What the Transcript Shows When No Return Was Filed: TC 140, TC 142 and TC 590 to 599

An account transcript for a year you never filed often looks empty. It is not. The IRS can establish a tax module without a return, and it records its delinquency work there. Knowing those codes tells you whether the IRS has noticed the gap, what it has done about it, and what it is likely to do next.

Opening the delinquency: TC 140, 141 and 142

Document 6209 describes three codes that open delinquency work on a module.

• TC 140, "IRP Delinquency Inquiry," which "establishes Entity and/or Tax Module and Status Code 02 (Delinquency Inquiry) within the affected tax module." IRP is the Information Returns Program. This is the payer data on your wage and income transcript turning into a question about a missing return.
• TC 141, "Delinquency Inquiry," generated by IDRS processes.
• TC 142, "Delinquency Investigation," which "records the issuing of a Taxpayer Delinquency Investigation (TDI/DEL RET)" and "establishes Status Code 03 within the affected tax module."

Document 6209's collection status codes explain the statuses. Status 00 means the module is established but the return is not filed. Status 02 means the return is not posted and a letter of inquiry was mailed. Status 03 means the module is in delinquency investigation status on IDRS.

If you see a TC 140 or TC 142, the IRS has formally noticed that a return it expects is missing. See Account Transcript vs. Wage and Income Transcript for how the payer data drives this.

Closing the delinquency: TC 590 through 599

Delinquency investigations close with a satisfying transaction in the 59X range. Document 6209 defines each.

Document 6209 says each requires a three-digit closing code for IDRS input. The Section 11 closing code tables add the reason. Examples include not liable because income was below the filing requirement, no return secured because little or no tax was due, no return secured because the taxpayer was due a refund, closures by the ASFR program, and not-liable determinations made after the case was classified for a substitute for return under IRC 6020(b).

What each closure means for you

TC 590 or TC 591 means the IRS concluded you were not required to file. That is a determination worth keeping. If you agree with it, keep the transcript. If you were in fact required to file, the code does not fix that; the obligation is still yours.

TC 594 means the IRS believes a return was already filed. If you see a TC 594 with no TC 150, the return may have posted to a different year or a different taxpayer. Document 6209 lists TC 971 action code 001 for a TC 150 posted to an incorrect TIN or tax period. That is worth chasing.

TC 593 means the IRS could not find you. Document 6209 notes that when an address change posts to the entity, a TC 592 is generated one cycle later for each module with a return due date within the previous five years, which reopens the delinquency.

TC 595 means the case was referred to Examination. The next codes are likely exam codes or a substitute for return.

TC 599 means a return was secured. Normally a TC 150 posts as well. On an ASFR case, IRM 5.18.1 describes the program requesting a TC 290 assessment and a TC 599 when the taxpayer agrees to the proposed assessment. See Substitute for Return on Your Transcript.

Document 6209's status 06 describes the result of most closures: delinquent return not filed, investigation closed or shelved, collection action suspended while an exam review is pending, until another tax period posts, because the taxpayer cannot be located, or because the taxpayer is not liable.

Other codes on unfiled years

A few more codes show up on years without a return.

TC 474 interrupts normal delinquency processing, and Document 6209 says it can be used "to prevent IDRS Delinquency notice or TDI/DEL RET issuance" for a period; TC 475 reverses it. TC 148 accelerates delinquency or balance due assemblies when certain non-compliance conditions are present, and TC 149 reverses it.

TC 460 records an extension of time to file. A TC 460 with no TC 150 means you asked for more time and then did not file.

Payments can sit on an unfiled year. Document 6209 says a TC 670 posted before the return "credits the Tax Module with prepayment on account," and estimated tax credits, TC 660, are frozen from refunding or offsetting until a TC 150 posts. Withholding is not credited to the account until a return claims it. That is money you cannot use until you file.

Why filing still matters

The statutes give you three reasons to file even late.

Assessment. IRC 6501(c)(3) allows assessment at any time when no return is filed. Your own return starts the assessment period under IRC 6501(a). A substitute for return does not, under IRC 6501(b)(3).

Penalty. The failure-to-file penalty under IRC 6651(a)(1) runs 5 percent per month up to 25 percent. Filing stops the clock on it.

Refunds. If tax was overpaid through withholding, IRC 6511 limits how long you have to claim it, and IRC 6513(b)(1) treats withholding as paid on the original due date. Late years can lose their refunds.

A verification of non-filing letter will not help you here. IRM 21.2.3.2.5 says it verifies only that the IRS has no record of a processed return, and "does not provide any status of the taxpayer's filing requirement." The account transcript codes are the better source.

A worked example

Each line in that sequence is also an opportunity that closes. Before the TC 150 dummy return posts, you can file your own return and avoid the substitute entirely. Before the notice of deficiency, you can respond to the proposed assessment. After the notice, the Tax Court window under IRC 6213(a) is the remaining formal route before assessment.

Every step is recorded. The IRS noticed the missing return through information returns, asked about it, opened an investigation, built a substitute return, issued the notice of deficiency and assessed. The taxpayer who reads this sequence early, at the TC 140 or TC 142 stage, still has the option of filing an accurate return before the substitute is built.

Business non-filers

Business accounts have their own delinquency processing. Document 6209 describes TC 925 as the business master file status transaction for IRP underreporter, CAWR and business non-filer work. If your business has a missing employment tax or income tax return, the business account transcript is where to look, and the same logic of opening codes and satisfying codes applies.

When the return finally arrives

Filing a late original return changes the codes. If no substitute return was built, your return posts as the TC 150, and the delinquency is satisfied. If a substitute return already posted, your return usually posts as a duplicate, TC 976, and the reduction, if any, follows as an adjustment. Either way, the year finally has your numbers on it, and every later code is measured against them. That is the point of filing: to replace the IRS's version of the year with yours.

Reading an unfiled year

• Confirm there is no TC 150.
• Look for TC 140, TC 141 or TC 142 and their dates.
• Look for a 59X closing code and identify which one.
• Look for a zero TC 150 with the SFR markers, or a TC 971 action code 141.
• Note any payments, estimated payments or extension on the module.
• Pull the wage and income transcript to see what the IRS knows.

An empty year is rarely empty. It is a year the IRS is waiting on, working, or has already decided about. The codes tell you which.