Yes, if the IRS identifies that the taxpayer has an unfiled prior year return (especially a return in which the IRS projects a balance owed), they can freeze the refund and request the taxpayer to file. The refund is held for 6 months while the IRS requests a filed return from the taxpayer. If no return is received, an assessment may be made through the Automated Substitute for Return (ASFR) program, and the refund applied to any balance due.
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