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 Those failures are not treated as evidence that the regulations are unavailable or repealed.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
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