Responsible Person.  A "responsible person" is a person or a group of people who has the duty to perform and the power to direct the collecting, accounting and paying of Trust Fund taxes. The person may be an officer or employee of a corporation, a member or employee of a partnership, a corporate director or shareholder, a member of a board of trustees of a nonprofit organization, or another person with authority and control over funds to direct their disbursement.

Retention Register.  IRS records which contain all entity and tax modules removed from the Master File. The basic criteria for removal of a tax module are: (a) the assessed module balance is zero and the last transaction (including the return) has been posted 51 or more months; (2) the assessed module balance is a credit and the last transaction (including the return) has been posted 60 or more months.

Revenue Agent.  An IRS employee who works in the field examining tax returns.

Revenue Officer.  An IRS employee who works in the field making personal contact with taxpayers and third parties to collect unpaid, delinquent taxes.

S.
Self-employment Tax.  Social security and Medicare tax paid by self-employed individuals on the net income from their trade or business.

Sham Transaction. A transaction without substance.

Special Agent.  An IRS employee who conducts criminal investigations.

Special Estate Tax Lien. An IRS lien which attaches to the gross estate.

Statutory Limitation Period.  The period provided by law within which an action, such as the assessment or collection of taxes, must be taken.

Statutory Notice of Deficiency (SND).  Also known as a 90-Day Letter or a AStat Notice.@ The SND sets forth the IRS's determination that additional taxes are due. The 90-day limit for filing a petition with the United States Tax Court can not be waived by the IRS or the Tax Court.

Step Transaction Doctrine. A doctrine used by the IRS to collapse multiple transactions into a single transaction for tax purposes.

Substitute for Return ("SFR").  A return prepared by the IRS for a taxpayer who failed to file his or her return.

Suit to Reduce Tax Claim to Judgment.  A lawsuit brought in federal district court by the IRS, through the Department of Justice, Tax Division, or the local U.S. Attorney's office, to extend the collection period where there does not appear to be a present source of collection available. The IRS's right to levy or foreclose the tax lien is not curtailed as a result of reducing the assessment to judgment. IRM § 34.7.5.1 (11-13-96).


T.
Tax Delinquency Investigation (TDI).  When taxpayers fail to file a return reporting income reported by payers, the account falls into delinquent status. An IRS Service Center sends the taxpayer a series of notices requesting the return (e.g., CP515, CP517 & CP518). If the account remains unresolved, it will be forwarded to ACS where a determination is made to forward it for processing under either ASFR or I.R.C. § 6020(b).

Tax Delinquency Account (TDA).  Accounts that are not fully paid after returns are processed, or when additional tax has been assessed, will trigger a series of Computer Paragraph (CP) balance due notices. The first notice requests payment in full. The final notice, CP504, advised the taxpayer a Notice of Federal Tax Lien may be filed, levies may be issued, and other enforced collection measures may be taken.

Tax Period.  The period of time for which a tax return is filed.

Transcript of Account.  An IRS computer print-out of activity in the taxpayer's account, including assessments, payments and extensions of statutory periods limiting assessment.

Transferee.  A taxpayer to whom property is transferred. If the seller owes unpaid taxes, and less than fair market value is paid by the transferee, the transferee may, under certain circumstances, be liable for payment to the IRS of an amount up to the value of the property transferred.

Trust Fund Recovery Penalty.  A penalty assessed, pursuant to Internal Revenue Code ' 6672, against a responsible person in an amount equal to unpaid income and FICA taxes withheld from employees' wages. Also referred to as the 100% penalty.

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