[forensics]

Thank you for digging this up! I am quite familiar with IRC 6201(a)(1) and its corresponding regs at 26 CFR 301.6201-1(1) et seq. However, which “return” are we talking about? The one that was originally “submitted” to but never actually “filed” by the agency (read: no DLN stamped on it), or the SFR that was fabricated by the agency (read: it shows up with a bogus DLN)?

If the agency's IMF record (entity + tax modules) does in fact represent the exclusive, official RECORD, then an SFR can truly be challenged based on its bogus nature. It appears to me that the agency cannot have it both ways. What do you guys (gals) think? B.

[forensics]

QUOTE(Author #5 @ Jan 26 2007, 07:15 PM)

JWR,

You're absolutely right!  Nice job!  Some specifics:

1. You are correct that the current version of the MF Decoder does not decode MFT 55.  The current version is 1.91.

2.  MFT55 is in fact listed in the Year 2003 IRS 6209 manual on p. 4-12.

3.  The next version will have this field decode added based on JWR's astute comments.

Thanks,

[snapback]3496[/snapback]

Thank you for commenting, and the link to the pertinent IRM section! I then cross referenced the penalty sections listed in the IRM against the GPO's “Parallel Table of Authorities” and found that ALL penalty sections listed (except for the penalties under 6662) exclusively relate to 27 CFR regs, thus are not applicable to an MFT=30 module. Since the MFD v1.91 is not going to handle this situation (at this time, anyway) I'll just have to do a separate decoding track for all the MFT=55 transactions. Serviceable, but somewhat messy, though … B.