expenses entered on wrong form to reduce tax or increase creditsFor example, moving deductions from Schedule A to Schedule C to avoid SE tax.
Issue Changed - Issue Penalty Asserted19Action or advice of Return Preparer - Penalty assertedThe error resulted from action or advice of paid preparer and was sufficiently blatant to warrant a penalty.
Issue Changed - Issue Penalty Asserted32FraudThe taxpayer omitted income or overstated deductions, credits, or prepayments with the intent to evade taxes.
Issue Changed - Issue Penalty Asserted33Abusive SchemesThe taxpayer asserts standard frivolous filer arguments or has used other abusive schemes.
Issue Changed - Earned Income Credit Issue60No earned incomeSelf-explanatory.
Issue Changed - Earned Income Credit Issue61Filing status changed to married filing separate statusSelf-explanatory.
Issue Changed - Earned Income Credit Issue62Requirement for filing Form 2555 met or Form 2555 filedSelf-explanatory.
Issue Changed - Earned Income Credit Issue63Non-resident alienSelf-explanatory.
Issue Changed - Earned Income Credit Issue64Investment income exceeds maximumSelf-explanatory.
Issue Changed - Earned Income Credit Issue65Taxpayer/spouse is qualifying child of anotherSelf-explanatory.
Issue Changed - Earned Income Credit Issue66Primary/secondary does not have a valid SSN for employmentSelf-explanatory.
Issue Changed - Earned Income Credit Issue67'Relationship test' for child claimed on Schedule EIC not metSelf-explanatory.
Issue Changed - Earned Income Credit Issue68'Residency test' for child claimed on Schedule EIC not metSelf-explanatory.
Issue Changed - Earned Income Credit Issue69'Age test' for child claimed on Schedule EIC not metSelf-explanatory.
Issue Changed - Earned Income Credit Issue70EITC qualifying child does not have a valid SSN for employmentSelf-explanatory.
Issue Changed - Earned Income Credit Issue71Taxpayer/spouse is eligible to be claimed as dependent by anotherSelf-explanatory.
Issue Changed - Earned Income Credit Issue72Main home outside United States for 6 months or moreSelf-explanatory.
Issue Changed - Earned Income Credit Issue73Increase to earned income or AGI or modified AGI (beginning Tax Year 2001)Self-explanatory.
Issue Changed - Earned Income Credit Issue74Decrease to earned income or AGI or modified AGI (beginning Tax Year 2001)Self-explanatory.
Issue Changed - Earned Income Credit Issue75Taxpayer denied, tie-breaker ruleSelf-explanatory.
Issue Changed - Earned Income Credit Issue76Change in qualifying children - IncreaseSelf-explanatory.
Issue Changed - Earned Income Credit Issue77IRS processing errorSelf-explanatory.
Adjustments from Flow Through Entities - NRP04Adjustment to 1040 due to basis limitation on 1120S - NRPAdjustment was made to limit the shareholder's loss due to insufficient basis in the NRP S corporation.
Adjustments from Flow Through Entities - NRP08Adjustment to 1040 due to at-risk limitation on 1120S - NRPAdjustment was made to limit the shareholder's loss due to the amount at risk in the NRP S corporation.
Adjustments from Flow Through Entities - NRP09Adjustment to 1040 due to passive activity limitation on 1120S - NRPAdjustment was made to limit the shareholder's loss from the NRP Scorporation due to passive activity rules.
Adjustments from Flow Through Entities - NRP12Adjustment to 1040 due to basis limitation on 1065 - NRPAdjustment was made to limit the partner's loss due to insufficient basis in the NRP partnership.
Adjustments from Flow Through Entities - NRP13Adjustment to 1040 due to at-risk limitation on 1065 - NRPAdjustment was made to limit the partner's loss due to the amount at risk in the NRP partnership.
Adjustments from Flow Through Entities - NRP15Adjustment to 1040 due to passive activity limitation on 1065 - NRPAdjustment was made to limit the partner's loss from the NRP partnershipdue to passive activity rules.
Adjustments from Flow Through Entities - NRP16Adjustment to 1040 due to passive activity limitation on trust - NRPAdjustment was made to limit the owner/beneficiary's loss from the NRP trust due to passive activity rules.
Adjustments from Flow Through Entities - NRP27Due to change in S corp income/(loss) item - NRPAdjustments resulting from the audit of the NRP S corporation that affected the shareholder's share of ordinary income/(loss) and/or separately stated items.
Adjustments from Flow Through Entities - NRP28Due to change in trust/estate income/(loss) item - NRPAdjustments resulting from the audit of the NRP trust/estate that affected the owner/beneficiary's share of ordinary income/(loss) and/or separately stated items.
Adjustments from Flow Through Entities - NRP29Due to change in partnership income/(loss) item - NRPAdjustments resulting from the audit of the NRP partnership that affected the partner's share of ordinary income/(loss) and/or separately stated items.
Adjustments from Flow Through Entities - NRP86Investor Level Statute Control (ILSC) - NRPInvestor Level Statute Control (ILSC) issue on an NRP case.
Adjustments from Flow Through Entities - NRP87TEFRA - Settlement Agreement - NRPNRP Case - Partner signed a Form 870-P, PT, L, or LT agreeing to the partnership adjustments binding the partners to their share of the adjustments.
Adjustments from Flow Through Entities - NRP88TEFRA - Defaulted FPAA - NRPNRP Case - Partner neither agrees nor petitions the Court resulting in the flow-through of the partnership adjustments to the partner.
Adjustments from Flow Through Entities - NRP89TEFRA - Court Decision - NRPNRP Case - Court issues a decision relative to the partnership adjustments allowing flow-through of adjustments to the partner.
Adjustments from Flow Through Entities - NRP90TEFRA - Bankruptcy - NRPNRP Case - Partner has petitioned the Bankruptcy Court and partnership items are converted to non-partnership items allowing the immediate flow-through of adjustments to the partner's return.
Adjustments from Flow Through Entities - NRP91TEFRA - AAR - NRPNRP Case - Tax Matters Partner (TMP) or partner has filed an Administrative Adjustment Request (AAR), which is an amended return for TEFRA partnerships. If accepted by the Service, these changes can be made at the request of the TMP or the partner.
Adjustments from Flow Through Entities - Non NRP24Due to change in S corp income/(loss) itemAdjustments resulting from the audit of the S corporation that affected the shareholder's share of ordinary income/(loss) and/or separately stated items.
Adjustments from Flow Through Entities - Non NRP25Due to change in trust/estate income/(loss) itemAdjustments resulting from the audit of the trust/estate that affected the owner/beneficiary's share of ordinary income/(loss) and/or separately stated items.
Adjustments from Flow Through Entities - Non NRP26Due to change in partnership income/(loss) itemAdjustments resulting from the audit of the partnership that affected the partner's share of ordinary income/(loss) and/or separately stated items.
Adjustments from Flow Through Entities - Non NRP34Adjustment to 1040 due to basis limitation on 1120SAdjustment was made to limit the shareholder's loss due to insufficient basis in the S corporation.
Adjustments from Flow Through Entities - Non NRP35Adjustment to 1040 due to at-risk limitation on 1120SAdjustment was made to limit the shareholder's loss due to the amount at risk in the S corporation.
Adjustments from Flow Through Entities - Non NRP36Adjustment to 1040 due to passive activity limitation on 1120SAdjustment was made to limit the shareholder's loss from the S corporation due to passive activity rules.
Adjustments from Flow Through Entities - Non NRP37Adjustment to 1040 due to basis limitation on 1065Adjustment was made to limit the partner's loss due to insufficient basis in the partnership.
Adjustments from Flow Through Entities - Non NRP38Adjustment to 1040 due to at-risk limitation on 1065Adjustment was made to limit the partner's loss due to the amount at risk in the partnership.
Adjustments from Flow Through Entities - Non NRP39Adjustment to 1040 due to passive activity limitation on 1065Adjustment was made to limit the partner's loss from the partnership due to passive activity rules.
Adjustments from Flow Through Entities - Non NRP40Adjustment to 1040 due to passive activity limitation on trustAdjustment was made to limit the owner/beneficiary's loss from the trust due to passive activity rules.
Adjustments from Flow Through Entities - Non NRP92Investor Level Statute Control (ILSC)Investor Level Statute Control (ILSC) issue.
Adjustments from Flow Through Entities - Non NRP93TEFRA - Settlement AgreementPartner signed a Form 870-P, PT, L, or LT agreeing to the partnership adjustments binding the partners to their share of the adjustments.
Adjustments from Flow Through Entities - Non NRP94TEFRA - Defaulted Final Partnership Administrative Adjustment (FPAA)Partner neither agrees nor petitions the Court resulting in the flow-through of the partnership adjustments to the partner.
Adjustments from Flow Through Entities - Non NRP95TEFRA - Court DecisionCourt issues a decision relative to the partnership adjustments allowing flow-through of adjustments to the partner.
Adjustments from Flow Through Entities - Non NRP96TEFRA - BankruptcyPartner has petitioned the Bankruptcy Court and partnership items are converted to non-partnership items allowing the immediate flow-through of adjustments to the partner's return.
Adjustments from Flow Through Entities - Non NRP97TEFRA - Administrative Adjustment Request (AAR)Tax Matters Partner (TMP) or partner has filed an Administrative Adjustment Request (AAR), which is an amended return for TEFRA partnerships. If accepted by the Service, these changes can be made at the request of the TMP or the partner.
Issue No Changed / Declassified51No Change - Taxpayer Substantiated the IssueThe issue was examined and substantiated.
Issue No Changed / Declassified52No Change - De MinimisThe issue was examined and closed for lack of potential, immaterial change, or no-changed due to timing issues.
Issue No Changed / Declassified53Issue Accepted as FiledExaminer - identified issue that does not warrant further examination. Should never be used for NRP examinations.
Issue No Changed / Declassified54No Change - 1120S StudyThe issue was examined and accepted as filed as part of the 1120S NRP Study.
Issue No Changed / Declassified84Declassified - Employee not trained on classified issueEmployee is unable to examine issue due to lack of training or experience.
Issue No Changed / Declassified85Declassified - No Audit PotentialClassified issue that was not examined after a determination that it lacked audit potential.
Other11No Show / No Response / Undeliverable MailUsed for adjustments where the taxpayer did not keep any appointments or respond to contact attempts or where mail to the taxpayer was returned undelivered.
Other22Statutory AdjustmentAutomatic adjustments due to changes to income/other limits. This code is automatically generated by the report writing software.
Other23Change due to adjustment in another year, financial and tax accounting differences, or entity types - not intentionalSelf-explanatory. Do not use for adjustments resulting from flow-through entities.
Other43Audit reconsiderationAdjustment based upon reconsideration of previous examination or IRS action. This includes Substitute For Return (SFR) assessment being corrected based upon the receipt of a filed return from the taxpayer.
Other44Computation or 'per return' Service Center errorAn adjustment necessary to correct a computational error on the return or incorrect transcription during return processing.

Exhibit 4.10.16-5

Rental Type Codes

CategoryCodeDescription
Residential11Single family house
Residential12Apartment or townhouse
Residential13Duplex house
Residential14Small apartment building - less than 5 apartments
Residential15Medium apartment building - 5 to 9 apartments
Residential16Large apartment building - more than 10 apartments
Vacation21Single family house
Vacation22Apartment or townhouse
Vacation23Duplex house
Vacation24Small apartment building - less than 5 apartments
Vacation25Medium apartment building - 5 to 9 apartments
Vacation26Large apartment building - more than 10 apartments
Commercial31Single store
Commercial322 to 4 stores
Commercial33More than 4 stores
Commercial34Warehouse
Commercial35Factory
Commercial36Office Space
Commercial37Land
Commercial38Self-Rental
Commercial40Other commercial
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