TC 570: Additional Liability Pending — the -R Freeze

By Forrest Baumhover, CFP®, EA · Last verified September 14, 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 — the IRS's record of one tax period within an account. 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 (the IRM tags this specific marker as a BMF-account indicator, not one to expect on an individual transcript), or an accompanying TC 971 with Action Code 052, 122, 134, or 140, among others the subsection lists without that same BMF-only tag. 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.

How it gets released — TC 571, and how TC 572 is different

The path back to a refund runs through TC 571, "Reversal of TC 570" per Document 6209. IRM 21.5.6.4.35.2's resolution table confirms it in practice: where a TC 570 holds an overpayment that should be refunded, the instruction is to "input a TC 571 using CC REQ77" — CC meaning Command Code, the internal keystroke command an employee types — "to release the freeze." Once the freeze clears, TC 846 is the separate transaction that actually issues the money — TC 571 removes the obstacle, TC 846 is the payment, 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, as "Correction of 570 Processed in Error" — it undoes a TC 570 that should never have posted at all, while TC 571 releases a freeze that was doing exactly what it was supposed to do until the underlying issue resolved. Both clear a -R freeze; only one means the freeze had a genuine basis in the first place. Doc 6209's TC 572 entry also mentions "TC570/576" together, and "576" names the TC 576 freeze too — TC 576 and its own reversal, TC 577, cover that mechanism in full.

What people mistake TC 570 for

People confuse it with TC 810: both freeze a refund and both can outlast a taxpayer's patience, but they have different origins. TC 570 sets the -R freeze and is usually about a specific pending question on the module itself — a missing document, a payment discrepancy, an open TDI (Taxpayer Delinquency Investigation, an unfiled prior-year return). TC 810 sets a separate freeze (-E on an IMF account; -Q on a BMF account for some responsibility codes) 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 and its release code, TC 811, for how that freeze works.

It is also worth distinguishing from TC 130, the V- freeze: TC 130 freezes an entire account for a liability recorded elsewhere, while a TC 570 -R freeze applies to one module over that module's own pending question. And TC 420 or TC 424 alongside a TC 570-generating credit balance does not make -R and -L (Open Examination) the same freeze — IRM 21.5.6.4.24 states plainly that a -L freeze "does not freeze the account," and like -R it operates at the module level, not TC 130's whole-account scope. Which specific code posted determines which investigation is actually the right one to research.

What to do next

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 ask the IRS to work the case (Practitioner Priority Service line, or Form 911 if the delay causes hardship); IRM 21.5.6.4.35.2's resolution table, which IRS employees use, 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, such as a missing document, a payment that needs to be matched up, or a review or examination the IRS has open. The hold lifts once whatever triggered it gets sorted out, and you'll usually see two more codes on your transcript once it does: one that lifts the hold, then one that shows your refund actually being sent.

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, so call the number on your IRS notice and ask. 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.

Sources

This page provides general information about IRS procedures. It is not personalized tax advice, and reading it does not create a practitioner-client relationship with Forrest Baumhover, Fbaum Enterprises LLC, or The Federal Tax Desk. Every situation is different — if real money or a real deadline is on the line, consider having a licensed CPA, EA, or tax attorney review your specific facts before you act.

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