IRS Tax Notice, Letter 3164A,B,C, DO – IRS Tax Help – Tax Solutions – Former IRS
If you have received a IRS Letter or Notice 3164 call us today to find out more. 1-866-700-1040.
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IRS has the right and ability to find out information from third parties as you will read below. These letters are usually used by IRS Revenue Officers when working a field investigation.
This letters and or notices are used for discovery purposes.
You should actively be contacting the IRS and trying to resolve this tax issue at hand. do not bury your head in the sand. Call us to learn more.
You should be aware that is there is an active investigation and a IRS Agents is currently working the file.
Advance Notification Requirements
There are three versions of Letter 3164 available for use by Collection employees.
Letter 3164 A (DO) for Trust Fund Recovery Penalty (TFRP) investigations.
Letter 3164 B (DO) for balance due investigations.
Letter 3164 C (DO) for delinquent return investigations.
Letter(s) 3164 should not be used for the purpose of initiating taxpayer contacts. Letter(s) 3164 should also not be routinely mailed/hand delivered upon receipt of a new case.
Overview
This IRM provides guidelines on revenue officer contact with third parties in the determination of a tax liability or collection of a tax liability.
The provisions of IRC §6103 and corresponding regulations apply to all third party contacts.
For third party contacts made for the purpose of collecting or determining a tax liability, IRC §7602(c) requires the IRS to:
1. Provide advance notice to the taxpayer that third party contacts may be made,
2. Periodically provide a list of all third party contacts to the taxpayer, and
Provide a list of third party contacts to the taxpayer upon request.
Any tax period under investigation by Criminal Investigation (CI) is not subject to the requirements of IRC §7602(c). A criminal investigation is initiated when an administrative referral based on a firm indication of fraud is made to CI.
Third-party contacts to develop a referral are contacts under IRC §7602(c).
Third Party Contacts
For purposes of IRC §7602(c), a third party contact has been made when an IRS employee initiates contact with a person other than the taxpayer and asks questions about a specific taxpayer with respect to that taxpayer’s Federal tax liability, including the issuance of a levy or summons to someone other than the taxpayer.
Generally, an IRS employee will identify himself or herself when attempting to obtain information from third parties. In situations where an IRS employee attempts to reach a taxpayer by telephone, but instead reaches someone other than the taxpayer:
If the appropriate Letter 3164 or Publication 1 ( Pub 1), Your Rights as a Taxpayer, version dated 05/2005 has been sent and the requisite waiting period has lapsed, the employee may seek additional information.
If the appropriate Letter 3164 or Pub 1 has not been sent and the requisite waiting period has not lapsed, the employee may not seek additional information nor should the employee identify himself or herself unless expressly asked.
IRS Tax Notice, Letter 3164-A B,C DO – IRS Tax Help – Tax Solutions – Former IRS
