eb683700__21_5_6_Freeze_Codes__Cont__1___THEN_
[If the TC 520 cc is:] 81 [THEN:] 
Follow the -V freeze instructions in IRM 21.5.6.4.44, -V Freeze. A TC 520 cc 81 is a Bankruptcy Litigation freeze but shows a -W freeze instead of a -V freeze. In January 2002 new bankruptcy closing codes became available; however, the closing code 81 continues to be used. Refer to IRM 5.9.5.6.1(5) and (6), Closing Codes, concerning older closing codes. Note: Prior to revisions in June 2005, the cc 81 was also used by Advisory on all periods for which a proof of claim was filed in a probate case. Now cc 80 is used in probate cases when the CSED is suspended while assets are in the custody of a court. Note: A cc 81 may be used for compliance with a Refund Turnover Order (RTO) as well as for a litigation freeze. Refer to IRM 5.9.5, Opening a Bankruptcy Case. After complying with an RTO, check whether the -W litigation freeze should remain on the account before reversing the -W freeze for RTO compliance. Refer to IRM 5.9.6, Processing Chapter 7 Bankruptcy Cases.
Internal Revenue Manual - 21.5.6 Freeze Codes (Cont. 1)
THEN: