Why SAM.gov's taxpayer check fails, and what the IRS consent is
What SAM.gov's taxpayer check compares with the IRS's records, the usual reasons it fails, what happens next, and what the IRS consent allows.
Updated
SAM.gov's taxpayer check asks the IRS whether the taxpayer name and identification number on a registration match the IRS's own file for the most current tax year reported. It usually fails because the name is not the one the IRS holds for that number: a trade name, or a spelling that differs from the IRS's letter issuing the number. The IRS consent is the taxpayer's own written permission for the IRS to tell SAM.gov whether they match, and SAM.gov emails the registration's contact with the result.
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What is SAM.gov's taxpayer check?
SAM.gov checks a registration's taxpayer name, address and identification number with the IRS. The check runs on every Financial Assistance and All Awards registration, and a registration is not active until it clears. A Unique Entity ID alone has no taxpayer check. The FAR says the same from the buyer's side. Its provision on SAM registration defines registered as validated by the Government, the taxpayer identification number with the IRS included, and marked Active (FAR 52.204-7).
SAM.gov lists three things the section needs: the taxpayer identification number, the most recent year the entity filed paperwork with the IRS, and the taxpayer name and address as on the most recent tax return. The number is an employer identification number or, for a sole proprietor who chooses it, a Social Security number. SAM.gov adds that this information may differ from the legal business name and physical address. It says to use what is on file with the IRS. What to have ready before you register in SAM.gov is the list for every section.
Why does the taxpayer check fail?
Most often because the name does not match. The IRS compares the name, or its name control, and the number on the registration with its own file for the most current tax year reported. That is how SAM.gov's consent describes the check. SAM.gov's own tip is that the taxpayer name must exactly match the name the IRS has on file for the number, according to the most recent tax return. A trade name, a doing-business-as name or the name as a state filing spells it can all differ from the name the IRS holds.
The name control is the IRS's short form of the name. The IRS says it is a sequence of up to four letters or numbers derived from a taxpayer's name, usually its first four characters. The IRS creates it from the legal name on the application when the number is requested. So the first word of the name, its spelling and its punctuation matter more than the suffix at the end. The IRS's letter that issued the number shows the name the IRS holds for it. A sole proprietor who gives a Social Security number gives their own name, as the IRS has it, never the trade name.
A brand-new number can fail for a different reason. The IRS's notice that issues an employer identification number says the number takes time to reach the IRS's permanent records. Until then it cannot pass a matching check. A registration started soon after the number was issued can fail the check with every name right. Is a UEI the same as an EIN? keeps the two identifiers apart; the taxpayer check is about the second.
What happens when the check fails?
SAM.gov emails. The Federal Service Desk's article on activation says you receive an email when the reviews are complete and the registration is active, or if it has been rejected for corrections to be made. While the IRS or the Defense Logistics Agency reviews the information, the article says, the government business point of contact should watch their email, spam or junk folder included. Its article on registering says a submitted registration goes through IRS verification and, where it applies, CAGE verification, and that nothing can be changed until those reviews are complete. SAM.gov's own taxpayer page says the same when the section is sent: once submitted, the information cannot be edited until the IRS completes verification.
A failed check is a correction, not a judgment on the business. The name or the number is corrected to what the IRS holds, and the registration goes through the check again. If the IRS's own file is what is wrong, the check cannot pass until that file and the registration agree. Why a SAM.gov registration is stuck or returned covers the other reasons a submitted registration waits. Why your business name and address have to match your paperwork exactly covers the earlier name match, against your formation records rather than the IRS's.
What is the IRS consent?
It is the taxpayer's written permission for the IRS to answer SAM.gov. SAM.gov's consent, headed consent to disclosure of tax information, cites 26 U.S.C. 6103(c), the part of the tax code that lets a taxpayer allow a disclosure. In it the taxpayer allows the IRS to validate the name, or name control, and the number given for the registration. The IRS may then tell the System for Award Management program office whether they match or do not match what it holds for the entity in the most current tax year reported. The IRS shares the match result, not a return and not a balance.
The consent also says where the result goes. The IRS-validated name and number reside in SAM.gov. There, federal procurement officials and other government personnel performing managerial review and oversight can use them for governmental business activities, tax reporting and debt collection included. The FAR adds why. Provision 52.204-7 says an offeror will be required to provide consent for TIN validation to the Government as part of the SAM registration process. SAM.gov's registration checklist lists the IRS consent form, with the taxpayer name and address, among the core data of a registration.
The consent is the taxpayer's own. A person with authority to give it for the entity gives it. That person gives their own name and title as the individual executing it, and states that they have that authority. Nobody gives it in your place.
What should I never put in a message or a chat?
SAM.gov asks for the taxpayer identification number in its own section and nowhere else. This guide does not ask for it, shows no example, and never will. Never put a tax ID or a bank number in a message, a chat or an email. An employer identification number and a Social Security number are tax IDs too.
What can this guide not tell you?
It cannot say how long the IRS takes, or whether a particular name will match: only the IRS's file decides, and SAM.gov reports the result. The Federal Service Desk's article on the taxpayer identification number process could not be read for this guide. So it quotes SAM.gov's own taxpayer pages as they were read during a registration, SAM.gov's checklist, the Federal Service Desk's articles on activation and on registering, the FAR and the IRS's page on the name control, and nothing else.
What does Firmenza do here?
Firmenza's copilot explains each taxpayer question in plain words and asks for no tax or bank number in a message or a chat. The IRS consent is yours: you give it in writing on Firmenza, before you send your answers, and we complete your SAM.gov registration from your answers. A Firmenza specialist reviews your application. If SAM.gov reports a failed check, we tell you what it says and what, if anything, we need from your business.
Free help also exists: APEX Accelerators (DoD-funded, free) and the Federal Service Desk will help you at no charge. We built Firmenza to be useful alongside them.
Sources
- SAM.gov: Entity Registration Checklist (PDF), the taxpayer identification number and the IRS consent form under Core Data
- Federal Service Desk: How long does it take until an entity registration is considered active? (the IRS check and its email)
- Federal Service Desk: How do I register a new entity or obtain a new Unique Entity ID in SAM.gov? (IRS verification after Submit)
- Acquisition.gov: FAR 52.204-7, System for Award Management (registered means validated with the IRS and marked Active)
- IRS: Using the correct name control in e-filing corporate tax returns (what a name control is)
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