IRS Form 720-TO – Terminal Operator Report

IRS Form 720-TO – Terminal operators across the United States must accurately track and report fuel movements. IRS Form 720-TO, officially titled the Terminal Operator Report, is the key IRS information return for this purpose. It ensures proper oversight of liquid products in the fuel distribution system and supports excise tax compliance.

This comprehensive guide, based on official IRS resources as of February 2026, explains everything you need to know about IRS Form 720-TO — including who must file, deadlines, electronic filing via ExSTARS, how to complete the form, penalties, and direct download links.

What Is IRS Form 720-TO (Terminal Operator Report)?

Form 720-TO is a monthly information return that terminal operators use to report:

  • All receipts (incoming liquid products) into approved terminals
  • All disbursements (outgoing liquid products) from approved terminals

An “approved terminal” is a taxable fuel storage and distribution facility supplied by pipeline or vessel, from which products are removed at a rack. The form covers all liquid products, not just taxable fuels — including gasoline, diesel, jet fuel, biodiesel mixtures, ethanol blends, kerosene, and many others identified by specific Product Codes (PC).

The current version is Form 720-TO (Rev. September 2010), with Instructions for Form 720-TO (Rev. July 2017). These remain the active documents on IRS.gov with no revisions issued as of early 2026.

Purpose: The data from Form 720-TO feeds into the IRS Excise Summary Terminal Activity Reporting System (ExSTARS). It helps match fuel movements against excise tax returns (such as Form 720), detect discrepancies, and ensure tax collection on fuels.

Who Must File IRS Form 720-TO?

Every terminal operator (a taxable fuel registrant operating an approved terminal) must file a separate Form 720-TO for each approved terminal they operate — even if the terminal is inactive for the month.

This includes:

  • Operators of IRS-approved bulk fuel storage terminals
  • Facilities with a Terminal Control Number (TCN) listed in the IRS Terminal Locations Directory

Related parties, such as position holders (the entity holding inventory title in the terminal), do not file 720-TO — only the terminal operator does.

Note: Bulk carriers (barges, ships, pipelines) use the companion Form 720-CS (Carrier Summary Report) for their transactions.

When and Where to File Form 720-TO?

Filing Frequency: Monthly
Due Date: Last day of the month following the reporting month
Example: Transactions in January 2026 are due by February 28, 2026 (or next business day if it falls on a weekend/holiday).

Paper Filing Address (if allowed):
Internal Revenue Service
Attn: Excise Unit
Stop 5701G
Cincinnati, OH 45999

Mail forms flat (no folding, stapling, or taping). Use IRS-designated private delivery services for timely mailing proof.

Electronic Filing Is Mandatory for Most Terminal Operators (ExSTARS)

If you have 25 or more reportable transactions in a month, you must file electronically through the Excise Summary Terminal Activity Reporting System (ExSTARS).

  • Each receipt or disbursement counts as a separate transaction.
  • Even smaller operators are strongly encouraged to file electronically.
  • Paper filing is permitted only if you have fewer than 25 transactions per month.

Benefits of ExSTARS e-filing:

  • Faster processing and confirmation
  • Reduced errors
  • Better compliance tracking
  • Access to the ExSTARS portal at exstars.irs.gov

To participate, submit a letter of application (sample letters available on IRS.gov) and register for an ExSTARS account. Approved transmitters and software developers are listed on the IRS website.

Publication 3536 (Motor Fuel Excise Tax EDI Guide) provides technical specifications for electronic filing.

How to Complete IRS Form 720-TO: Step-by-Step?

The form consists of:

  • Part I — Identification of the terminal operator (name, address, EIN, Form 637 registration number, contact info)
  • Part II — Terminal details (name, location, TCN)
  • Part III — Monthly summary by Product Code (beginning inventory, receipts, disbursements, gains/losses, ending physical inventory)

Two key schedules (attach as needed):

Schedule A – Terminal Operator Receipts

  • One schedule per Product Code
  • Report carrier name, EIN, mode code, document date/number, and net gallons
  • Non-bulk receipts for certain codes (001, 049, 092, 122, 188, 960) can be summarized monthly using “Various” and mode code “CE”

Schedule B – Terminal Operator Disbursements by Position Holder

  • Separate schedule for each position holder, per Product Code, and often by destination state and mode
  • Include carrier details, mode code, date, document number, and gallons
  • Non-bulk for summary-eligible codes can use monthly summary

Key Data Elements:

  • Use net gallons (corrected to 60°F) for most entries
  • Mode Codes (critical): J=Truck, R=Rail, B=Barge, S=Ship, PL=Pipeline, RS=End-use at terminal, RF=Refueling vessels, BA=Reclassifications, CE=Summary, plus import/export variants (IJ, IB, etc.)
  • Product Codes (PC): Over 50 codes; examples include:
    • 065 = Gasoline
    • 167 = Diesel Fuel #2 Low Sulfur Undyed
    • 130 = Jet Fuel
    • 001 = Crude
    • E00–E99 = Ethanol mixtures
    • B00–B99 = Biodiesel mixtures
    • Full list in the official instructions

Inventory Reconciliation (Part III): Beginning inventory + Receipts – Disbursements ± Gains/Losses = Ending physical inventory. Report gains/losses separately (losses in parentheses).

Signature: Must be signed under penalties of perjury by an authorized person.

Penalties for Failure to File or Incorrect Reporting

The IRS imposes penalties for:

  • Late filing
  • Incomplete or incorrect information (including wrong EINs)
  • Failure to file electronically when required

Reasonable cause may waive penalties, but proper recordkeeping (retain records for at least 3 years) is essential.

  • Form 720 — Quarterly Federal Excise Tax Return (for actual tax liability)
  • Form 720-CS — Carrier Summary Report
  • Form 637 — Application for Registration (excise tax activities)
  • Form SS-4 — EIN application
  • IRS Terminal Locations Directory (for TCNs)
  • ExSTARS Help Desk: 859-320-4091

Official Downloads (Direct from IRS.gov):

Common Questions About Form 720-TO

“Do I need to file even if my terminal had no activity?”
Yes — report zero transactions if required.

“Can I summarize small transactions?”
Yes, for specific low-volume Product Codes using the “CE” summary option.

“What if I need to correct a previously filed report?”
File a corrected paper return with “Void” and “Corrected” copies, or follow electronic correction procedures in Pub. 3536.

Stay Compliant in 2026 and Beyond

Accurate Form 720-TO reporting protects your business from penalties and supports the integrity of the U.S. fuel excise tax system. Terminal operators should:

  1. Confirm their TCN and Form 637 registration status
  2. Implement robust inventory tracking systems
  3. Enroll in ExSTARS if they exceed the 25-transaction threshold
  4. Consult the latest instructions before each filing

For the most current information, always visit the official IRS pages:

Need help? Contact the ExSTARS Help Desk or a qualified excise tax professional. Proper filing ensures smooth operations for your terminal business.

This guide is for informational purposes only and is based on current IRS publications as of February 2026. Tax rules can change — verify all requirements directly with IRS.gov before filing.