Delayed Tax Refunds, TC 570 And An Important Distinction

By the stats, the current tax season has been quite a success. The Internal Revenue Service is reporting that, despite an abbreviated season, they are processing tax returns and issuing tax refunds at a much faster pace than last year.

Of course, all of the numbers in the world don't matter when the one number you're counting on – your own refund – is affected.

This season, I've heard from a number of taxpayers experiencing tax refund delays (though certainly nothing near last year's education credit snafu). Initially, the trouble seemed to focus on those 1121 codes. The IRS was made aware of the problem and did issue a statement, saying:

A very small percentage of taxpayers may see an 1121 reference number if they check "Where's My Refund?" after they initially were provided a projected refund date by the tool. The IRS is aware of this situation, and emphasizes that the small group of taxpayers who see this reference number should continue checking Where's My Refund for an update. If we need more information to process their return, we will contact them — usually by mail.

Most of the taxpayers who reached out to me regarding the 1121 issue – including Donna – have since reported that they've either received their refunds or updated information about the delay.

However, shortly after the 1121 issue was made public, the focus from taxpayers on social media – and in emails, direct messages and private messages to me – has zeroed in on another code that's popping up over and over: TC 570. There is a notable difference between the 1121 code and the TC 570: the latter is not an explicit refund code. It appears not on the "Where's My Refund?" tool but on a taxpayer's transcript. That's an important distinction.

I reached out to IRS to find out whether there was any sort of systemic issue causing taxpayers to see a TC 570 on their transcript. So far, the answer to that question is no. The IRS is, however, clearly aware of the concerns and had this to say:

A Transaction Code 570 can mean different things in different cases so a taxpayer should not try to draw a conclusion based on the presence of a TC 570. The Transaction Code 570 will stop a refund from being issued until the impact of the action being taken on the account and the refund is determined and processed. Transaction Codes are used internally by the IRS to identify a transaction, adjust and research tax accounts and to maintain a history of actions posted to a taxpayer's account. While they are reflected on transcripts they are not reflected on most public facing documents or tools like Where's My Refund because they are difficult to interpret and can have different meaning depending on the case and associated codes and files. Again, the best way for taxpayers to check the status of their refund is by going to Where's My Refund.

It's a statement worth repeating. The IRS uses a lot of internal codes on transcripts and they can mean different things. And what it means exactly isn't always apparent to the person taking the call at IRS. Does that suck? Of course it does. Trust me. I've been on the end of those calls trying to decipher what's going on for taxpayers. And I totally believe that taxpayers are calling IRS and getting two or three different answers about the status of their refund. And I believe that taxpayers deserve a better answer.

But I would caution taxpayers not to try and pick apart their tax transcripts in an effort to find answers. There is no "one size fits all" answer to the TC 570 – not even in the best of circumstances. It does not necessarily equate, as some have surmised, an audit. Nor does it means, as others have posited, that the refund is subject to an offset. It could mean those things – but again, you're not going to be able to tell from a glimpse at your transcript this early in the season.

It reminds of me of this great scene in The Princess Bride:

Those codes? They don't always mean what you think they mean.

I know that isn't the answer that taxpayers want to hear. And trust me, I am continuing to pester IRS about these issues (believe me when I say that they have my number). But it's not a certainty that a TC 570 on your transcript is anything sinister at this stage of the season. The data doesn't appear to support it. And if there's a real problem with your specific return, you'll hear from IRS.

And yes, there have been problems. I have confirmed reports that a glitch in at least one program has resulted in the issuance of paper checks instead of direct deposit. Errors – mostly transposition of numbers – have slowed processing of other returns. There have been bounces for bad addresses. Returns have been held because of prior years when no returns were filed. And yes, identity theft continues to be a big problem especially when Social Security numbers for dependents have appeared on more than one return. Clearly, not everyone is having a smooth tax season.