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FIND THE EXPLANATION

A tax notice arrived: choose the response that fits

Identify the tax, period, and notice before choosing between disputing the amount, arranging payment, or requesting hardship relief.

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If you came here to check a specific citation, open the original archive below. It includes its source dates and recorded qualifications.

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The explanation above is written for readers. These original working documents preserve the evidence trail, including technical language, dated passages and known corrections. They have not all received independent professional review. Use the marked limits before relying on a particular rule or figure.

DETAILED RESEARCH · EVIDENCE & LIMITS INCLUDED

Tax-debt research: federal primary-source recovery

D014 · source-02Captured 2026-10-254 tables · 11 claim records · 12 source recordsScoped coordinator review completed

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

D014 SOURCE-02 — Federal primary-source recovery

Baseline: October 22, 2026, America/Los_Angeles Check date: October 22, 2026, unless otherwise stated Route: Same regular Chat, GPT-6; no Deep Research Scope: Eight specified original source rows, plus documented reuse of S002/S003/S011.

The original IDs remain unchanged. New D014-FS-S### identifiers distinguish individual authorities and supporting passages without overwriting the historical register.

The initial retrieval confirmed exact OLRC statutory endpoints for §§ 6320, 6330, 6343, 6159, 6502 and 7122. The eCFR § 1.1017-1 page was accessible; the first attempts to retrieve §§ 1.108-7 and 301.7122-1 failed. Those failures are not treated as evidence that the regulations are unavailable or repealed.

The OLRC pages identify statutory text in effect through Public Law 119-120 (October 7, 2026). The accessible eCFR page identifies Title 26 as current through October 19, 2026. These are source currency statements, not enactment or effective dates for each individual rule. uscode.house.gov+2

1. Corrected source register

Version convention: OLRC = Title 26 text through Public Law 119-120, October 7, 2026. eCFR = electronically maintained regulation, authoritative but unofficial. IRS guidance = agency explanation, not a substitute for statute or regulation.

All newly opened rows below were checked October 22, 2026. No historical source record is overwritten.

Retained ID / new sub-ID Primary authority, direct literal URL Passage read and evidence Access / disposition
S010 / FS-S001 Treasury, 26 CFR § 1.108-7. https://www.ecfr.gov/current/title-26/section-1.108-7 Tax-attribute reduction; requested section endpoint returned an access error Unresolved — no claim of passage verification
S010 / FS-S002 Treasury, 26 CFR § 1.1017-1. https://www.ecfr.gov/current/title-26/section-1.1017-1 § 1.1017-1(a), (b)(1)–(2): basis-reduction ordering, preceding attribute reductions and allocation among multiple discharged debts Opened/read; eCFR displayed current through October 19, 2026 ecfr.gov
S012 / FS-S003 OLRC, 26 USC § 6320. https://uscode.house.gov/us/usc/119-118/t26/s6320/ § 6320(a)(1)–(3), (b), (c): written NFTL notice, delivery methods, five-business-day period, hearing request and coordination with § 6330 Opened/read uscode.house.gov
S013 / FS-S004 OLRC, 26 USC § 6330. https://uscode.house.gov/us/usc/119-118/t26/s6330/ § 6330(a)–(d): pre-levy notice, hearing rights, permissible issues, Tax Court review Opened/read uscode.house.gov+1
S014 / FS-S005 OLRC, 26 USC § 6343. https://uscode.house.gov/us/usc/119-118/t26/s6343/ § 6343(a)(1)(A)–(E), (a)(2)–(3), (b): mandatory release grounds, essential business property, subsequent levy and return of property Opened/read uscode.house.gov
S015 / FS-S006 OLRC, 26 USC § 6159. https://uscode.house.gov/us/usc/119-118/t26/s6159/ § 6159(a)–(e): agreements, modification/termination, guaranteed agreements, partial-payment review, administrative review Opened/read uscode.house.gov
S016 / FS-S007 OLRC, 26 USC § 6502. https://uscode.house.gov/us/usc/119-118/t26/s6502/ § 6502(a)(1)–(2), (b): ten-year baseline, specified agreed periods, court proceedings and levy date Opened/read uscode.house.gov
S017 / FS-S008 OLRC, 26 USC § 7122. https://uscode.house.gov/us/usc/119-118/t26/s7122/ § 7122(a)–(c): compromise authority, submission payments, payment application and exceptions Opened/read uscode.house.gov+1
S017 / FS-S009 Treasury, 26 CFR § 301.7122-1. https://www.ecfr.gov/current/title-26/section-301.7122-1 Regulatory definitions of DATL, DATC and ETA sought; direct retrieval failed Unresolved — exact endpoint identified, operative passage not independently read
S022 / FS-S010 IRS, Failure to Pay Penalty. https://www.irs.gov/payments/failure-to-pay-penalty Calculation sections: 0.5% ordinary monthly rate, 25% ceiling, concurrency, conditional 0.25% and 1% rates, relief Opened/read Internal Revenue Service
S022 / FS-S011 IRS, Failure to File Penalty. https://www.irs.gov/payments/failure-to-file-penalty Individuals/most businesses, partnership distinction, monthly rates, concurrency, return-due-date minimums Opened/read Internal Revenue Service
S022 / FS-S012 IRS, Failure to Deposit Penalty. https://www.irs.gov/payments/failure-to-deposit-penalty Official penalty page opened; complete rate tiers and deposit-period applicability not yet extracted and reconciled Partial Internal Revenue Service

Coordinator-verified evidence reuse — no new-opening claim

Original source Direct URL and pinpoint Original claim Check provenance
D014-S002 https://uscode.house.gov/us/usc/119-118/t26/s61/ — § 61(a)(11) D014-C030: discharge-of-indebtedness gross-income category, subject to exceptions Coordinator opened/read October 22, 2026, 23:25:30 UTC
D014-S003 https://uscode.house.gov/us/usc/119-118/t26/s6050P/ — § 6050P(a)–(c) D014-C031: applicable-entity $600 information-reporting threshold, distinct from substantive taxable income Same coordinator check
D014-S011 https://uscode.house.gov/us/usc/119-118/t26/s6321/ — § 6321 D014-C001: statutory tax-lien attachment framework Same coordinator pass; reused D028 passage check

The coordinator's exact timestamp is 2026-10-22T23:25:30.042416+00:00. This evidence was supplied in the request; it was not newly opened during SOURCE-02.

These three reused checks do not establish cancellation timing, complete reporting regulations, lien priority, third-party property rights or all related exceptions.

2. Material claim and mapping replacements

The following are new supplemental claims, not renumberings of original claims. Original claims outside the supplied mappings remain unchanged and unreviewed.

New claim ID Source / area Supported replacement finding and limitations
D014-FS-C001 S010 / FS-S002; A067 Under § 1.1017-1(a), specified excluded COD income reduces property bases in an ordered sequence, generally using property held on the first day of the following taxable year. § 1.1017-1(b)(1) requires accounting for preceding attribute reductions. This does not independently establish the full § 108 exclusion or attribute-reduction calculation.
D014-FS-C002 S012 / FS-S003; A019 § 6320(a)(2) requires NFTL notice within five business days after filing. § 6320(a)(3)(B) establishes a separate 30-day hearing-request window beginning the day after that five-day period. Do not calculate an actual deadline without filing and calendar facts.
D014-FS-C003 S013 / FS-S004; A019 § 6330(a) generally requires notice at least 30 days before the first levy for the specified tax period. §§ 6330(c), (d), (e) and (f) govern hearing issues, review, suspension and exceptions. The 30-day Tax Court petition period runs from the determination, not the original levy notice. uscode.house.gov+1
D014-FS-C004 S014 / FS-S005; A019 § 6343(a)(1) requires levy release when enumerated conditions are met, including determined economic hardship. An installment agreement does not guarantee release where the statutory exceptions apply. Release does not necessarily bar a subsequent levy.
D014-FS-C005 S015 / FS-S006; A019 § 6159(c) requires an agreement for qualifying individual Subtitle A liabilities of no more than $10,000 excluding specified additions, subject to five-year compliance history, inability to pay immediately, full payment within three years and continuing compliance. This is not a general $10,000 business-tax guarantee.
D014-FS-C006 S015 / FS-S006; A019 § 6159(b) permits modification or termination on specified grounds; ordinarily the statute requires 30 days' advance explanatory notice, subject to jeopardy exception. § 6159(d) requires partial-payment agreement review at least every two years.
D014-FS-C007 S016 / FS-S007; A019 § 6502(a) establishes a general ten-year period after assessment for timely levy or commencement of court proceedings, with stated exceptions. Actual CSED requires assessment-specific suspension, extension and proceeding analysis; ten years cannot simply be added to a tax-return due date.
D014-FS-C008 S017 / FS-S008; A019 § 7122(a) authorizes compromises; § 7122(c) prescribes submission-payment rules and exceptions, including the statutory individual low-income exception. § 7122(f) includes a 24-month deemed-acceptance provision subject to judicial-dispute tolling. A submitted offer is not automatically accepted. uscode.house.gov
D014-FS-C009 S022 / FS-S010–S011; A019 IRS guidance distinguishes failure-to-file from failure-to-pay penalties. For applicable returns, concurrent monthly penalties reduce the filing component by the payment component. The ordinary rates cannot simply be added as independent 5% and 0.5% charges for the same month.
D014-FS-C010 S022 / FS-S011; A019 The IRS identifies a $525 minimum failure-to-file penalty for the listed Forms 1040/1120 where the return due date without extension is after December 31, 2025, the return is more than 60 days late, and the statutory lesser-of limitation applies. Other return types have different rules.
D014-FS-C011 S022 / FS-S012; A019 IRS guidance gives failure-to-deposit tiers of 2% for 1–5 calendar days late, 5% for 6–15 days, 10% after 15 days, and a conditional 15% notice-triggered tier. These tiers replace rather than accumulate with one another. Actual liability depends on deposit obligations and relief. Internal Revenue Service

Penalty concurrency — corrected illustrative calculation

For an otherwise applicable individual income-tax return, assume $10,000 of unpaid tax, one overlapping month, ordinary failure-to-file and failure-to-pay rates, and no relief or special-rate adjustment.

Plain text

Unpaid tax = $10,000

Ordinary monthly failure-to-file rate = 5%
Ordinary monthly failure-to-pay rate = 0.5%

Failure-to-pay component
= $10,000 × 0.005
= $50

Reduced failure-to-file rate
= 5% - 0.5%
= 4.5%

Failure-to-file component
= $10,000 × 0.045
= $450

Combined monthly penalties
= $450 + $50
= $500

This is an illustration of the concurrency rule, not a tax-account estimate. Filing extensions, return classifications, reasonable cause, minimum penalties, rate changes and the actual number of chargeable months can change the result. Internal Revenue Service+1

3. Granular source/authority coverage

Original source / subrow Status Resolved evidence Residual hold and exact next action
S010 / FS-S001 Unresolved Exact § 1.108-7 endpoint identified, fetch failed Retrieve current regulation from eCFR or official CFR and read all operative attribute-order, reduction and effective-date provisions
S010 / FS-S002 Answered for named passages § 1.1017-1(a), (b)(1)–(2) read Verify remaining paragraphs, elections and property-specific limits before a complete COD calculator
S012 / FS-S003 Answered for statutory framework § 6320 notice and hearing provisions read Verify CDP regulations, mailing facts, service and calendar before computing deadlines
S013 / FS-S004 Answered for statutory framework § 6330(a)–(f) read Check procedural regulations and exception-specific applicability
S014 / FS-S005 Answered for enumerated release grounds § 6343(a), (b) read Verify regulatory hardship test, levy status and wrongful-levy remedies
S015 / FS-S006 Answered for cited statutory provisions § 6159(a)–(e) read Verify applicable regulations, agreement category, fees and actual case eligibility
S016 / FS-S007 Partial Ten-year baseline and § 6502 exceptions read Read relevant § 6503 suspension provisions and reconstruct CSED event history
S017 / FS-S008 Answered for statute § 7122(a)–(f) read Verify regulatory grounds and process against § 301.7122-1
S017 / FS-S009 Unresolved Regulation endpoint identified, retrieval failed Open operative regulation, confirm DATL/DATC/ETA definitions, exceptions and effective text
S022 / FS-S010 Partial IRS failure-to-pay calculations and concurrency read Read § 6651 and § 301.6651-1 for controlling scope and exceptions
S022 / FS-S011 Partial IRS filing-penalty rates, return categories and minimums read Verify § 6651, inflation adjustment and specific return/year
S022 / FS-S012 Partial IRS deposit tiers, noncumulative treatment and relief read Read § 6656 and applicable employment-tax deposit regulations; validate deposit schedule and notice facts

Coverage result: The eight original source identities are now associated with exact federal URLs. Six statutory source rows have opened operative text; S010 and S017 remain incomplete because one regulatory component of each was not successfully retrieved. S022 has three opened IRS guidance pages, but its complete controlling statutory and regulatory chain remains unfinished.

4. Remaining publication holds

These source repairs do not clear either parent area.

  • Federal procedural holds: Actual CDP deadlines, mailing/service disputes, CSED calculations, hardship determinations, agreement eligibility, OIC acceptance and procedural exceptions require additional regulations or transaction facts.
  • COD holds: § 1.108-7 remains unopened; bankruptcy, insolvency, tax attributes, entity classifications, joint liability, foreclosure/repossessions, state conformity and tax-year transitions remain subject to their original holds.
  • Penalty holds: IRS guidance establishes the described rates, but full § 6651/§ 6656 controlling-law reconciliation, return-type distinctions, relief and year-specific adjustments are not complete.
  • Original-report holds: No acceptance of all 50 original claims, 40 original sources, worked examples or A019/A067 overall. Unreviewed original claims retain their previous status.
  • Nonfederal/contract holds: State, local and tribal taxes, actual creditor agreements, guaranties and other contract-dependent questions are outside SOURCE-02 and remain unverified.

5. Researcher self-check

Newly opened and read: Six OLRC statutory sections, one accessible eCFR regulation, and three IRS penalty guidance pages, all in the October 22, 2026 check session. The statutory and regulatory version information and exact direct URLs appear above.

Attempted but not successfully read: 26 CFR §§ 1.108-7 and 301.7122-1. No operative regulatory claim is certified from those failed retrievals.

Reused, not reopened: S002, S003 and S011, based on the coordinator's supplied October 22 UTC primary-text check and its explicitly limited findings.

Not performed: Independent audit of the parent report, complete verification of original claim mappings, account-specific deadline calculations, nonfederal research, private-data access, publication, file saving, external contact or account changes.

This is a focused researcher evidence check, not an independent review or acceptance of D014.

END D014 SOURCE-02

Every captured table

Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

Captured table 01

Original headerless table; first data row retained · 13 data rows

Retained ID / new sub-IDPrimary authority, direct literal URLPassage read and evidenceAccess / disposition
S010 / FS-S001Treasury, 26 CFR § 1.108-7. https://www.ecfr.gov/current/title-26/section-1.108-7Tax-attribute reduction; requested section endpoint returned an access errorUnresolved — no claim of passage verification
S010 / FS-S002Treasury, 26 CFR § 1.1017-1. https://www.ecfr.gov/current/title-26/section-1.1017-1§ 1.1017-1(a), (b)(1)–(2): basis-reduction ordering, preceding attribute reductions and allocation among multiple discharged debtsOpened/read; eCFR displayed current through October 19, 2026 ecfr.gov
S012 / FS-S003OLRC, 26 USC § 6320. https://uscode.house.gov/us/usc/119-118/t26/s6320/§ 6320(a)(1)–(3), (b), (c): written NFTL notice, delivery methods, five-business-day period, hearing request and coordination with § 6330Opened/read uscode.house.gov
S013 / FS-S004OLRC, 26 USC § 6330. https://uscode.house.gov/us/usc/119-118/t26/s6330/§ 6330(a)–(d): pre-levy notice, hearing rights, permissible issues, Tax Court reviewOpened/read uscode.house.gov +1
S014 / FS-S005OLRC, 26 USC § 6343. https://uscode.house.gov/us/usc/119-118/t26/s6343/§ 6343(a)(1)(A)–(E), (a)(2)–(3), (b): mandatory release grounds, essential business property, subsequent levy and return of propertyOpened/read uscode.house.gov
S015 / FS-S006OLRC, 26 USC § 6159. https://uscode.house.gov/us/usc/119-118/t26/s6159/§ 6159(a)–(e): agreements, modification/termination, guaranteed agreements, partial-payment review, administrative reviewOpened/read uscode.house.gov
S016 / FS-S007OLRC, 26 USC § 6502. https://uscode.house.gov/us/usc/119-118/t26/s6502/§ 6502(a)(1)–(2), (b): ten-year baseline, specified agreed periods, court proceedings and levy dateOpened/read uscode.house.gov
S017 / FS-S008OLRC, 26 USC § 7122. https://uscode.house.gov/us/usc/119-118/t26/s7122/§ 7122(a)–(c): compromise authority, submission payments, payment application and exceptionsOpened/read uscode.house.gov +1
S017 / FS-S009Treasury, 26 CFR § 301.7122-1. https://www.ecfr.gov/current/title-26/section-301.7122-1Regulatory definitions of DATL, DATC and ETA sought; direct retrieval failedUnresolved — exact endpoint identified, operative passage not independently read
S022 / FS-S010IRS, Failure to Pay Penalty. https://www.irs.gov/payments/failure-to-pay-penaltyCalculation sections: 0.5% ordinary monthly rate, 25% ceiling, concurrency, conditional 0.25% and 1% rates, reliefOpened/read Internal Revenue Service
S022 / FS-S011IRS, Failure to File Penalty. https://www.irs.gov/payments/failure-to-file-penaltyIndividuals/most businesses, partnership distinction, monthly rates, concurrency, return-due-date minimumsOpened/read Internal Revenue Service
S022 / FS-S012IRS, Failure to Deposit Penalty. https://www.irs.gov/payments/failure-to-deposit-penaltyOfficial penalty page opened; complete rate tiers and deposit-period applicability not yet extracted and reconciledPartial Internal Revenue Service
Source links captured in this table

Captured table 02

Original headerless table; first data row retained · 4 data rows

Original sourceDirect URL and pinpointOriginal claimCheck provenance
D014-S002https://uscode.house.gov/us/usc/119-118/t26/s61/ — § 61(a)(11)D014-C030: discharge-of-indebtedness gross-income category, subject to exceptionsCoordinator opened/read October 22, 2026, 23:25:30 UTC
D014-S003https://uscode.house.gov/us/usc/119-118/t26/s6050P/ — § 6050P(a)–(c)D014-C031: applicable-entity $600 information-reporting threshold, distinct from substantive taxable incomeSame coordinator check
D014-S011https://uscode.house.gov/us/usc/119-118/t26/s6321/ — § 6321D014-C001: statutory tax-lien attachment frameworkSame coordinator pass; reused D028 passage check
Source links captured in this table

Captured table 03

Original headerless table; first data row retained · 12 data rows

New claim IDSource / areaSupported replacement finding and limitations
D014-FS-C001S010 / FS-S002; A067Under § 1.1017-1(a), specified excluded COD income reduces property bases in an ordered sequence, generally using property held on the first day of the following taxable year. § 1.1017-1(b)(1) requires accounting for preceding attribute reductions. This does not independently establish the full § 108 exclusion or attribute-reduction calculation.
D014-FS-C002S012 / FS-S003; A019§ 6320(a)(2) requires NFTL notice within five business days after filing. § 6320(a)(3)(B) establishes a separate 30-day hearing-request window beginning the day after that five-day period. Do not calculate an actual deadline without filing and calendar facts.
D014-FS-C003S013 / FS-S004; A019§ 6330(a) generally requires notice at least 30 days before the first levy for the specified tax period. §§ 6330(c), (d), (e) and (f) govern hearing issues, review, suspension and exceptions. The 30-day Tax Court petition period runs from the determination, not the original levy notice. uscode.house.gov +1
D014-FS-C004S014 / FS-S005; A019§ 6343(a)(1) requires levy release when enumerated conditions are met, including determined economic hardship. An installment agreement does not guarantee release where the statutory exceptions apply. Release does not necessarily bar a subsequent levy.
D014-FS-C005S015 / FS-S006; A019§ 6159(c) requires an agreement for qualifying individual Subtitle A liabilities of no more than $10,000 excluding specified additions, subject to five-year compliance history, inability to pay immediately, full payment within three years and continuing compliance. This is not a general $10,000 business-tax guarantee.
D014-FS-C006S015 / FS-S006; A019§ 6159(b) permits modification or termination on specified grounds; ordinarily the statute requires 30 days' advance explanatory notice, subject to jeopardy exception. § 6159(d) requires partial-payment agreement review at least every two years.
D014-FS-C007S016 / FS-S007; A019§ 6502(a) establishes a general ten-year period after assessment for timely levy or commencement of court proceedings, with stated exceptions. Actual CSED requires assessment-specific suspension, extension and proceeding analysis; ten years cannot simply be added to a tax-return due date.
D014-FS-C008S017 / FS-S008; A019§ 7122(a) authorizes compromises; § 7122(c) prescribes submission-payment rules and exceptions, including the statutory individual low-income exception. § 7122(f) includes a 24-month deemed-acceptance provision subject to judicial-dispute tolling. A submitted offer is not automatically accepted. uscode.house.gov
D014-FS-C009S022 / FS-S010–S011; A019IRS guidance distinguishes failure-to-file from failure-to-pay penalties. For applicable returns, concurrent monthly penalties reduce the filing component by the payment component. The ordinary rates cannot simply be added as independent 5% and 0.5% charges for the same month.
D014-FS-C010S022 / FS-S011; A019The IRS identifies a $525 minimum failure-to-file penalty for the listed Forms 1040/1120 where the return due date without extension is after December 31, 2025, the return is more than 60 days late, and the statutory lesser-of limitation applies. Other return types have different rules.
D014-FS-C011S022 / FS-S012; A019IRS guidance gives failure-to-deposit tiers of 2% for 1–5 calendar days late, 5% for 6–15 days, 10% after 15 days, and a conditional 15% notice-triggered tier. These tiers replace rather than accumulate with one another. Actual liability depends on deposit obligations and relief. Internal Revenue Service

Captured table 04

Original headerless table; first data row retained · 13 data rows

Original source / subrowStatusResolved evidenceResidual hold and exact next action
S010 / FS-S001UnresolvedExact § 1.108-7 endpoint identified, fetch failedRetrieve current regulation from eCFR or official CFR and read all operative attribute-order, reduction and effective-date provisions
S010 / FS-S002Answered for named passages§ 1.1017-1(a), (b)(1)–(2) readVerify remaining paragraphs, elections and property-specific limits before a complete COD calculator
S012 / FS-S003Answered for statutory framework§ 6320 notice and hearing provisions readVerify CDP regulations, mailing facts, service and calendar before computing deadlines
S013 / FS-S004Answered for statutory framework§ 6330(a)–(f) readCheck procedural regulations and exception-specific applicability
S014 / FS-S005Answered for enumerated release grounds§ 6343(a), (b) readVerify regulatory hardship test, levy status and wrongful-levy remedies
S015 / FS-S006Answered for cited statutory provisions§ 6159(a)–(e) readVerify applicable regulations, agreement category, fees and actual case eligibility
S016 / FS-S007PartialTen-year baseline and § 6502 exceptions readRead relevant § 6503 suspension provisions and reconstruct CSED event history
S017 / FS-S008Answered for statute§ 7122(a)–(f) readVerify regulatory grounds and process against § 301.7122-1
S017 / FS-S009UnresolvedRegulation endpoint identified, retrieval failedOpen operative regulation, confirm DATL/DATC/ETA definitions, exceptions and effective text
S022 / FS-S010PartialIRS failure-to-pay calculations and concurrency readRead § 6651 and § 301.6651-1 for controlling scope and exceptions
S022 / FS-S011PartialIRS filing-penalty rates, return categories and minimums readVerify § 6651, inflation adjustment and specific return/year
S022 / FS-S012PartialIRS deposit tiers, noncumulative treatment and relief readRead § 6656 and applicable employment-tax deposit regulations; validate deposit schedule and notice facts

Find the assertion and its boundaries

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

D014-FS-C001 Saved research record

Under § 1.1017-1(a), specified excluded COD income reduces property bases in an ordered sequence, generally using property held on the first day of the following taxable year. § 1.1017-1(b)(1) requires accounting for preceding attribute reductions. This does not independently establish the full § 108 exclusion or attribute-reduction calculation.

Recorded check status: not yet checked

New claim ID
D014-FS-C001
Source / area
S010 / FS-S002; A067
D014-FS-C002 Saved research record

§ 6320(a)(2) requires NFTL notice within five business days after filing. § 6320(a)(3)(B) establishes a separate 30-day hearing-request window beginning the day after that five-day period. Do not calculate an actual deadline without filing and calendar facts.

Recorded check status: not yet checked

New claim ID
D014-FS-C002
Source / area
S012 / FS-S003; A019
D014-FS-C003 Saved research record

§ 6330(a) generally requires notice at least 30 days before the first levy for the specified tax period. §§ 6330(c), (d), (e) and (f) govern hearing issues, review, suspension and exceptions. The 30-day Tax Court petition period runs from the determination, not the original levy notice. uscode.house.gov +1

Recorded check status: not yet checked

New claim ID
D014-FS-C003
Source / area
S013 / FS-S004; A019
D014-FS-C004 Saved research record

§ 6343(a)(1) requires levy release when enumerated conditions are met, including determined economic hardship. An installment agreement does not guarantee release where the statutory exceptions apply. Release does not necessarily bar a subsequent levy.

Recorded check status: not yet checked

New claim ID
D014-FS-C004
Source / area
S014 / FS-S005; A019
D014-FS-C005 Saved research record

§ 6159(c) requires an agreement for qualifying individual Subtitle A liabilities of no more than $10,000 excluding specified additions, subject to five-year compliance history, inability to pay immediately, full payment within three years and continuing compliance. This is not a general $10,000 business-tax guarantee.

Recorded check status: not yet checked

New claim ID
D014-FS-C005
Source / area
S015 / FS-S006; A019
D014-FS-C006 Saved research record

§ 6159(b) permits modification or termination on specified grounds; ordinarily the statute requires 30 days' advance explanatory notice, subject to jeopardy exception. § 6159(d) requires partial-payment agreement review at least every two years.

Recorded check status: not yet checked

New claim ID
D014-FS-C006
Source / area
S015 / FS-S006; A019
D014-FS-C007 Saved research record

§ 6502(a) establishes a general ten-year period after assessment for timely levy or commencement of court proceedings, with stated exceptions. Actual CSED requires assessment-specific suspension, extension and proceeding analysis; ten years cannot simply be added to a tax-return due date.

Recorded check status: not yet checked

New claim ID
D014-FS-C007
Source / area
S016 / FS-S007; A019
D014-FS-C008 Saved research record

§ 7122(a) authorizes compromises; § 7122(c) prescribes submission-payment rules and exceptions, including the statutory individual low-income exception. § 7122(f) includes a 24-month deemed-acceptance provision subject to judicial-dispute tolling. A submitted offer is not automatically accepted. uscode.house.gov

Recorded check status: not yet checked

New claim ID
D014-FS-C008
Source / area
S017 / FS-S008; A019
D014-FS-C009 Saved research record

IRS guidance distinguishes failure-to-file from failure-to-pay penalties. For applicable returns, concurrent monthly penalties reduce the filing component by the payment component. The ordinary rates cannot simply be added as independent 5% and 0.5% charges for the same month.

Recorded check status: not yet checked

New claim ID
D014-FS-C009
Source / area
S022 / FS-S010–S011; A019
D014-FS-C010 Saved research record

The IRS identifies a $525 minimum failure-to-file penalty for the listed Forms 1040/1120 where the return due date without extension is after December 31, 2025, the return is more than 60 days late, and the statutory lesser-of limitation applies. Other return types have different rules.

Recorded check status: not yet checked

New claim ID
D014-FS-C010
Source / area
S022 / FS-S011; A019
D014-FS-C011 Saved research record

IRS guidance gives failure-to-deposit tiers of 2% for 1–5 calendar days late, 5% for 6–15 days, 10% after 15 days, and a conditional 15% notice-triggered tier. These tiers replace rather than accumulate with one another. Actual liability depends on deposit obligations and relief. Internal Revenue Service

Recorded check status: not yet checked

New claim ID
D014-FS-C011
Source / area
S022 / FS-S012; A019

Sources, pinpoints and access limits

Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.

D014-FS-S001 Saved research record

Treasury, 26 CFR § 1.108-7. https://www.ecfr.gov/current/title-26/section-1.108-7

Recorded check status: not yet checked

Retained ID / new sub-ID
S010 / FS-S001
Passage read and evidence
Tax-attribute reduction; requested section endpoint returned an access error
Access / disposition
Unresolved — no claim of passage verification
Direct source URLs
https://www.ecfr.gov/current/title-26/section-1.108-7
https://www.ecfr.gov/current/title-26/section-1.108-7?utm_source=chatgpt.com
D014-FS-S002 Saved research record

Treasury, 26 CFR § 1.1017-1. https://www.ecfr.gov/current/title-26/section-1.1017-1

Recorded check status: not yet checked

Retained ID / new sub-ID
S010 / FS-S002
Passage read and evidence
§ 1.1017-1(a), (b)(1)–(2): basis-reduction ordering, preceding attribute reductions and allocation among multiple discharged debts
Access / disposition
Opened/read; eCFR displayed current through October 19, 2026 ecfr.gov
Direct source URLs
https://www.ecfr.gov/current/title-26/section-1.1017-1
https://www.ecfr.gov/current/title-26/section-1.1017-1?utm_source=chatgpt.com
D014-FS-S003 Saved research record

OLRC, 26 USC § 6320. https://uscode.house.gov/us/usc/119-118/t26/s6320/

Recorded check status: not yet checked

Retained ID / new sub-ID
S012 / FS-S003
Passage read and evidence
§ 6320(a)(1)–(3), (b), (c): written NFTL notice, delivery methods, five-business-day period, hearing request and coordination with § 6330
Access / disposition
Opened/read uscode.house.gov
Direct source URLs
https://uscode.house.gov/us/usc/119-118/t26/s6320/
https://uscode.house.gov/us/usc/119-118/t26/s6320/?utm_source=chatgpt.com
D014-FS-S005 Saved research record

OLRC, 26 USC § 6343. https://uscode.house.gov/us/usc/119-118/t26/s6343/

Recorded check status: not yet checked

Retained ID / new sub-ID
S014 / FS-S005
Passage read and evidence
§ 6343(a)(1)(A)–(E), (a)(2)–(3), (b): mandatory release grounds, essential business property, subsequent levy and return of property
Access / disposition
Opened/read uscode.house.gov
Direct source URLs
https://uscode.house.gov/us/usc/119-118/t26/s6343/
https://uscode.house.gov/us/usc/119-118/t26/s6343/?utm_source=chatgpt.com
D014-FS-S006 Saved research record

OLRC, 26 USC § 6159. https://uscode.house.gov/us/usc/119-118/t26/s6159/

Recorded check status: not yet checked

Retained ID / new sub-ID
S015 / FS-S006
Passage read and evidence
§ 6159(a)–(e): agreements, modification/termination, guaranteed agreements, partial-payment review, administrative review
Access / disposition
Opened/read uscode.house.gov
Direct source URLs
https://uscode.house.gov/us/usc/119-118/t26/s6159/
https://uscode.house.gov/us/usc/119-118/t26/s6159/?utm_source=chatgpt.com
D014-FS-S009 Saved research record

Treasury, 26 CFR § 301.7122-1. https://www.ecfr.gov/current/title-26/section-301.7122-1

Recorded check status: not yet checked

Retained ID / new sub-ID
S017 / FS-S009
Passage read and evidence
Regulatory definitions of DATL, DATC and ETA sought; direct retrieval failed
Access / disposition
Unresolved — exact endpoint identified, operative passage not independently read
Direct source URLs
https://www.ecfr.gov/current/title-26/section-301.7122-1
https://www.ecfr.gov/current/title-26/section-301.7122-1?utm_source=chatgpt.com
D014-FS-S010 Saved research record

IRS, Failure to Pay Penalty. https://www.irs.gov/payments/failure-to-pay-penalty

Recorded check status: not yet checked

Retained ID / new sub-ID
S022 / FS-S010
Passage read and evidence
Calculation sections: 0.5% ordinary monthly rate, 25% ceiling, concurrency, conditional 0.25% and 1% rates, relief
Access / disposition
Opened/read Internal Revenue Service
Direct source URLs
https://www.irs.gov/payments/failure-to-pay-penalty
https://www.irs.gov/payments/failure-to-pay-penalty?utm_source=chatgpt.com
D014-FS-S011 Saved research record

IRS, Failure to File Penalty. https://www.irs.gov/payments/failure-to-file-penalty

Recorded check status: not yet checked

Retained ID / new sub-ID
S022 / FS-S011
Passage read and evidence
Individuals/most businesses, partnership distinction, monthly rates, concurrency, return-due-date minimums
Access / disposition
Opened/read Internal Revenue Service
Direct source URLs
https://www.irs.gov/payments/failure-to-file-penalty
https://www.irs.gov/payments/failure-to-file-penalty?utm_source=chatgpt.com
D014-FS-S012 Saved research record

IRS, Failure to Deposit Penalty. https://www.irs.gov/payments/failure-to-deposit-penalty

Recorded check status: not yet checked

Retained ID / new sub-ID
S022 / FS-S012
Passage read and evidence
Official penalty page opened; complete rate tiers and deposit-period applicability not yet extracted and reconciled
Access / disposition
Partial Internal Revenue Service
Direct source URLs
https://www.irs.gov/payments/failure-to-deposit-penalty
https://www.irs.gov/payments/failure-to-deposit-penalty?utm_source=chatgpt.com

What was examined—and what is still missing

The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.

coverage-1 Saved research record

S010 / FS-S001

Recorded check status: recorded; no individual primary acceptance inferred

Status
Unresolved
Resolved evidence
Exact § 1.108-7 endpoint identified, fetch failed
Residual hold and exact next action
Retrieve current regulation from eCFR or official CFR and read all operative attribute-order, reduction and effective-date provisions

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-2 Saved research record

S010 / FS-S002

Recorded check status: recorded; no individual primary acceptance inferred

Status
Answered for named passages
Resolved evidence
§ 1.1017-1(a), (b)(1)–(2) read
Residual hold and exact next action
Verify remaining paragraphs, elections and property-specific limits before a complete COD calculator

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-3 Saved research record

S012 / FS-S003

Recorded check status: recorded; no individual primary acceptance inferred

Status
Answered for statutory framework
Resolved evidence
§ 6320 notice and hearing provisions read
Residual hold and exact next action
Verify CDP regulations, mailing facts, service and calendar before computing deadlines

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-4 Saved research record

S013 / FS-S004

Recorded check status: recorded; no individual primary acceptance inferred

Status
Answered for statutory framework
Resolved evidence
§ 6330(a)–(f) read
Residual hold and exact next action
Check procedural regulations and exception-specific applicability

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-5 Saved research record

S014 / FS-S005

Recorded check status: recorded; no individual primary acceptance inferred

Status
Answered for enumerated release grounds
Resolved evidence
§ 6343(a), (b) read
Residual hold and exact next action
Verify regulatory hardship test, levy status and wrongful-levy remedies

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-6 Saved research record

S015 / FS-S006

Recorded check status: recorded; no individual primary acceptance inferred

Status
Answered for cited statutory provisions
Resolved evidence
§ 6159(a)–(e) read
Residual hold and exact next action
Verify applicable regulations, agreement category, fees and actual case eligibility

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-7 Saved research record

S016 / FS-S007

Recorded check status: recorded; no individual primary acceptance inferred

Status
Partial
Resolved evidence
Ten-year baseline and § 6502 exceptions read
Residual hold and exact next action
Read relevant § 6503 suspension provisions and reconstruct CSED event history

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-8 Saved research record

S017 / FS-S008

Recorded check status: recorded; no individual primary acceptance inferred

Status
Answered for statute
Resolved evidence
§ 7122(a)–(f) read
Residual hold and exact next action
Verify regulatory grounds and process against § 301.7122-1

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-9 Saved research record

S017 / FS-S009

Recorded check status: recorded; no individual primary acceptance inferred

Status
Unresolved
Resolved evidence
Regulation endpoint identified, retrieval failed
Residual hold and exact next action
Open operative regulation, confirm DATL/DATC/ETA definitions, exceptions and effective text

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-10 Saved research record

S022 / FS-S010

Recorded check status: recorded; no individual primary acceptance inferred

Status
Partial
Resolved evidence
IRS failure-to-pay calculations and concurrency read
Residual hold and exact next action
Read § 6651 and § 301.6651-1 for controlling scope and exceptions

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-11 Saved research record

S022 / FS-S011

Recorded check status: recorded; no individual primary acceptance inferred

Status
Partial
Resolved evidence
IRS filing-penalty rates, return categories and minimums read
Residual hold and exact next action
Verify § 6651, inflation adjustment and specific return/year

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance
coverage-12 Saved research record

S022 / FS-S012

Recorded check status: recorded; no individual primary acceptance inferred

Status
Partial
Resolved evidence
IRS deposit tiers, noncumulative treatment and relief read
Residual hold and exact next action
Read § 6656 and applicable employment-tax deposit regulations; validate deposit schedule and notice facts

Recorded coordinator check boundaries

coordinator acceptance
scoped_review_with_remaining_holds_not_parent_acceptance

Corrections, review and scope

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.

Recorded review disposition

revise

Other components in this research series

D014initial

Tax Debt Resolution and Cancellation Taxation

Inside: A019 — Tax debt resolution · Federal assessment, liens, levies, and collection sequence · Installment agreements and ordinary payment alternatives

8 tables50 claim records40 source recordsScoped review · limits applyCaptured 2026-10-22
D014correction-01

Focused evidence correction and publication-control supplement

Inside: Focused evidence correction and publication-control supplement · Evidence and ID controls · 1. Replacement finding — C008 / S019: IRS Simple Payment Plans

13 tables19 claim records9 source recordsScoped review · limits applyCaptured 2026-10-23
D014formula-02

FORMULA-02 — Original worked-example repairs

Inside: 1. Repaired original formulas · E01 — Insolvency exclusion with partially taxable COD · E02 — Why insufficient cash does not establish insolvency

3 tables7 claim records7 source recordsScoped review · limits applyCaptured 2026-10-23
D014local-03

LOCAL-03 — California and Orange Local-Source Recovery

Inside: 1. California FTB — D014-S030 · 2. California EDD — D014-S033 · 3. Orange County Treasurer–Tax Collector — D014-S034

4 tables8 claim records12 source recordsScoped review · limits applyCaptured 2026-10-23
D014mapping-04

MAPPING-04 — FORMULA-02 Metadata and Provenance Amendment

Inside: 1. Corrected count sentence · 2. Source/status replacement rows · 3. Original claim/example mapping

3 tables8 claim records2 source recordsScoped review · limits applyCaptured 2026-10-23
Record integrity

Original saved Markdown SHA-256: d1bdadb53070a69c83cdb4136ee68908ff3b9b04c3dc4b6e08d82af5c96da987. Public formatting, private-reference removal and correction annotations are separate from that immutable original.

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