File a frivolous

Prepare injunction referral memo and forward case to Counsel for referral to Department of Justice or for advice as to penalty only assessments. If analysis results in determination to seek no injunctive action or penalty assessment, close case advising promoter of no change via Letter , "Discontinuance". Ensure any income derived from promotion is considered including erroneous refunds and income derived from promotional activities. Counsel will forward results of injunctive action including any rejected cases with appropriate penalty instructions.

To apply sanctions on non-compliant preparers, Penalty Policy Statement P directs assertion of preparer penalties only after due deliberation on all facts and circumstances. Individuals who knowingly aid and abet in the understatement of the tax liability for another person may be subject to certain penalties. For purposes of imposing a penalty under IRC Section or , a tax return preparer is any person who prepares for compensation, or who employs one or more persons to prepare for compensation other than for the person all or a substantial portion of any return or any claim for refund of tax.

The preparation of a substantial portion of a return or claim for refund shall be treated as if it were the preparation of such return or claim for refund. All preparer penalty cases prepared by FRP will be coordinated with Associate Area Counsel to determine if the case will be considered for civil injunction, penalty assessment, or no action.

Cases referred for IRC Section penalties are usually those with frivolous filings that are limited in number and in which the preparer has stopped preparing returns. The penalty under IRC Section a must be assessed within 3 years after the return at issue is assessed was filed.

The penalty under IRC b may be assessed at any time. Therefore, if there is six months or more time remaining in the period of assessment for any applicable tax period, refer the case for penalty assessment under both section a and section b.

Refer any case for penalty assessment under section b only, if there is less than six months remaining in the period of assessment. The tax case has bearing on the penalty on the IRC Section case only insofar as assertion of the penalty requires an understatement of tax, or overstatement of credit. A preparer penalty case is not an income tax investigation of the preparer. If there are indications that the preparer is participating in the scheme or is otherwise in need of audit e.

Assess the penalty on the year of the infraction. Case file will contain:. Cases referred for IRC Section penalties are not as common but will be considered when appropriate. Other information: "Explanation of Penalty" - Use information from court injunction or specific explanation from non-enjoined penalty case, e. Form number of return for which penalty is being charged - , X, etc. Instruct the preparer to send a letter requesting Appeals Consideration indicating what they do not agree with and the reasons why they do not agree.

Claims - See IRM Review case for specific processing requirements per IRM Claims may be for abatement or refund and will be worked as follows:. Send C, advising that the preparer has not paid the required 15 percent or provided sufficient documentation to honor the claim.

They are not entitled to judicial review. If valid claims are received and denied, the preparer must then bring suit in Federal District court within 30 days of receiving a Notice of Claim Disallowance or 30 days after the expiration of six months from the filing of the claim, whichever is earlier; if the preparer pays the penalty in full, they may bring a refund suit in either the U.

Court of Federal Claims or a district court within two years of the date of denial of the claim or upon the expiration of six months after the date of filing the claim.

LDC will notify Collections as appropriate, that penalties are being assessed by contacting the ATAT Coordinator for the area where the taxpayer resides. Coordination with both internal and external stakeholders is imperative to ensure a consistent approach to combating frivolous non-compliance.

The nature of tax avoidance has insidious effects. When undetected, improper tax avoidance grows with long-lasting impact on compliance, such as pyramiding non-filing, erroneous refunds, and an impact on IRS resources, including TAS and Appeals involvement.

When erroneous refunds result from unidentified frivolous filings, revenue is lost, but most importantly, the public trust is endangered. Upon initial detection of new frivolous promotions, education throughout the IRS will be undertaken. Coordination will be made with the following stakeholders:.

When processing campuses fail to identify frivolous filings, feedback will be provided through HQ staff to prevent continued misidentification. When erroneous refunds result from failure to identify frivolous filings, coordination will be made with the appropriate processing function to correct procedures.

All potential frivolous arguments must be coordinated with Counsel prior to processing under FRP guidelines. Requests for Counsel opinion will be coordinated with the Technical Coordinator to prevent duplicate requests. Requests will outline the specific frivolous argument involved and must have examples provided to assist Counsel in rendering opinions and must have "Headquarters" authorization.

Provide support for criminal investigations leading to prosecution of frivolous preparers, promoter, and filers. SERP electronic alerts will be issued whenever new frivolous arguments are identified or when existing arguments resurface in significant numbers. The alert process will be used to apprise all employees to watch for filings in order to prevent processing and erroneous refunds. Forward information for alerts to the LDC and include all pertinent information related to the nature of the filing.

Outreach education for internal stakeholders on frivolous arguments is critical and will be given priority. This training will be provided annually to Submission Processing and also made available for all IRS offices.

This endeavor is imperative to stop the proliferation of egregious promotions, ensure timely and accurate tax assessments, avoid erroneous refunds and provide fair and consistent treatment to all taxpayers. Coordination will be undertaken for all affected areas and will encompass IMF and BMF original returns, amended returns and claims processing.

This web page is designed to provide internal customers information on pertinent issues and data associated with Fraud Referrals such as Program point of contacts and Campus FRP Coordinators contact information. Refer to IRM 3. TTs should follow IRM Most questions should be answered during the phone call on the FRP toll-free line. There should be a minimal number of telephone referrals made to TTs working the case. A request for a credit or refund may be allowed based on an informal inquiry, but if the request is denied the taxpayer should be informed that the informal inquiry does not constitute a claim for credit or refund and the informal response does not enable the taxpayer to go to court and contest the rejections.

This informal inquiry should be distinguished from an informal claim for refund which may constitute a filing within the period of limitations for filing a claim for credit or refund. Under the informal "claims" doctrine created by the courts, the information needed to make a formal claim may be substituted after the period of limitations has expired.

When callers inquire about available options regarding penalties, you must provide information regarding a penalty reduction by referencing the IRS.

The search results will provide the caller with access to Form , the instructions and Rev. Proc If the result will be a refund, advise the taxpayer to allow weeks from the received date of the documentation for a refund to be issued.

Do Not provide an electronic payment option. Electronic payments are not available on MFT If not trained on balance due issues, tell the caller you will transfer them to someone who can set up an installment agreement. Transfer the caller to English or Spanish. Follow procedures in IRM Applies to taxpayers that continue to send frivolous correspondence, forms, and filings.

Input a TC responsibility code 4 with a post delay code 1 to reestablish -E freeze to hold future refunds pending FRP review. Advise TP to discontinue sending frivolous information and the consequences that occur in addition to refunds being held. Include supporting case research to substantiate the determination that the refund is to be released.

If frivolous determination can be made, inform the TP of the frivolous issue and advise them to rescind their position follow steps for Disagreed- Unsubstantiated. Requests for abatement will be granted ONLY in cases involving service error. Remind the taxpayer they were sent a Letter C to the address of record. This notice provides a 30 day time frame to provide a valid response. If no response was received, or it was not received within the 30 days, then the frivolous penalty is assessed.

Advise taxpayer that they can submit reasons for abatement request in a letter or by using Form , Request for Penalty Abatement. Please refer to these publications for the most current listing of frivolous arguments. Recognized frivolous arguments include but are not limited to:. Eisner v. McComber - The filer reports wages but deducts them as "non-taxable receipts to reduce some or all income" referencing Eisner v.

McComber U. The individual may alter line items showing non-taxable compensation or non-taxable receipts to back out some or all of their income, generally resulting in a zero tax liability.

Zero Returns ZERO - The filer submits a return with zero money amounts on all or most of the line items on the form, e. See Rev. The filer may include on or attach to a return a statement claiming there is no section of the Internal Revenue Code that established an income tax liability.

The statement may also contain arguments regarding the definition of income. There are several variations on this type of filing such as those bearing the words "nunc pro tunc" and "not liable. To explain the zeros inserted on the form, the individual references U. See United States v Long. The individual may file a Form NR to receive a refund of withheld income tax or claim citizenship of a "State Republic".

Alternatively, the individual may claim that the United States does not include all or part of the physical territory of the 50 States and instead consists of only places such as the District of Columbia, Guam, Puerto Rico, the Virgin Islands, the Northern Marianna Islands, and certain other possessions, enclaves, and trust territories.

The aforementioned does not apply to a foreign person who has paid withholding inadvertently and has filed a claim for a refund. Reparation Tax REPTX - The filer submits a return, an amended return, or correspondence referring to a reparation settlement based on the impact of slavery, or may refer to black taxes, reparations for African Americans, or 40 acres and a mule. Form Deduction F - The filer submits a return showing income then deducts that same amount or a large portion of that amount by adding "Form " to line Form , Foreign Earned Income, is usually attached showing the individual's address in the United States as the foreign address.

The filer also shows his income on Form as "foreign earned income" even though his employers address is also in the United States. Correspondence may be attached arguing the term "income" and stating that each of the several states are foreign countries.

Sixteenth Amendment 16AMEND - The filer argues the Sixteenth Amendment was not properly ratified and therefore the federal government does not have the legal authority to collect an income tax without apportionment.

Generally, the argument focuses on matters such as inconsistencies in versions ratified by the various states. Fifth Amendment 5AMEND - The individual makes an improper blanket assertion of the Fifth Amendment right against self-incrimination as a basis for not providing any financial information.

May include reference to UCC 1— or a statement that the return was not signed under penalties of perjury. The alteration may be located elsewhere on the return with an arrow pointing to the jurat. There may be an explanation on the return or attachments reflecting the desire to negate the effect of the jurat by showing the taxpayer did not intend to file a return in good faith. Unsigned Returns UNSIGN - The filer completes a return but fails to sign and includes a statement explaining why the return is not signed indicating, among other arguments, disagreement with the tax system, IRC a.

The deduction is usually included in the cost of goods sold but could appear under a different deduction category. Various other arguments may be used in the document. The disclaimer states the individual, "disclaims the liability for the tax due" , making the liability on the return zero. This disclaimer may be a part of a return, on a return attachment, or in other documents. For the return to be frivolous the individual must claim frivolous deductions or credits based on an objection to having his or her taxes used to support various government activities.

As a separate position, the individual may argue that other laws or documents prevent the IRS from assessing and collecting tax. Paperwork Reduction Act-Individual argues that they cannot be penalized for failing to file a Form series return because the instructions and regulations associated with the Form do not display an OMB control number.

The individual further argues that since the IRS deposits its revenues in the Federal Reserve Bank, it is a collection agency for the bank, which is in the business of making loans and conducting proprietary business, thereby removing the cloak of governmental immunity. Additionally, they argue the Department of Treasury is part of the United Nations and is clandestinely leading the tax-paying public into a "new world order.

The individual submits a return on which all, or substantially all, of the gross income is claimed as a contribution deduction on the return. The taxpayer will withdraw or rescind their SSN, claiming they are a sovereign citizen.

The taxpayer argues that notes are not valid currency or legal tender and, thus, those who possess them cannot be subject to a tax on them.

This includes indentured servitude arguments and barter offsets. The individual may also argue that the Thirteenth Amendment outlawed slavery.

The taxpayer may claim to be "natural unfranchised individuals and freemen" who are residents of states, and therefore nonresident aliens for the purpose of the Internal Revenue Code. Obscene, Vulgar, Harassing OBSC - The individual submits documents or other materials indicating that non-filing is due to dissatisfaction with tax policies or taxation in general. Often, this argument is expressed with obscene, vulgar, or crude language and characters in an extremely demeaning manner.

Any other position described as frivolous in any revenue ruling or other published guidance in existence when the return or the specified submission adopting the position is filed with the IRS. Taxpayer requests a "lifetime earnings statement" from Social Security Administration in order to list the amount of withheld social security taxes as federal income tax or other payments.

The return also reflects zero money amounts despite indications the taxpayer has taxable income. Based on 26 CFR section 1.

In addition, some employers file amended payroll tax returns and request refunds of previously paid payroll taxes. May also cite IRC section which provides a tax exemption to some employees of international organizations. The World Bank qualifies as an international organization, therefore, if the individual worked for the World Bank as a citizen of another country, they may qualify for the exemption. IRC section , various court cases and revenue rulings allow for tax free income earned either for fishing rights on treaty land, income from the land or on land held in trust for certain individual Native Americans.

The return usually consists of all zeros except withholding and generally a refund is claimed. No further justification for the zero return is given. These taxpayers appear to want the IRS to accept the frivolous return they have filed in place of what they filed previously. IRC - The individual attempts to eliminate tax liability by filing Form X removing all or part of income as an itemized deduction on Schedule A, "Other Miscellaneous Deductions" and citing, "IRC even exchange of property - Labor property - Employer's property.

Butcher's Union Co. Crescent City Co. A statement may be included indicating the taxpayer is rebutting information submitted to the IRS by the payer. Fuel Tax Credit - A filer files a return or claim requesting an amount of fuel tax credit that is so disproportionately excessive to income normally business income reported on the individual's return as to be unallowable.

In addition, the individual's occupation would generally not qualify for off-highway usage. Form OID - Individual or business files a return reporting false amounts of income generally "Other" or "Miscellaneous" income and claims a false amount of income tax withholding approximately equal to the amount of falsely reported income. Although the return reports income, the taxpayer does not calculate any tax due. Other false financial instruments may be filed in the place of or in addition to the Series Form s such as Form , promissory notes, bonds, sight drafts, etc.

Individual files a return containing the filer's identifying information but does not request a refund, often lacking sufficient information to determine a tax liability. Individual files a return that attempts to send some type of message or protest to the IRS but fails to include sufficient identifying information for the IRS to determine the identity of the taxpayer or the taxpayer's return address.

Prisoner Filings - Individual who is incarcerated files a return with which they include a Substitute Form W-2 Form In the explanation portion of the Form they explain the income is based on a computation of minimum wage for hours worked within the prisons and lists an amount of withholding which allegedly represents the withholding an employer would withhold from an employee working at minimum wage.

The inmate claims a refund based on the data for income and withholding the prisoner alleges the prison should have reported. The claims also may include a list that includes a work log or a computer printout showing their cost of incarceration. Non Taxable Social Security SS Benefits - Individual files a return reflecting non-taxable SS, or Railroad Retirement benefits and claims false or excessive withholding credit resulting in a zero return. FRP Master is a composite of several tables linked together to allow FRP employees to accurately respond to taxpayers and assists in trending frivolous filings for outreach education to internal and external stakeholders.

It also provides the means to identify new abusive tax avoidance promotions in order to make referrals for civil injunctive actions, criminal investigations, and follow-up monitoring on violations of existing court orders on abusive promoters and preparers. The tables include but are not limited to:. Friv Input Form - Table used to update taxpayer compliance history, forms and letter sent to taxpayers, pre-audit compliance, frivolous arguments used by the taxpayer, etc.

TAR Form - Used to elevate unique technical questions, data on new promotions, etc. Utilize FRP Master to ensure a record is made of all pertinent actions taken on accounts. Consider existing information derived from FRP Master Project Status Listing prior to taking action on existing accounts such as whether:. Home IRM Part25 Part Special Topics Chapter Revenue Protection Section Frivolous Return Program. Program Scope and Objectives. Refer to the following: IRM 1.

Roles and Responsibilities. Program receipts will be reviewed for frivolous criteria and either selected or cleared as follows: If not frivolous, stamp the upper left corner, "FRP cleared" , and include the last five digits of IDRS number and return to processing. Program Management and Review.

Program Controls. The Frivolous Return Program FRP is responsible for: Reviewing, asserting, and monitoring all frivolous penalties, and penalty reduction procedures Controlling inventory related to frivolous returns, frivolous submissions, and correspondence Referring preparer penalty related to frivolous filings. Related Resources. Identification of Frivolous Submissions.

Frivolous returns often: Contain on the face of the tax return or on attachments to the tax return arguments about the obligation to file or pay tax. Include altered forms or jurats containing frivolous arguments. Note: The section penalty should not be assessed against a taxpayer who encloses with, or attaches to, an otherwise accurate and complete tax return, documents articulating frivolous arguments. ARG 2 - Eisner v. Altered jurats, rewording or crossing off parts of the jurat, statements such as "signed under duress," and "all rights reserved," Irregular entities such as: name of taxpayer in all lower-case letters, addresses such as "Territory of state " or address in all lower- or upper-case letters, Reduces or eliminates tax liability without valid justification, and reports Improper credits, deductions, or exclusions.

Referrals to Frivolous Return Program. Send referrals via Form to: Note: If the frivolous document contains valid inquiries such as Freedom of Information Act FOIA requests, transcript requests, or taxpayer advocate issues, it should be forwarded to the appropriate function prior to transshipping to Ogden, FRP.

Internal Revenue Service. Rulon White Blvd. Original return as received including any attachments or a copy of the original. Note: Do Not close case or transfer controls in order to transship cases. Note: Appeals Letter dates are required to complete penalty assessment actions. Reminder: Incomplete packages will be returned to the generating function.

Screening Correspondence. Reminder: All incoming paper documents must be stamped with the FRP received date. Frivolous Correspondence. Note: Correspondence that purports to be "in lieu of" a tax return or informal refund claims are subject to the IRC penalty.

Exception: Correspondence receipts that meet automation criteria will be added to the appropriate automation spreadsheet for case controlling purposes. Reminder: If correspondence will be used to document civil or criminal fraud, Do Not Destroy. Note: The table below is not all inclusive. Note: Follow regular FRP processing procedures after scanning.

Note: Router will specify the reason for referral and FRP criteria identified. Scan into FRP Master. Route to FRP Analyst. Route to assigned Tax Technician to associate with case. Route to Collection Miscellaneous Department. Note: Detach any non-frivolous forms from frivolous correspondence to be routed through non-frivolous correspondence. Reminder: Although frivolous correspondence is excluded from Policy Statement P criteria, every attempt will be made to respond within 30 days of the IRS received date.

Note: Systemic issuance of Letter C, may be conducted as deemed appropriate. Non-Frivolous Correspondence. Exception: Correspondence receipts that meet automation criteria will be added to the appropriate automation spreadsheet for case controlling purposes and controls and database input must be completed within 14 days of receipt. Input and scan to FRP Master using the appropriate action code, within 3 days of receipt.

Route to TT Team for processing. Route to Audit Reconsideration Team. Route as appropriate following mail routing guide procedures. Input and scan to FRP Master using the appropriate action code. Undeliverable FRP Mail. Reminder: Notate undeliverables with "unclaimed" or "refused". Screening Returns and Claims.

Note: Pursuant to a recent Tax Court opinion, we must obtain written supervisory approval of a civil penalty, including section , before assessing a penalty. Note: BMF returns require expedite handling 2 business days to avoid interest on legitimate refunds. Reminder: All incoming documents must be stamped with the FRP received date. Reminder: Under IRC , a return must refer to a frivolous position or reflect a clear indication of a desire to delay or impede the administration of tax laws.

Update training materials and Internal Revenue Manuals. Handling of Returns and Claims. Note: BMF returns require expedited handling 2 business days to avoid interest on legitimate refunds.

Note: Refer to table below for additional information regarding specific freeze codes. Note: See IRM Note: Refer to IRM Exception: If a C letter has been sent within the last 12 months for the same tax period or with an on-going FRP involvement, select the appropriate FRP Master action code to ensure pre-notification is not reissued to the taxpayer.

Note: Systemic issuance of Letter C may be conducted, as deemed appropriate. If And Then Frivolous Return invalid for processing purposes Issue C letter with 12C Paragraphs and any other applicable paragraphs to outline the frivolous behavior that needs to be corrected.

Review disaster specific memo information to determine established suspense time frames. Caution: Do not assess tax or penalties on impacted accounts until after the suspense time of the notice expires letter must be issued after disaster suspense lifted unless , exigent circumstances apply.

Example: Exigent circumstances include circumstances involving the loss of opportunity for the government to collect taxes due, such as the expiration of the statute of limitations or assets being placed beyond the reach of the government.

Note: Research IDRS for case controls, freezes and histories to determine if fraud case is in development. Secure permission from CI to work or route as directed below. Note: If there is a bearing on the penalty, follow open issue above. Release any FRP freezes. Route using the Mail Routing Guide. Note: If altered jurat is an issue, make sure that taxpayer was afforded the opportunity to properly sign the return using Letter 12C.

Note: In June , the C letter was modified to include specific criteria for three letter iterations including altered jurat. Employee Frivolous Filings. C-Filed Returns that are not subject to the IRC a Penalty based upon a Counsel opinion or a subsequent filing within the same tax period will close with "subsequent C-File" Initial C-Filed Return subject to IRC a will close with "C-File" Note: Verify at least one penalty assessment is applied for the return tax period prior to selecting subsequent C-file as your action code if applicable.

Identity Theft Screening. The following subsection contains procedures for screening identity theft on IMF Returns. Release any FRP freeze condition. Follow normal frivolous return procedures. Editing Return Instructions. Current year IMF returns requiring processing will be edited as follows: Exception: Edit prior year returns with tax year underlined in red and the line item numbers must be corrected to match current filing year returns.

Note: This code freezes refunds. Note: This code indicates the return is blank or contains all zeros or insignificant entries other than entity information. Note: This code forces the return to post and bypass certain error checks. Note: This code causes the return to reject for further handling.

Editing Amended or Converted Returns. Reminder: Do Not verify. Enter all data as listed except the false Form amount. Case Processing Overview. Process cases as follows: Ensure all taxpayer issues are addressed as appropriate. Ensure any taxpayer responses are associated and considered prior to determining next action. Note: See IRM 4. Note: Note: Prior to preparing Letter C, complete research to identify the argument code category, and expected response type for the tax period in question.

Note: Unprocessable returns pulled into treatment must afford the filer the opportunity to provide the necessary information to process. Civil Fraud. Identity Theft Processing.

Abate any penalty assessments related to identity theft filings. Remove all FRP Master issues tied to identity theft filings. Caution: Careful consideration needs to be used in making determinations on Form or other claims of identity theft from SSN owners when it appears the claim is invalid, or the individuals do not appear to be victims.

Control of Inventory. Note: During periods of high volume, adjustments to inventory control time frames will be coordinated and adjusted by management and HQ as needed. Note: Multiple FRP Acton Control Categories have been established to segment FRP treatment streams and any new or updated controls must contain all necessary field updates to ensure accurate inventory counts.

Conducting Compliance Checks. Note: Compliance Checks are to be conducted when an erroneous refund, offset, or transfer is identified in IDRS research and on specific arguments as specified by HQ. Note: Frivolous argument 44 and 46 are currently designated by HQ for required compliance checks. Some indicators for potentially processed frivolous returns are: TC for.

Note: Do not ESTAB for returns if there is a subsequent TC or TC with the appropriate amount assessed or the statute for assessment has expired or will expire within 1 year, unless tax can be assessed using one of the exceptions by IRC e. Scheme return. Input to FRP Master. Initiate FRP case processing. Release FRP controls and freezes. Scheme CIS return.

Complete a history item. Suspend the case. Monitor for 30 days. If the return is not received, make a second request:. Suspend the case Monitor for 45 days If the return is not received, do a "special search:". Exception: If you have a high dollar case, take to your manager for a determination.

Fraud Penalty Returns. Note: Per IRC c 1 , effective August 15, , do not make any contact with a third party until the 46th day following the date of Letter Area Office Procedures.

If the compliance check reveals case meets criteria for deficiency potential for area office examination, process as follows: Continue frivolous filing procedures, pre-notify and assess penalty using IRM Statute of limitation on original returns will be determined as follows: Processable frivolous return filings may be valid returns and begin the assessment statute of limitations under IRC Follow the chart below for processing Statute Expired accounts.

Note: If non-processable return was processed in error, seek Counsel opinion for reversal of filing. Notate return with "Considered in FRP" in lower left margin of the front of the return. Close all RIVO control bases. Update FRP Master as required. Note: If the taxpayer later provides sufficient documentation to support the claim, move the overpayment back to the account from Excess Collections using Form and allow the refund to be issued.

Processing of Responses. Responses to Frivolous Return letters should be processed using the table below. Note: Responses to amended returns or subsequent filings will follow IRM Note: Any account impacted by a disaster that contains an O or S freeze requires additional considerations prior to assessment.

Assess penalty on both frivolous returns. Update FRP Master. Do not assess the frivolous return penalty. Verify taxpayer filed a correct and accurate return. Update FRP Master and ensure revenue protection is recorded. Close all FRP case controls. Note: Ensure an extension was not granted before processing as a late response. Ensure that neither return is processable.

Note: If either return is processable follow directions in box 3 above Input precautionary freeze codes to prevent erroneous refunds. Note: Claim disallowance procedures do not apply to processed frivolous returns.

Do Not assess a penalty. Note: Include open paragraph: "We received your response to Letter that includes your intent to rescind the frivolous position. Form Referrals. Refer return to clerical team as shown below.

Reverse -E and -R freezes if present on the module. Electronically filed return: print to. Paper filed return: print to. Processing Amended Returns and Claims. Frivolous Return Penalties Overview. Reminder: A claim does not need a signature to be frivolous. Note: Assess the penalty on a photocopy of an initial return only if the initial return has been lost and the taxpayer provides a copy of that return.

Penalty Case Creation. Note: Ensure an extension was not granted before processing response as untimely. Note: If assessing more than one tax period, fill out a separate Form for each tax period. Penalty Assessment. The motion to reopen was thus denied. O-1 visas are for persons of extraordinary ability in the sciences, arts, education, business or sports. Administered by the Department of State, the J-1 visa is for students, trainees, academics, researchers, professionals or experts participating in an approved Exchange Visitor program.

E-1 visas and E-2 visas are for nationals of countries with which the United States has a treaty of friendship, commerce and navigation FCN or bilateral investment treaty BIT.

If you are a nonimmigrant trader or investor seeking to conduct business operations or develop a new enterprise in the U. As a recognized expert in this area, Mr. Levin will provide experienced and dependable assistance with E-1 or E-2 visa applications. The L-1 visa category is for executives, managers or professionals employed by foreign affiliates of U. S companies. On This Page.

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