IRS EIN Reference Number 115: The Responsible Party Is Recorded as Deceased

Why estates trigger it

An estate application asks for the deceased person’s Social Security number once, beside the “Estate” box on Line 9a, so the IRS can tie the estate to the person’s final return. It asks for the responsible party separately on Lines 7a and 7b, and that must be a living person with authority over the estate: the executor, administrator or personal representative, with their own SSN or ITIN.

The form’s wording makes the mix-up easy. The estate is named after the person who died, so people keep writing that person into every box. The IRS checks Line 7b against Social Security’s death records, and the application stops with 115. Form SS-4 for an estate, line by line.

Fix it for an estate or a trust

• Line 7a: your name, as executor, administrator, personal representative, or successor trustee.
• Line 7b: your own SSN or ITIN.
• Line 9a: for an estate, tick Estate and enter the deceased person’s SSN there. For a trust, tick Trust and enter the grantor’s SSN there, even if the grantor has died.
• Line 11: the date of death, not today.

With those four lines right, the same application goes through. If you would rather not make a second attempt on the website, the fax route is reviewed by a person and the corrected form is accepted there too. The full estate EIN guide.

If you are alive and the IRS says otherwise

A small number of living people are marked deceased in Social Security’s records by clerical error, and the first place it surfaces is often a rejected credit application or an EIN attempt. The IRS reads the SSA record and will keep returning 115 until it changes. The correction is made at a Social Security office, in person, with government identification; the SSA issues a letter confirming the record has been fixed.

Once the record is corrected, apply by fax and include a copy of the SSA letter with the SS-4. The online tool may keep failing for a while after the correction, because it reads a cached copy of the records.

What it is not

115 is not a name-mismatch code; that is 102 or 103. And it is not a reason to enter a different living relative as the responsible party to get past the screen. The responsible party must actually control the estate or trust, and the IRS can ask the executor to prove it later.

Quick answers

Can the deceased person be the responsible party for their own estate?

No. The responsible party is defined as the person who controls the entity, and an estate is controlled by its executor or administrator.

The executor lives abroad and has no SSN. What then?

The executor is still the responsible party; Line 7b is left for the IRS, and the application goes by fax or mail rather than online. Getting an EIN without an SSN.

Every reference number in one place

IRS EIN reference numbers 101 to 115, explained.