TC 570: Additional Liability Pending — the -R Freeze
By Forrest Baumhover, CFP®, EA · Last verified August 28, 2026
TC 570 holds a refund on the possibility of a liability the IRS has not yet finished pricing, and a second TC 570 posted before the first one clears is the one detail that turns an ordinary hold into a freeze that will not lift on its own.
What the code actually does
TC 570 sets the -R freeze on a tax module. Per IRM 21.5.6.4.35, "the -R freeze is set when there is an additional tax liability pending and a Transaction Code (TC) 570 posts to a module." IRS Document 6209 states the effect more bluntly: TC 570 "indicates additional liability pending" and "freezes (—R freeze) module from refunding or offsetting credit out." Nothing about the code itself says the liability is confirmed — only that something is pending review before the module's credit balance is allowed to move.
That "pending" framing matters for how a practitioner should read the code on a transcript. TC 570 is not, by itself, evidence of a determination against the taxpayer. It is a hold placed while a specific question — a missing signature, a mismatched payment, an open examination reference, a return flagged for further review — gets resolved one way or the other. The freeze reaches offsets as well as refunds: Document 6209 is explicit that it stops the module from both "refunding" and "offsetting credit out," so a TC 570 module's overpayment cannot be swept to pay a balance on another period either, until the freeze clears.
What generates it
Document 6209 lists several distinct triggers rather than one single cause, and reading the specific one on a given transcript changes what a practitioner should expect next. Two worth knowing by name: a "TDI/DEL RET Refund Hold (Julian Date 999)" — a TC 570 carrying 999 in the Julian date field of its Document Locator Number, which IRM 21.5.6.4.35.2 ties to an open delinquent-return investigation on a prior year holding a current-year refund — and a credit-balance trigger tied to examination activity, stated in Document 6209 as "TC 670 posts creating a credit balance and an unreversed TC 420 or 424 is posted to module." That second trigger is worth flagging on its own: TC 420 and TC 424 identify Examination involvement, and their presence is what turns an ordinary payment-created credit balance into a -R freeze rather than a routine overpayment.
IRM 21.5.6.4.35 also documents a Return Integrity Verification Operations (RIVO) pathway to the same freeze, identifiable on a transcript by specific markers — a TC 570 with all fives in the blocking series and serial number of its DLN, or an accompanying TC 971 with Action Code 052, 122, 134, or 140, among others the subsection lists. Those markers tell a practitioner *that* RIVO is involved, not *why* — the IRM's public text does not explain the internal criteria RIVO uses to select a return for review, and this page does not speculate about it.
The trap: a second TC 570 blocks systemic release
IRM 21.5.6.4.35 flags this directly, as a Note attached to its own opening sentence: "A subsequent TC 570 prevents the -R Freeze from systemically releasing. Follow procedures in IRM 21.5.6.4.35.2, Resolving -R Freeze, for resolution." In practice, that means a transcript showing two TC 570 postings on the same module is not simply "the freeze got renewed" — it is the IRS's own documented signal that whatever automated process might otherwise have cleared the first hold will not act on its own, and the module now needs a human to work it through IRM 21.5.6.4.35.2's resolution table rather than waiting for a system-generated release.
This is the single most useful fact a practitioner can pull from this page: seeing a lone TC 570 justifies patience while the underlying issue resolves; seeing a second one on the same module is the cue to start actively working the case rather than continuing to wait for the transcript to update on its own.
How it gets released — TC 571, and how TC 572 is different
The path back to a refund runs through TC 571. Document 6209, in the TC 571 entry itself: "Reversal of TC 570 ... Releases the 570/576 freeze status." IRM 21.5.6.4.35.2's own resolution table confirms the same mechanism in practice — where a TC 570 is holding an overpayment that should actually be refunded, the instruction is to "input a TC 571 using CC REQ77, to release the freeze," and a separate row of that same table states plainly that once "TC 840/571 has been input," the "[f]reeze automatically releases when the transaction posts." Once the -R freeze clears and the module carries a credit balance, TC 846 is the code that actually issues the money — Document 6209 defines TC 846 as debiting "the tax module for the amount of overpaid tax (plus applicable interest) to be refunded to the taxpayer." TC 571 clears the obstacle; TC 846 is the payment itself, and the two are not the same event on a transcript.
Do not read TC 572 as a second flavor of release. Document 6209 defines it separately: "Correction of 570 Processed in Error ... Used to remove TC570/576 Input in error." TC 572 undoes a TC 570 that should never have posted at all — an input mistake — while TC 571 releases a freeze that was doing exactly what it was supposed to do until the underlying issue got resolved. Both codes clear a -R freeze from the module; only one of them means the freeze had a genuine basis in the first place.
What TC 570 gets confused with
The most common mix-up is with TC 810, and it is easy to see why: both freeze a refund, both sit quietly on a transcript, and both can outlast a taxpayer's patience. But they are different freezes with different origins. TC 570 sets the -R freeze and, per IRM 21.5.6.4.35, is usually about a specific pending question on the module itself — a missing document, a payment discrepancy, an open TDI. TC 810 sets a separate -E freeze that IRM 21.5.6.4.10 describes as placed "by Compliance or Return Integrity and Compliance Services (RICS)" — a broader compliance hold, not a module-level processing question. See TC 810 for how that freeze works and what its own release code, TC 811, requires.
TC 570 is also worth distinguishing from TC 130, the V- freeze covered elsewhere in this library. TC 130 freezes an entire account — every module, every tax period — because of a liability the IRS says exists somewhere else on record; a TC 570 -R freeze applies to one module and is usually about that module's own pending question, not a debt parked on a different account. Seeing "something froze the refund" on a transcript is the start of the research, not the end of it — which specific code posted determines which of two very different investigations is the right one.
And, as covered above, TC 420 or TC 424 alongside a TC 570-generating credit balance does not make the -R and -L (Open Examination) freezes the same thing. Per IRM 21.5.6.4.24, in full: "The -L (Open Examination Indicator) freeze is set when a Transaction Code (TC) 420 or TC 424 posts to an account that has been referred to Examination. It does not freeze the account. Instead, the module is frozen from refund and offset." That is the same module-level scope as -R, not TC 130's whole-account V- freeze — so -L flags Examination involvement rather than a pending item, and each freeze releases through its own, separate procedure.
The practitioner's actual next step
Count the TC 570 postings on the module before doing anything else. One posting: research the specific trigger (DLN blocking series, TC 971 action code, TDI status) and expect the freeze to run its own course absent a second signal. Two or more postings on the same module: treat systemic release as off the table and move directly to working the case under IRM 21.5.6.4.35.2's resolution table, which sorts by the actual reason the freeze was set — a misdirected payment, missing return information, an unresolved TDI, and several others — rather than by the code itself.
Where the module shows an unreversed TC 420 or TC 424 alongside the TC 570, confirm whether the practitioner is actually looking at an open examination before advising the client the freeze will clear on the usual processing timeline; an active Exam involvement changes who is actually working the case.
What this means for your refund
A TC 570 on your transcript means the IRS is holding your refund for one specific, pending reason — not that anything is wrong with your return in general. Most of the time this resolves once whatever triggered it (a missing document, a payment that needs to be matched up, a review the IRS is finishing) gets sorted out, and a TC 571 followed by a TC 846 shows up once it does.
The one thing worth watching for is a second TC 570 appearing after the first. That is the IRS's own signal that the hold will not clear automatically and someone needs to work the case directly — at that point, waiting longer usually will not help. If you want a clearer picture of exactly what your own transcript is showing and what a TC 570 or a second one means for your specific account, the IRS Transcript Decoder walks through your codes in plain language.