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Part 4. Examining Process

Chapter 75. Exempt Organizations Examination Procedures

Section 16. Case Closing Procedures

4.75.16  Case Closing Procedures

4.75.16.1  (05-13-2003)
Introduction

  1. This IRM contains specific procedures for exempt organization group managers and examiners on how to properly close a completed examination. It also includes guidelines for preparing the closing documents and assembling the case file.

4.75.16.2  (05-13-2003)
Pre-closing Review of Case File by Examiner

  1. The examiner should review the workpapers and reports for completeness and accuracy before closing the case to the group manager. The examiner's review should include, but not be limited to, answering the following questions.

    1. Does the report of examination and/or closing letter contain grammatical, spelling or typographical errors?

      Note:

      The examiner can usually eliminate grammatical, spelling and typographical errors just by proofreading the entire report of examination and/or closing letter after they are completed.

    2. If a Form 5666, TE/GE Referral Information Report, has been prepared for a subsequent year examination, have copies of all workpapers that would assist the subsequent examiner been attached to the Form 5666?

    3. Have all of the items in the heading of Form 5772, EO Workpaper Summary, been completed correctly?

      Reminder:

      The examiner should verify that the total hours shown on the Form 5772, EO Workpaper Summary, agree with the time on the Form 5464, Case Chronology Record; Form(s) 5599, TE/GE Examined Closing Record; and Form 6490, TE/GE Technical Time Report. If the Form 5772 is prepared using a workcenter, the time may be incorrect if the Form 5772 was printed before all work was completed on the case. The correct time may be annotated by hand on the Form 5772 or the time corrected in the workcenter and the Form 5772 reprinted.

      Exception:

      The disposal codes and descriptions and letter number will be entered by the reviewer in unagreed cases.

    4. Do the conclusions on the Form 5773, TEGE Workpaper Summary Continuation Sheet, agree with the conclusions in the workpapers and reports of examination or closing letter? Discrepancies between the conclusions on the Form 5773 and the conclusions in the supplemental workpapers, the report of examination, and/or closing letter can occur when an initial conclusion entered on the Form 5773 is subsequently found to be incorrect and the comments on the Form 5773 are not revised to reflect the final conclusion. Errors of this type can be easily prevented if the examiner reviews the conclusions on the Form 5773 and the conclusions in the supplemental workpapers, report of examination, and closing letter before the case is closed. If the workpapers have been printed, the corrections may be handwritten.

      Example:

      The examiner initially concluded the receipts from Clark, Inc. the corporation that published the organization's journal were unrelated business income from paid advertising. This conclusion was entered on the Form 5773 before the closing conference. At the closing conference the organization provided the examiner with additional documents proving the receipts from Clark, Inc. were royalties and therefore, were not taxable as unrelated business income. A no change letter was issued. The Form 5773 was not updated after the closing conference. Therefore, when the case was closed, the conclusions on the Form 5773 did not agree with the closing letter or the workpapers since the conclusions on the Form 5773 continue to state the receipts from the journal were unrelated business income.

      Example:

      The examiner's initial computation of unrelated business income did not include mailing expenses related to the unrelated business income. The error was discovered and the report of examination and agreement form were corrected but the examiner did not update the initial computation in the workpapers or note that it had been superseded. Therefore, the conclusions in the workpapers did not agree with the report of examination. This error may result in unnecessary time being expended by the group manager or reviewer during case reviews because he/she must determine which computation is correct.

    5. Has Form 5774, Private Foundation Workpapers, been prepared and completed correctly if applicable?

    6. Are ALL of the workpapers organized in a logical manner and indexed?

    7. Are all workpapers labeled with the taxpayer's name, title of the workpaper, the date completed and the examiner's initials?

      Exception:

      If a workpaper contains multiple pages, the label may be entered on the first page only. When the label is entered on the first page only, the total number of pages must be entered, e.g., Analysis of Entertainment Expenses, 3 pages.

    8. Are all workpapers legible?

    9. Is the purpose of and conclusions drawn from each workpaper or group of workpapers clear?

      Note:

      If copies of the taxpayer's records are secured and placed in the workpapers, it is imperative that the reason for inclusion be noted on the copies or on a coversheet preceding the copies.

      Caution:

      If original documents or copies of documents are related to an issue that may be litigated, any notations should be entered on a duplicate copy of the document made for this purpose, a workpaper, or a coversheet rather than on the original document or the original copy of the document.

    10. Have all unnecessary or duplicate workpapers been purged? The agent is responsible for disposing of any reports and/or workpapers which are no longer needed prior to submitting the case to the group manager for closing.

      Caution:

      Workpaper and reports that were provided to the taxpayer during the examination should not be purged. If the workpaper or report is changed, the original workpaper or report should be annotated in the top margin with a comment such as, "Superseded by Workpaper C14" or "Superseded by Report Dated 12/2/2003" in bold letters.

      Caution:

      If the case involves a declaratory judgment issue, the examiner should refer to IRM 4.75.32, Declaratory Judgment and Administrative Record, before defacing or destroying any original documents or copies of documents provided to the examiner by the organization.

    11. Does the Case Chronology Record reflect complete and accurate documentation of the case history including the dates follow-ups were scheduled?

    12. Have all of the group manager's actions on the case been documented in the Case Chronology Record and initialed by the group manager?

      Note:

      If the group manager's actions have been documented but have not been initialed, the examiner should flag the entries that require the group manager's initials with a post-it note or as otherwise instructed.

4.75.16.3  (05-13-2003)
Statute Control Procedures

  1. The group manager will ensure agreed cases have at least 180 days remaining on the statute of limitations and unagreed cases have 270 days remaining, when they are closed from the group.

    Note:

    All examination cases involving revocation or modification of exempt status or reclassification of foundation status are considered unagreed for statute control purposes.

  2. All cases, including related cases, submitted for technical advice must have one year remaining on the statute of limitations before being sent to EO Mandatory Review for processing.

  3. The group manager will prepare a memo providing an explanation for all cases submitted with less than the required time frames remaining on the statute of limitations and attach to the case file.

  4. All cases with less than 8 months (270 days) on the statutory period will be placed in a red folder. If the statute expiration is subsequently extended to a period greater than 8 months the case should be removed from the red folder.

  5. For any case being transferred between locations/areas, closed to EO Examinations Special Support Unit (ESS), or closed to Mandatory Review with less than 60 days remaining on the statute, the group manager must notify the receiving manager of the transfer by telephone. This should be done with the knowledge and concurrence of the respective Area Manager. The group manager will hand carry, use overnight mail, or an express delivery service to ship the case to the receiving group. The group manager will follow-up to ensure the case is received timely.

4.75.16.4  (05-13-2003)
Guidelines for Timely Closing Cases

  1. Examinations should generally be closed within the national established time-frames. Any delays or extended periods of inactivity must be adequately documented on the Case Chronology Record.

  2. The established time-frames for closing cases are as follows:

    1. Ten (10) calendar days for the examiner to close agreed or no-change examinations. The 10 days start the date the no-change determination is made, usually the date of last taxpayer contact when the examiner discusses the examination results with the taxpayer.

    2. Twenty (20) calendar days for examiner to close unagreed examinations. The 20 days start the date of final closing conference or the date a closing conference was declined.

    3. Ten (10) calendar days for the manager to initial and date the case chronology after receipt from the examiner.

  3. The case chronology should reflect the date the case is closed by the examiner and the date the manager approves the case for closing.

4.75.16.5  (05-13-2003)
Preparing AIMS Closing Documents

  1. The examiner is responsible for preparing the appropriate form to close an examination case off the Automated Information Management System (AIMS) Master File (MF) or Non-master File (NMF).

  2. The following forms are used to close EO accounts off AIMS:

    1. Form 5599, TE/GE Examined Closing Record

    2. Form 4881, Chapter 42 Taxes-Disqualified Person/Foundation Manager

    3. Form 5596, EO Non-Examined Closings

4.75.16.5.1  (05-13-2003)
Form 5599, TE/GE Examined Closing Record

  1. The Form 5599, TE/GE Examined Closing Record, is used for closing examined returns and surveyed claims off AIMS at the close of the examination. The form is used to close both master file and non-master file accounts and is also used to update the BMF, Business Master File, with assessment and closing information. The examiner is responsible for entering certain information on the Form 5599. In most cases, this requires determining the correct disposal code. Refer to Exhibit 4.75.16-1, Form 5599 - Required Entries and Instructions for Completion, for instructions on completing the Form 5599.

4.75.16.5.1.1  (05-13-2003)
Disposal Codes

  1. The examiner is generally required to determine the correct disposal code and enter the two-digit number on the appropriate line of the Form 5599. The exception is for unagreed examinations. In these cases, the Review Staff will enter the correct code. For assistance in determining the correct disposal code, examiners should refer to Document 6379, Exempt Organizations Management Information Systems Codes - Quick Reference for EO Employees. This booklet is published at the beginning of each fiscal year. Since codes may change, examiners should refer to the current version of the booklet to ensure the correct code is used.

  2. AIMS closing procedures allow for one disposal code that best describes the principal examination result. In cases involving multiple issues, the examiner should determine which one has the highest priority. A list of disposal codes by priority can be found in Document 6379.

  3. Tax change disposal codes would take precedence over disposal codes involving advisory and notification letters.

  4. Related returns being examined simultaneously will normally be considered separately and closed with the disposal code appropriate for the results of each return. The exception to this would be for an examination resulting in no changes to the primary return, but where there is an adjustment or delinquency issue associated with a related return. In this case, the appropriate disposal code for the primary return would be 04, Changes to Related Return; or 05, Delinquent Related Return Secured.

4.75.16.5.2  (05-13-2003)
Form 5596, EO Non-Examined Closings

  1. The Form 5596, EO Non-Examined Closings, is used to close non-examined BMF or NMF accounts (except surveyed claims) off AIMS. Instructions for completing the form can be found in IRM Handbook 7.3.1 Chapter 2 Exhibit 7.3.1.2-29.

    Note:

    IRM Handbook 7.3.1 Chapter 2 has been revised and will be reissued as IRM 4.5.1, TEGE AIMS Processing.

4.75.16.5.3  (05-13-2003)
Deleting AIMS Accounts

  1. In cases where an AIMS/BMF account or an AIMS/NMF account has been established in error, the examiner will use the following procedures to delete the account on the AIMS database.

    Note:

    A RICS printed return is not a filed return for purposes of these instructions. Thus, a RICS return established in error when the filed return has NOT been secured may be deleted by following these instructions.

    Caution:

    If Area has possession of the filed return, these procedures can NOT be used to delete an AIMS/BMF account. In these cases the group manager or examiner will close the AIMS account using one of the following disposal codes.

    Disposal Code Description
    31 Survey Before Assignment
    32 Survey After Assignment
    36 Survey After Initial Contact

    1. The group manager or examiner will prepare a Form 5596, TEGE Non-Examined Closing. Disposal Code 33, Error Accounts with no Returns, will be entered to delete BMF accounts and Disposal Code 99, Information Report and Miscellaneous, will be entered to delete NMF accounts.

    2. Form 10904, Request for Record Deletion from AIMS, should be prepared and approved by the Area Manager. If the account is in status 12 or above, the examiner should include a statement regarding taxpayer contact on Form 10904.

  2. If contact has been made with the taxpayer, the examiner will prepare a letter advising the taxpayer their return(s) or books and records (if no return is due or filed) are not going to be examined at this time. The letter must contain statement, "Do not consider this as an examination that resulted in no change to your tax liabilities or your status status. You were not examined for these years."

  3. Approved deletion requests should be forwarded to:

    Internal Revenue Service
    TEGE:EO:E:PR:SS
    MC 4910 DAL
    1100 Commerce Street
    Dallas, TX 75242

4.75.16.6  (05-13-2003)
Preparing Other Case Closing Documents

  1. The examiner may be required to complete other documents to ensure proper processing of the case by ESS and/or EO Mandatory Review function. These include:

    • Form 2363-A, Request for IDRS, Integrated Data Retrieval System, Input for BMF-EO Entity Change

    • Form 3198, Special Handling Notice

    • Form 5666, TE/GE Referral Information Report

    • Form 4760, Processing Record for Agreed Unpaid Deficiency Cases Requiring Prompt Assessment or Overassessment

4.75.16.6.1  (05-13-2003)
Form 2363-A, Request for IDRS Input for BMF-EO Entity Change

  1. The Form 2363-A, Request for IDRS Input for BMF-EO Entity Change, is used to establish or change EO accounts on the Business Master File. For instructions on completing the Form 2363-A examiners should refer to Exhibits 4.75.16-2, Form 2363-A Required Input, and 4.75.16-3, Instructions for Completion of Form 2363-A, for a quick guide to completing Form 2363-A, or IRM 25.7.2, EO/BMF Processing Procedures, for detailed instructions.

  2. Examiners conducting an examination of an exempt organization should complete a Form 2363-A to reflect any changes resulting from the examination. Additionally, any errors identified on a Master File entity during the examination should also be corrected using the Form 2363-A.

  3. Generally, the examiner should submit Forms 2363-A to the ESS Unit as soon as the need for a change is identified. The exception to the general rule is when the change is subject to Mandatory Review.

  4. Some common changes requiring the preparation of a Form 2363-A and the disposition of the Form 2363-A are as follows:

    For Submit the Form 2363-A
    A Name and/or Address Change Immediately.
    An Exempt Status Change With the case file.
    A Foundation Status Classification Modification With the case file.
    A Filing Requirement Change  
      Delinquent Return Secured Immediately.
      Contested Filing Requirement With the case file.
    NTEE Immediately.

  5. Forms 2363-A to be processed immediately should be mailed to the ESS Unit at the following address:

    Internal Revenue Service
    TEGE:EO:E:PR:SS
    MC 4910 DAL
    1100 Commerce Street
    Dallas, TX 75242

  6. Retained copies of Forms 2363-A submitted to ESS before the case is closed should be placed in the workpapers and labeled "Copy - Original Mailed to ESS on Date."

  7. If Forms 2363-A to be processed are enclosed in the case file, a Special Handling Notice should be prepared with "Form 2363-A to be Processed " entered in the "Special Instructions" section. The examiner will not complete the initials and date section in " Special Instructions."

    Note:

    Mandatory Review will complete these items or destroy the Special Handling Notice and Form 2363-A, as appropriate.

4.75.16.6.2  (05-13-2003)
Form 3198, Special Handling Notice

  1. A Form 3198, Special Handling Notice, should be attached to any case file requiring special handling.

  2. The following items should be appropriately noted on Form 3198:

    1. Cases subject to mandatory review,

    2. Cases that include a Form 2363-A to be processed,

    3. Cases closed based on an organization's retained copy of a return,

    4. Cases where an amended return was received directly from the taxpayer during the examination,

    5. Power of Attorney instructions,

    6. Discrepancy adjustments cases,

    7. Restricted interest cases,

    8. Unagreed and agreed cases with less than 8 months on the statute of limitations,

    9. Instructions for notification of state officials,

      Note:

      See IRM 4.75.21, Special EO Examination Procedures, (to be published the 2nd quarter of 2003.

    10. Related case files,

      Note:

      See IRM 4.75.16.8, Processing Related Returns.

    11. Any other special instructions regarding the case that may be helpful in the closing process.

4.75.16.6.3  (05-13-2003)
Form 4881, Chapter 42 Taxes - Disqualified Person/Foundation Manager

  1. Form 4881 is a manually processed assessment and accounting document used in conjunction with Form 5599 for all cases involving the assessment of Chapter 42 taxes on a disqualified person or foundation manager.

  2. A separate form is prepared for each tax period and person for which there is an assessment of Chapter 42 taxes.

  3. For instructions on preparing Form 4881, Chapter 42 Taxes-Disqualified Person/Foundation Manager, see Exhibit 4.75.16-4.

4.75.16.6.4  (05-13-2003)
Form 5666, TE/GE Referral Information Report

  1. Form 5666, TE/GE Referral Information Report, is used as an information notice and for recommending a future year examination. The general instructions for completing a Form 5666 are on the back of the form. Detailed instructions are included in IRM Handbook 7.3.1 Chapter 2 Exhibit 7.3.1.2-25.

    Note:

    IRM Handbook 7.3.1 Chapter 2 has been revised and will be reissued as IRM 4.5.1, TEGE AIMS Processing.

  2. The Form 5666 is also used to transmit information disclosed during the examination of an exempt organization to other operating units within the Service.

  3. All Forms 5666 should be forwarded to EO Classification. The name and telephone number do not need to be entered in Item 16, Forward Report to Name/Date/Organization/Telephone Number, since all Forms 5666 now go to EO Classification in Dallas. Item 16 should be include the following information:

    1. EO Classification MC 4910 DAL and

    2. Current Date

      Exception:

      If the case is subject to Mandatory Review, the examiner will not enter the current date The current date will be entered by the reviewer.

  4. Form 5666 will be placed in the case folders. See IRM 4.75.16.12, Case File Assembly.

4.75.16.6.4.1  (05-13-2003)
Future Year Information Report

  1. The examiner should prepare a Form 5666 in cases where a subsequent year examination is warranted due to certain activities or operations disclosed during the examination that could jeopardize the organization's exempt status.

  2. If the case involves a tax liability which extends beyond the taxable years covered by the examination report and into a taxable period for which a return is not yet due, the examiner will prepare a Form 5666 recommending a future year examination to ensure compliance.

4.75.16.6.4.2  (05-13-2003)
Referral Revocation Cases

  1. Form 5666 will be prepared in all cases involving revocations except the revocation of a private foundation. It will be prepared by the EO examiner prior to submitting the case to Mandatory Review.

    Note:

    A referral is not made in cases involving the revocation of a private foundation because EO Examinations has examination jurisdiction over taxable returns, e.g. Forms 1120, filed by a revoked private foundation.

    Note:

    The Form 5666 will remain in the case file until a final determination is made. If the revocation is sustained, the Mandatory Reviewer or Appeals Officer will date Form 5666 and route it to EO Classification. If the revocation is not sustained, the Mandatory Reviewer or Appeals Office will destroy the Form 5666 and attachments.

  2. The Form 5666 will recommend examination for either the first year in which the organization is a taxable entity or for an appropriate subsequent year. Information submitted with the Form 5666 will include the following information:

    1. A statement that the organization's exemption has been revoked.

    2. The effective date of the revocation action.

    3. The date the organization was incorporated. If the organization is an unincorporated association, the date the association was formed.

    4. A statement that, as a taxable entity, the organization should be reporting any income, employment and excise taxes for which it may be liable.

    5. A list of the taxable returns secured by the examiner, including the form number, MFT and the tax period and a statement that the original returns are being processed by EO Examinations.

    6. A statement that contributions to the organization are no longer deductible as charitable contributions, if applicable.

    7. The effective date after which contributions are no longer deductible as charitable contributions, if known.

    8. If discrepancy adjustments have not been proposed, list the names and social security numbers or employer identification numbers of contributors who will not be able to deduct contributions made before the revocation is/was published in the Internal Revenue Bulletin.

      Note:

      A contributor can not deduct contributions prior to the date an announcement is published in the Internal Revenue Bulletin, if the contributor: 1. had knowledge of the revocation of the ruling or determination letter, 2. was aware that such revocation was imminent, or 3. was in part responsible for, or was aware of, the activities or deficiencies on the part of the organization which gave rise to the revocation. See Treas. Reg. §1.509(a)-7(a) and Rev Proc 82-39, 1982-2 C.B.

  3. The following documents will be attached to the Form 5666:

    1. A copy of the Report of Examination in agreed IRC 501(c)(other) cases.

      Note:

      In agreed cases, the Mandatory Reviewer will attach a copy of the letter transmitting the report to the taxpayer. In unagreed cases, the Reviewer or Appeals Office will attach the revocation letter or conference report after a final determination is made.

    2. A copy of the exempt organization returns being converted, e.g., Form 990.

    3. A copy of any taxable returns which have been obtained.

    4. If no taxable return has been obtained because the organization did not submit appropriate returns as requested by the EO examiner, or because the conversion of the Form 990 to Form 1120 or Form 1041 is complex and requires the expertise of income tax examiners, a statement to that effect and a recommendation that the return be secured by LMSB or SBSE.

    5. Any pertinent financial or other information or documents.

4.75.16.6.4.3  (05-13-2003)
Referral Other Issues

  1. If information is discovered during the examination of an exempt organization that will effect the tax liability of individual or taxable entity and the issue can not be addressed using discrepancy adjustment procedures, the examiner will prepare a Form 5666.

4.75.16.6.5  (05-13-2003)
Form 4760, Processing Record for Agreed Unpaid Deficiency Cases Requiring Prompt Assessment or Overassessment

  1. Quick assessment procedures must be used to process unpaid, agreed deficiency cases of $50,000 or more. Agreed deficiency cases of $50,000 and over must be manually assessed within twenty-two (22) calendar days of the received date of the signed agreement form.

    Note:

    The term "deficiency " refers to the sum of all deficiencies and penalties for any one taxpayer, for all tax periods in the case file, without regard to any offsetting overassessment.

  2. Examiners must complete the Form 4760; Processing Record for Agreed Unpaid Deficiency Cases Requiring Prompt Assessment or Overassessment, for all cases with agreed unpaid deficiencies or overassessments of $50,000 or more. These forms may also be used for agreed unpaid deficiencies or overassessments of $10,000 or more. The Form 4760 is attached to the front of the case file. Each employee handling the case must initial the Form 4760 and record the date they handled the case. If the examiner encounters delays in transmitting the case to the next processing level, he/she must record the reason on the Case Chronology Record.

4.75.16.7  (05-13-2003)
Processing Restricted Interest Cases

  1. When a case involves restricted interest, the examiner does not solicit the interest due during the examination. If the taxpayer desires to make full payment of the balance due, the examiner will notate on the Form 3198 that the restricted interest computation is to be provided to the examiner. At closing ESS will provide the interest computation to the examiner. The examiner will then contact the taxpayer and solicit payment of the interest.

4.75.16.8  (05-13-2003)
Processing Related Returns

  1. Related cases should generally be closed simultaneously with the primary return.

  2. A Form 3198, Special Handling Notice, should be attached to each case folder.

    1. The primary case file should list the: 1. Name, 2. EIN/SSN, 3. MFT, and 4. Tax year for all related cases under the box for "Name" . If additional space is required the examiner should attach a separate list and annotate the Form 3198 "RELATED CASES - See Attached List " in the space under the box for name

    2. All case files, both primary and related, should include the following statement in red ink at the top of the Form 3198: "MULTIPLE RETURNS/CASE FOLDERS INVOLVED - DO NOT SEPARATE."

  3. The examiner should include in the primary case file, copies of all materials necessary to document any adjustment(s) proposed in related case file(s).

  4. The examiner may consider closing related cases separately, where issues are not interrelated and separate closing(s) would avoid long delays in processing no-change or agreed cases. If cases are separated, a notation should be made on each Case Chronology Record indicating the reason and managerial approval for doing so.

4.75.16.9  (05-13-2003)
Closing Cases on a Copy of Return

  1. An examiner closing a case without the original return must secure an exact duplicate of the organization's retained copy or a BTVU/RTVUE print. A Form 3198 should identify the case file as being closed based on a retained copy or a BTVU/RTVUE print.

  2. If a copy of the return is being used to close the case, the examiner should annotate in bold red print the words "Copy of Filed Return Secured by EO" in the upper margin on the face of the copy of the return.

  3. If a BRTVU/RTVUE is being used to close the case, the examiner should annotate in red at the top of the print "BRTVU/RTVUE Print Used by EO" .

  4. The examiner should verify tax payments and credits claimed on the return. A transcript should be secured if necessary to determine the true liability.

4.75.16.10  (05-13-2003)
Processing Suspense Cases

  1. Case files requiring suspension of action will normally be held in Dallas by Mandatory Review until action on the case can resume. These will include, but are not limited to, technical advice cases and Section 1254 suspense cases.

  2. Before forwarding a suspense case to Review, it will be the group’s responsibility to insure the statute is protected for at least one year. Upon receipt in Review, it will be Review’s responsibility to secure any further extensions to the statutes. Review will also secure extensions on subsequent years if there is a continuing issue.

  3. Technical Assistance cases will be maintained in the groups. The group should forward a copy of the technical assistance memorandum to Review for information and follow up purposes.

4.75.16.11  (05-13-2003)
Updating the Determination File

  1. If the examiner secures information to update the Determination File, microfiche, he/she should:

    1. Complete the "Documents to be Added to Determination File/Microfiche " cover sheet as shown in Exhibit 4.75.16-5.

    2. Attach to the form information to be added to the determination file.

    3. Send form and attachments to the following address:

    Internal Revenue Service
    Records Unit - Room 4010
    P.O. Box 2508
    Cincinnati, OH 45201

    Note:

    The date the cover sheet and the documents were mailed to the Records Unit should be noted on the Case Chronology Record.

  2. Additions to the determination file include:

    • Information pertaining to a name change (amended articles of organization, e.g. Articles of Incorporation or Articles of Association.)

    • Address change

    • Other amendments

    • Changes to the determination letter or foundation status

    • Changes to activities

    • Information on termination of the organization

    • Any other information the examiner determines should be added to the determination file that will assist subsequent examiners

  3. The examiner will document in the case file the records secured and the date forwarded to the Records Unit. In cases where the information is needed to document an issue, a file copy of the forwarded records should be retained and included in the workpapers.

4.75.16.12  (05-13-2003)
Case File Assembly

  1. Because further technical, administrative and procedural action is sometimes required on a case after being closed from the examiner's inventory, it is important the file be properly organized. This will assist group managers, reviewers, conferees, processing clerks and others who may subsequently become involved with the case.

  2. Adherence to this IRM will provide a uniform presentation to the next level. Guidelines for assembling most forms used in examinations are provided in this section. Each form, report or document listed will not be required in every case. While this listing is not all-inclusive, it will cover most situations. For less commonly used forms, not addressed here, examiners should use their judgment in determining where to place a particular document. Minor variances from the IRM may be necessary in unusual situations.

  3. The examiner is responsible for properly assembling the case file and purging all unnecessary documents, including duplicate letters, envelopes, routing slips, etc. Examiners should not purge items relating to the audit trail such as IDRS prints of AMDIS, INOLES, and BMFOLI. Once the files are properly assembled, they will be maintained in this manner throughout the closing process.

  4. The examiner should adequately index all supporting documentation in the case file to the Form 5772, 5773 and 5774. Any indexing system is acceptable, so long as it allows anyone unfamiliar with the case to easily locate workpapers and other important documents in the file.

  5. Refer to Exhibit 4.75.16-6 for a diagram illustrating case file assembly.

4.75.16.12.1  (05-13-2003)
Case Folders

  1. A separate folder will be used for each type of return and taxpayer. Multiple years of the same return for one taxpayer should be placed in one folder.

    Example:

    In an examination of the 200012 and 200112 Forms 990, Return of Organization Exempt from Income Tax, and 990-T, Exempt Organization Business Income Tax Return, there would be two folders, one for the 200012 and 200112 Forms 990 and another for the 200012 and 200112 Forms 990-T.

  2. The administrative record will be placed in a separate folder.

  3. The examiner should include in the primary case file, copies of all materials necessary to document any adjustment(s) proposed in related case file(s).

  4. In most cases, brown folders will be used. Red folders are used on all cases with less than eight months remaining on the statute of limitations. Additionally, special project cases may be placed in a colored folder.

  5. Large case files may require more than one folder or may be placed in expanding folders. All folders should be labeled with the organization's name, EIN, type of return, and year. Multiple folders should be numbered in consecutive order. The number of file folders should be indicated on the Form 3210 prepared to transmit the case for closing.

  6. In examinations involving multiple case folders, it is important to ensure all case folders remain together throughout the closing process. A Form 3198 should be attached to each case folder with the following statement in large red letters "Multiple Returns/Case Folders Involved - DO NOT SEPARATE" . For additional requirements, refer to section 4.75.16.7.

4.75.16.12.2  (05-13-2003)
Forms Attached to Outside of Folder

  1. Forms and documents assisting in the processing and closing of the case should be attached to the outside of the case folder, top to bottom, as follows.

    1. Form 895, Notice of Statute Expiration, Parts I and II.

    2. Document 6441, This Document Requires Protection. This document is a special cover sheet for cases requiring protection.

      Note:

      Document 6441 is a cover sheet to alert others to the sensitive nature of the information.

    3. Form 3198, Special Handling Notice.

    4. EO Church Approvals Coversheet

    5. Form 5456, Reviewers Memorandum.

    6. Form 5457, Response to Reviewers Memorandum.

    7. Document 6077, Deficiency/Overassessment Case $50,000 or More. This document is affixed to a case folder to flag a $50,000 or more agreed case, which requires expeditious processing.

    8. Document 6078, Deficiency/Overassessment Case $10,000-$49,000. This document is affixed to a case folder to flag a $10,000 to $49,000 agreed case, which requires expeditious processing.

    9. Form 4760, Processing Record - Agreed Unpaid Deficiency Cases Requiring Prompt Assessment.

    10. Form 5599, TEGE Examined Closing Record.

4.75.16.12.3  (05-13-2003)
Forms Attached to Left Inside of Case Folder

  1. The following forms and disks should be attached to the inside left of the case folder, top to bottom, as follows:

    1. Form 5666, TE/GE Referral Information Report, and attachments.

    2. Form 2363-A, Request for IDRS Input for BMF/EO Entity Change, to be processed;

      Note:

      Form 2363-A for unagreed revocations or modifications which should not be processed prior to an Appeals' decision should be placed in a "To be opened by addressee only" envelope. The envelope should be annotated with a statement such as: "Form 2363-A to be processed if revocation is upheld. If revocation is not upheld, please shred."

    3. Form 4881, Chapter 42 Taxes-Disqualified Person/Foundation Manager;

    4. AIMS Update Forms;

    5. Computer disk Enclose the examination computer disks in an envelope or disk sleeve and staple the envelope or disk sleeve to the left hand side of the folder.

      Caution:

      The computer disks must be enclosed with all cases files including no-change, no-change advisory cases, agreed tax change, agreed status change and all unagreed cases.

4.75.16.12.4  (05-13-2003)
Returns, Forms, and Other Documents Enclosed in the Case File

  1. In order to create a well organized professional appearing case file, the forms, reports of examination, workpapers and other documents in the case file should be arranged in packages (groups). The packages should be clipped or stapled together and placed inside the folder as follows, top to bottom.

  2. Confidential Information Enclose referrals, informants' reports, and other confidential information in a "To be Opened by Addressee Only" envelope with a Document 6441, This Document Requires Protection, stapled to the front of the envelope.

  3. Form 872-T, Notice of Termination of Special Consent to Extend Time to Assess, if initiated by the Service.

  4. Waiver and Acceptance Form(s) and Closing Agreement including but not limited to:

    • Form 6018, Consent to Proposed Adverse Action;

    • Form 870, Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment;

    • Form 2297, Waiver of Statutory Notification of Claim Disallowance;

    • Form 3363, Acceptance of Proposed Disallowance of Claim for Refund or Credit;

    • Form 2504, Agreement to Assessment and Collection of Additional Tax and Acceptance of Overassessment;

    • Form 4549, Income Tax Examination Changes;

    • Form 4549-E, Income Tax Discrepancy Adjustments; and/or

    • Closing Agreement on Final Determination Covering Specific Matters.

  5. Closing Letters original and copies of the closing letters to be dated and/or mailed by ESS or Review Staff.

    Note:

    Copies should be annotated, "File Copy" , in the top margin.

  6. Form 4620, Transmittal Letter - Exempt Organization;

  7. Report of Examination: copies and/or original agreed or unagreed report of examination. The report of examination includes the following forms, schedules, and documents as necessary:

    1. Form 4621, Exempt Organizations - Report of Examination

    2. Form 4549, Income Tax Examination Changes

    3. Form 4667, Examination Changes - Federal Unemployment Tax

    4. Form 4668, Employment Tax Examination Changes Report

    5. Forms 886-A; Explanation of Items

    6. Exhibits

    7. Schedules

    8. Other documents included in the Report of Examination as an attachments

    Note:

    File copies should be annotated, " File Copy" , in the top margin.

  8. Returns, including taxpayer copies, BRTVU or RTVUE prints, substitute and dummy returns, with the latest year's return on top.

    Caution:

    RICS returns can no longer be used to close a case. A BRTVU OR RTVUE print out should be secured.

    Note:

    A dummy return, Form 990, is used to close examinations of organizations that are not required to file Form 990.

    Note:

    The returns referenced here are the returns being used to close the case. Copies of returns or RICS returns that are not being used to close the case should be purged or placed in the supplemental workpapers. If a case is assigned with a RICS return and the original is received before the case is closed, the RICS should always be placed in the supplemental workpapers because it may be needed for a TEQMS review.

  9. Converted Return Package to be processed after the primary return has closed off AIMS, e.g., Forms 990 converted to Forms 1120 as a result of a revocation.

    Note:

    Enclose the converted returns in a "To be Opened by Addressee Only" envelope. Enter instructions, e.g., "Converted Returns Forms 1120 to be processed after Forms 990 are closed off AIMS" in the special instructions section of Form 3198. Staple the Form 3198 to the envelope.

  10. Workpapers including:

    1. Form 5772, EP/EO Workpaper Summary;

    2. Form 5773, EP/EO Workpaper Summary Continuation Sheet;

    3. Form 5774, Private Foundation Workpapers;

    4. Form 5464, Case Chronology Record;

    5. Supplemental workpapers including but not limited to examiner prepared transcripts of interviews, schedules, and analysis of financial records and copies of documents secured from the taxpayer;

      Note:

      The case file for the primary return should include information necessary to support adjustments made to related returns. The workpapers, including Forms 5772 and 5773, for any related cases need only address the issues relating to these returns. For example the case file for a Form 990-T, related to the examination of a Form 990, would generally only need to address the unrelated business issues.

    6. Correspondence with the taxpayer;

    7. Information Document Requests;

    8. Prior Examination Reports;

    9. Copies of reports of examination of related returns; and

      Note:

      Copies of reports from examinations of related returns need only be included in the case folder for the primary return. The copies should be labeled " Copy" in the top margin of the first page of each report.

    10. Miscellaneous documents, e.g., printouts of IDRS research, RICS returns if the case is closed on an original return, etc.

    Note:

    If the workpapers consist of more than one hundred (100) pages, the pages should be Acco fastened together. Acco fastening is optional for smaller cases.

4.75.16.13  (05-13-2003)
Documents Attached to the Return

  1. The following forms should be stapled to the front of the return, top to bottom:

    • Current AMDISA print

    • Form 3244-A, Payment Posting Voucher, stapled to face of return

    • Copy of Check

    • Form 4571, Explanation for Filing Late or Paying Tax Late, if applicable

  2. Form 2848, Power of Attorney and Declaration of Representative, should be stapled to the back of the first page of the return.

  3. The following forms should be stapled to the back of the last page of the return, top to bottom, facing out:

    • Form 872, Consent to Extend the Time to Assess Tax

    • Form 56, Notice of Fiduciary Relationship

    • Form 8821, Tax Information Authorization

    • Form 5546, Examination Return Charge Out, or if not available an AMDIS print

    • Amended returns, Forms 843, Claim for Refund; Form 1045, Application for Tentative Refund or Form 1139, Corporation Application for Tentative Refund.

      Note:

      If the amended return was received directly from the taxpayer during the examination, this should be noted on the Form 3198, Special Handling Notice, attached to the front of the return file.

  4. Refer to Exhibit 4.75.16-7.

4.75.16.14  (05-13-2003)
Group Manager Responsibilities

  1. All completed case files must be sent through the group manager for closing. For cases requiring action by another group or area before final closing, the group manager should first contact the other group or area and then update the status before forwarding the case.

  2. The group manager will ensure the final case grade is accurate and approve the case for closing. The manager should indicate his/her approval by initialing and dating the bottom of the Case Chronology Record.

  3. IRC § 6751 requires written documentation of the manager's involvement in any decision to assess most penalties. The written documentation can be included on the Case Chronology Record. Exception: The following penalties do not require managerial approval:

    • IRC Section 6651, Failure to File or Failure to Pay - except where fraud is involved

    • IRC Section 6654, Failure to Pay Estimated Tax for Individuals

    • IRC Section 6655, Failure to Pay Estimated Tax for Corporations

    • Any other penalties automatically calculated through electronic means

4.75.16.15  (05-13-2003)
AIMS/EOIC Group Processing Responsibilities

  1. At the time a case is closed, the group will query IDRS using the AMDISA command code to ensure each return being closed has been placed in status 12. If a return is not in status 12, the return will be updated to 12 using the AMSTU command code.

  2. A return being closed to Review should be updated to status 52 using the AMSTU command code. All other cases, except for Project Code 011, Referral/Information Report; referred to in Item (3) below should be updated to status 53.

  3. Cases having a Project Code 011, Referral/Information Report, which are not subject to review must be closed to the Classification Unit. The case should be updated on AIMS to Status 60 and on EOIC to EO CLASS7. These cases should have cover sheets identifying them as referral cases. All other cases should be updated to status 53.

  4. An AMDISA print will be made for each return reflecting the appropriate status, 52, 53, or 60. The print will be stapled to the face of the return and should not be folded.

  5. The return(s) will be closed off EOIC using the close case screen. The grade of case reported on EOIC will be compared with the grade on the Form 5599. If the two do not agree, the case grade will be changed to the one indicated by the manager. The Form 5599 will be used to determine the disposal code and the number of hours spent by the examiner on the case.

  6. The returns and related workpapers will be sent to Review, AIMS Processing, or Classification based on manager direction or local procedures. The Form 3210 will be numbered consecutively as determined by the Group. Cases being closed to the various units should be indicate on EOIC the following:

    • Special Review - "REVS."

    • Mandatory Review - "REVM."

    • AIMS Processing/ESS - "APU#."

    • Classification - "CLA#."

    Note:

    The number for the appropriate AIMS Processing or Classification units is provided in the addresses on EOIC.

  7. Once the cases are closed off EOIC, the Form 3210 will be printed in triplicate. The forms should be signed and include the originator's telephone number. Two copies of the Form 3210 should be included with the closed cases and one copy maintained in the Group. When the acknowledgement copy of the Form 3210 is received in the Group, the copy previously maintained will be destroyed.

  8. The returns and related workpapers will be sent by overnight delivery service if directed by the Group Manager. Otherwise, the returns and related workpapers will be sent by U. S. Mail or other shipping.

4.75.16.16  (05-13-2003)
Mandatory Review Cases

  1. Cases involving the following issues are subject to mandatory review:

    1. Cases involving a proposed revocation of exempt status as an organization described in IRC § 501(c)(3) or IRC § 170(c)(2);

      Caution:

      Cases involving the modification of the exempt status of an organization described in IRC § 501(c)(3) or IRC § 170(c)(2) are not included in cases subject to mandatory review because the exempt status of an organization described in IRC § 501(c)(3) or IRC § 170(c)(2) CAN NOT BE MODIFIED. See IRM 4.75.13, Issue Development.

    2. Cases involving proposed modification of the foundation status classification of an organization where the issue is subject to a declaratory judgment under IRC § 7428(a)(1)(B);

      Note:

      This includes IRC § 4942(j)(3) private operating foundation classifications and reclassifications from one public charity status to another, e.g., classification from IRC §§ 509(a)(1) and 170(b)(1)(A)(vi) to IRC § 509(a)(2) or classification from IRC § 509(a)(1) and IRC § 170(b)(1)(A)(vi) to IRC § 509(a)(1) and IRC § 170(b)(1)(A)(ii).

    3. Cases involving modification or revocation of qualification for exempt status under sections other than IRC § 501(c)(3);

    4. Cases involving Requests for Technical Advice;

    5. Cases involving an inadequate records notice when Letter 978 (DO), Notice of Inadequate Records or Letter 979, Inadequate Records Notice has been issued.

    6. Cases involving a penalty under IRC §§ 6661, 6700, 6701 and 6702;

    7. Private foundation examination cases for which a determination letter under IRC § 4945(g) is to be issued;

    8. Health care organizations that are integrated delivery systems; hospitals where physician practices or physician facilities are purchased or compensation is based on net profits or earnings; hospital management service organizations; preferred provider organizations; physician hospital organizations; health maintenance organizations; and managed care purchasing organizations, i.e., organizations established by hospitals, employers, insurance companies, physician groups, and community representatives to fix health care rates and enroll participating employers;

    9. Unagreed cases;

    10. Installment agreement cases;

    11. All closed church tax inquiries and examination cases including inquiries and examinations that result in a no-change.

      Reminder:

      An "EO Church Approvals Coversheet" must be prepared and attached to the front of the case folder and accompany all EO church case submissions. See IRM 4.76.7, Church Tax Inquiries and Examinations - IRC Section 7611.

    12. Notices of deficiency for any IRC § 4958 tax arising from transactions between a disqualified person and a church.

4.75.16.16.1  (05-13-2003)
Forwarding Cases to Review

  1. A Form 3198, Special Handling Notice, must be completed and attached to the front of all cases identified for mandatory review.

  2. Examination cases in the groups that are subject to mandatory review will be sent to EO Mandatory Review at the following address:

    Internal Revenue Service
    TEGE:EO:E:PR:MR
    MC 4920 DAL
    1100 Commerce Street
    Dallas, TX 75243

  3. An EOIC generated Form 3210 must accompany all cases.

  4. All cases received in Review should have a minimum of 270 days left on the statute for unagreed cases and 180 days for agreed cases. Any cases with less time on the statute must be communicated to the Review Manager via a telephone call before forwarding to Review for action. This will include "No-Change" cases.

Exhibit 4.75.16-1  (05-13-2003)
Form 5599 - Required Entries and Instructions for Completion

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The following instructions are for the line items on the Form 5599 that should be completed at the group level. These items are usually completed by the examiner but some may be completed by the group secretary or group manager per procedures established by the group manager. The numbers in the first column correspond with the circled numbers on the sample Form 5599. The Responsibilities for Completion section on the Form 5599 revised 1-2002 has not been updated to reflect the information in this IRM Exhibit. For more detailed information see on a specific item see IRM Handbook 4.5.2 Chapter 3, Processing EO/AIMS Closings.

Note:

IRM handbook 7.3.1 Chapter 3 is being republished as IRM 4.5.2, TEGE AIMS Special Processing.

NO. INSTRUCTIONS
1 CC TSCLS(Box A at top of page 1.) Place an "X" in the box to release the AIMS freeze on investor closures if the return was assigned as a Partnership Investor Control File (PICF) examination. A PICF examination is indicated on the AMDISA by an entry of 1 through 8 following the PICF-CD. An entry of "0" following the PICF-CD indicates the return is not a PICF return.
2 TIN(P7-18) For a social security number (SSN) posted on IMF enter "XXX-XX-XXXX; " for a SSN posted on NMF enter "XXX-XX-XXXX N;" for an employer identification number (EIN) posted on BMF enter "XX-XXXXXXX;" for an EIN posted on NMF enter "XX-XXXXXXXN."
3 MFT(P21-22) The Master File Tax Code (MFT) or Non-Master File Tax Code (NMFT) must be entered. Refer to Document 6379 for a listing of MFTs.
4 Tax Period(P24-29) The tax period is the measure of time for which a return is required to be filed. The format for tax period is " YYYYMM" . The first four-digits represent the year, the next two digits represent the month. For Forms 11C and 730, the beginning of the tax period must be entered. For all other forms enter the end of the tax period.
5 Name Control/Check(Digit P31-34) Enter the check digit in positions 31 and 32. If the check digit is not available, the name control should be used. If there is no check digit or name control on the first print line of the examination label, underline the name control on line two. If the check digit was used to establish the account, the check digit must be used at closing.
6 Name (Item C) Enter the name of taxpayer as shown on the tax return. On IMF or BMF with a SSN, the last name will appear first followed by a comma then the first name and middle initial if any. On BMF, the portion of the name in the prime sort field will print first. The name can not exceed 35 characters.
7 Interest "To" Date (Item 6a) Enter the date used in restricted interest calculations. This field is always required when interest is input using a TC 340, Restricted Interest Assessment, or TC 341, Restricted Interest Abatement.
8 Credit Interest to Date (Item 6b) Enter the "to" date. This is a required entry when a TC 770, Credit Interest Due Taxpayer, is input for an amount other than zero. This entry is not required for TC 770 with a zero amount. Items 6a and 6b may both be entered when processing TC 770 and TC 340. The Credit Interest to Date is input for IMF and BMF accounts.
9 Compute Interest Amount (Item 6c) Enter the amount of computed interest including manually computed interest (TC 340, Restricted Interest Assessment, and any TC 772 Netted Interest), module balance, accrued and assessed interest, and assessed failure to pay. "Compute Interest Amount" is input for both IMF and BMF.
10 Disposal Code (Item 13) Enter one Disposal Code that best describes the examination results. Refer to Document 6379 for Disposal Code definitions.
11 Claim Rejection Date (Item 20) Enter the completion date of Form 2297 or the date of the letter notifying the taxpayer that their claim has been disallowed in MMDDYYYY format.
12 Amount Claimed (Item 21) Enter the amount of the claim or reduction of tax requested by the taxpayer. If the Source Code is 30, this item is a required entry.
13 Claim Amount Disallowed (Item 22) Enter the dollar amount that was protected from leaving the revenue base (a disallowed claim amount). This amount cannot exceed the amount that is entered in Item 21 or the amount in the "claimed" field on AIMS. An entry must not be made if the claim was allowed in full. If the claim is being referred to Appeals, enter the entire disallowed amount in this field and a negative $1 in Item 18. If the taxpayer is also protesting other issues, enter the protested amount of the other issues in item 18 and the claim amount disallowed in Item 22.
14 Claim Hours (Item 23) Enter time spent on revenue base protection in whole hours only. Examiners must include any hours or fractions of hours spent on non-revenue in Item 28.
15 Claim Type (Item 24) Enter appropriate alpha code from the following list:
  A Abatement of Interest Claims
  B Bankrupt/Insolvent Financial Institution Claims
  C Carry Back/Carry Forward Claims (Restricted Interest and Tentative Carry Back)
  E Excise Taxes Claims
  F FICA or Self-Employment Tax Claims
  G Grants, Fellowship, or Stipend Claims
  H Hardship Claims
  I Injured Spouse Claims
  J Joint Committee Case Claims
  K Disaster Claims*
  L Loss Year BMF Return Consolidation Claims
  M Tax Exempt Bonds
  N Non-Disaster Casualty Losses Over $10,000
  O Other Claims (Amended Returns, 60-Day Statute Pending, Constitutional Objection to Income Tax, Protested Claims)
  P Protective Claims
  R Returns for Estate or Gift Tax Claims
  S Savings/Retirement/Investment Plan Distribution Claims
  T Tax Treaty Claims
  V Vow-of-Poverty Issue Claims
  W WPT Claims
  X Examination Requested Immediately by Taxpayer Claims
  Y Claims Involving any Terminated Year
16 Examiner's Time (Item 28) Enter total time spent on non-revenue base protection issues for each return examined. Time should be reported in full hours and tenths of hours.
  Caution: The examiner should verify that the total time reported on Form(s) 5599; Form 6490, TE/GE Technical Time Report; Case Chronology Record, and Form 5772 agree.
17 Examination Technique (Item 30) Enter the appropriate code. Valid codes for this item are:
  1 Office Interview Examination
  2 Office Correspondence Examination
  4 Field Examination
18 Examiner's Grade (Item 31) Enter the two-digit grade of the examiner who closed the case. An entry is not required for Surveyed Claims.
19 Case Grade (Item 32) This item is completed by examiner or the group manager. If the entry is made by the examiner, it must be initialed by the Group Manager. Enter the appropriate 2 digit code for the examiner's grade, e.g., 11, 12, or 13.
  For related returns enter the same three-digit code as the primary return followed by an "R" , unless the primary and related returns are audited by different examiners. In these cases the related returns are graded as separate entities by the group manager and an "R" is not entered in Item 32.
20 Examiner's Name (Item 33) Enter the last name first, followed by a space and the first initial.
21 Exam Adjustment Amount (Item 34) Enter "1.00" in Item 34 for closing codes 4, Change to Related Returns; 5, Delinquent Related Returns Secured; and 6, Delinquent Return Secured. (This entry will be obsolete as of January 2004.)
22 Delinquent Return Code (Item 37) This field is completed when closing delinquent returns secured from the taxpayer during the examination. If Item 37 is completed, an entry is required in Item 414, Delinquent Return Amount. The examiner will complete Item 37 as follows: Segregate the closing records of delinquent returns secured by MFT. Enter a "T" on the closing record for the earliest year. Enter an "R" on the rest of the closing records having the same MFT code.
  Example: Ten delinquent returns are secured from a taxpayer - Forms 990 for tax years 200112 and 200212, and Forms 941 for each quarter of those years. A "T" should be entered on the closing documents of the 200112 Form 990 and the 200103 Form 941. The balance of the closing documents would be marked with an "R" .
23 Fraud Condition (Item 38) Enter a "C" for civil fraud or "F" for criminal fraud, when applicable. In all other cases leave blank.
24 Project Code (Item 40) Enter Project Code if applicable. Refer to Document 6379 for valid Project Codes.
25 No Change Issue Codes (Item 41a-41d) This entry identifies examined discrepancy issues that resulted in "No-Change" to taxable income. An entry must be present when closing discrepancy adjustment examinations involving Forms 1040 or 1040-A, MFT 30 closed with an 02 Disposal Code. Subsequent classifiers and examiners will use this code to determine whether repetitive no-change examinations have been made. Enter the applicable eight-digit code (without periods or dashes) from the Publication 1102, Uniform Issue List, when closing Discrepancy Adjustment cases that resulted in a no change to taxable income.
  The following codes are Uniform Issue Codes used most frequently for a "No Change" on an exempt organizations' discrepancy examination:
  00612100 Enter for uniform issue code 61.00-00 "Income from Pensions " when income from pensions was examined.
  08610000 Enter for uniform issue code 861.00-00, "Income from Sources Within the U.S." pertaining to aliens to which IRC § 861 applies.
  01700000 Enter for uniform issue code 170.00-00, "Charitable Contributions " when the charitable contribution deductions under IRC § 170 were examined.
  99999999 Enter uniform issue code 9999.99-99 for "No Change Cases Where All Issues Are Changed." In some cases, all examined issues are adjusted yet the return is closed as a Disposal Code 01 or 02 due to other circumstances such as: negative taxable income, offsetting adjustments, barred statute, or de minimis tax liability. Code 9999.99-99 will only be used when all examined issues are changed yet the return is closed as no-change with adjustment or no-change.
26 ARDI Code (Item 42) Enter the appropriate one-digit code when closing an agreed deficiency under the Accounts Receivable Dollar inventory (ARDI) project. Refer to Document 6379 for valid ARDI Codes.
  Note: When closing multiple years and an overassessment from one year will be used to offset an assessment from another year, consider the overassessment as payment secured. Full Paid or Partially Paid depends on the amount of the overassessment.
27 NOL CF Disallowed (Item 44) Enter the amount of any NOL Carry Forward disallowed. Leave blank if the Carry Forward Year return is examined. If an entry is made in Item 44 an NOL indicator must be entered in Item 45.
  Note: The Disposal Code entered in Item 13 can not be 02.
28 NOL indicator(Item 45) This item is used to identify the three types of NOL/Carry Forward Returns.
  1 Enter a "1" for tax periods in which the taxable income line is less than zero.
  2 Enter a "2" for all carry back and/or carry forward tax periods related to the case in which you entered a "1" in Item 45 even if the NOL was examined and the final result was a no change.
  3 Enter a "3" for tax periods in which adjustments on the return were offset either in part or full by a carry over if the carry forward year return is not picked-up. Refer to IRM 4.4.12 Exhibit 6 for examples.
29 Credit CF Disallowed (Item 46) This item is used to report adjustments to a credit that was carried forward but only if the carry forward year return was not examined. Enter the amount of the carry forward that was disallowed. Credit CF Disallowed can be 1 to 11 characters long and may not be negative or zero.
  Example: The examiner examined the 200212 return and disallowed the foreign tax credit of $5,000. Three thousand dollars ($3,000) of the credit disallowed was used in 200212 and $2,000 was carry forward to 200312. The examiner did not pick up 200312 return, since it was not due and had not been filed. Enter 2000 Item 46 and 3000 in Item 12 of the Form 5599 for the 200212 return.
30 CF Credit Type (Item 47) Enter the type of credit that was disallowed in Item 46. If more than one type of credit was disallowed, enter "M" for multiple. If there is only one type of credit, enter the appropriate code as follows:
  B Business Energy Credit
  D Development Credit, Research
  E Experimental Credit, Research
  F Foreign Tax Credit
  H Historical Restoration Credit
  I Investment Tax Credit
  L Low Income Housing Credit
  O Other
  T Tight Formation Gas Credit
  V Vehicle Credit; Qualified Electric
31 Secondary Business Code (Item 49) Enter five zeros. The Secondary Business Code is reserved for future use by TE/GE.
32 Employee Group Code (Item 50) Enter four-digit group number.
33 Place a " check" in the box if additional items are entered on Page 2.
34 CEP Case (Item 400, Page 2) Leave Blank. No longer valid.
35 Delinquent Return Amount (Item 414, Page 2) Enter the following:
  For taxable returns, enter the balance due or refund amount (excluding penalties) per the delinquent return.
  For non-taxable returns, enter the amount of the ordinary net income/loss or special allocation items per return.
  If there is no balance due/refund due or no change to income/loss, enter an "1" in Item 414.
  Note: If Item 414 is entered, Item 37, Delinquent Return Code must also be entered and vice versa. If Item 414 is entered, Item 13, Disposal Code must not be 02 or 34.
36 Amended Return Amount (Item 415, Page 2) Enter the amount of the TC 29X that has posted to MF as a result of an ongoing examination. A current transcript must be included in the case file supporting the amount entered in Item 415. (The TC 42X date must be prior to the TC 29X date).
  For taxable returns, enter the amount of the TC 29X, less any credits posted. In most cases this is the balance/refund due.
  For non-taxable returns, enter the adjustment amount to income/loss.
  Note: This entry is only valid if MF shows that the examination was started before the taxpayer filed the amended return or an original return if the TC 150 is a Substitute for Return (SFR).
37 Fax Agreement Ind. (Item 416) Enter a "1" if the taxpayer faxed the agreement to the Examiner, otherwise leave this item blank.
38 RAR Retained (Item 700, Page 2) "RAR Retained" is no longer a required entry. This item will be eliminated in the next revision of Form 5599.
39 Principal Issue Codes (Item 701, Page 2) The valid range of codes is 01 through 34, 49 and 53 through 67. Refer to Document 6379 for the definitions.
40 IRC Subsection (Item 702, Page 2) Enter the appropriate two-digit code. If an IRC Subsection does not apply, leave blank. Refer to Document 6379 for the IRC Subsection Codes.
41 Asset Code (Item 703, Page 2) Entry is valid for 990-PF's (MFT 44) only, in all other instances, leave blank. Refer to Document 6379 for the appropriate asset amount codes.
42 Related Return (Item 704, Page 2) When closing a Form 990-T account related to a Form 990 examination, enter a "1." When closing a Form 990-T account related to a Form 990-PF examination, enter a " 2." In all other instances leave blank.
  Note: Item 704 is required only when the MFT is 34 (Form 990-T).
43 Comments Section (Page 2) Cases having related returns will be identified by the examiner by writing "Related Case" in the "Comments" area. In addition, the name, EIN, and the return form number of the related case will be shown. Other pertinent information related to the case maybe entered in the "Comments" area, space permitting.
44 "Additional EO Examined Closing Information" column (Page 2) Complete Items 706 and 707 for the primary return.
  Example: A delinquent Form 990-T with tax due of $1,000 was secured during the examination of a Form 990. Enter 1000 in item 706 of the Form 5599 for the Form 990.
  Caution: It is imperative that the examiner enter this additional closing information. The information is extracted from BMF for quarterly, semi-annual and annual TEGE Summary of Changes in Tax Liability and Penalty Assessment reports. Failure to enter this information will result in incorrect statistics reported.
45 Liability Related (Item 706, Page 2) Enter the tax liability from delinquent return(s) secured during the examination, i.e., Item 34, per the delinquent return closing document. If delinquent return(s) were not secured or if liability is not reported leave blank.
  Caution: Do not include the deficiency from previously filed return(s).
46 Liability Converted (Item 707, Page 2) Enter the tax liability determined from the conversion of Form(s) 990 or 990-PF to Form(s) 1041 or 1120. Leave blank if the:
  a. Form(s) were not converted.
  b. The information necessary to make the determination was not available.
  c. Liability was not determined.
  Note: When EO Forms are converted to Form(s) which TEGE does not have examination jurisdiction over, a Form 5666, TE/GE Information Report, must be prepared for the operating division that does have examination jurisdiction. The Form 5666 is submitted to EO Classification for processing.
47 Analysis of Change in Tax Liability(Items 708-739, Page 2) For a non-tax issue or a no change closing, leave Items 708 through 724 and 728 through 731 blank. For tax changes, enter the tax liability resulting from the examination on the appropriate line(s). This information is entered on the Form 5599 for the return being closed.
  Example: Forms 990 and 990-T were examined. As a result of the examination the IRC § 511 unrelated business tax due on the Form 990-T was increased by $500. Enter 500 in item 720 of the Form 5599 for the Form 990-T.
For Form 4720 complete the following items if applicable.
  ITEM NO. INSTRUCTIONS
  708 Enter the amount of the deficiency or overassessment imposed under IRC § 4911 or IRC § 4912.
  710 Enter the amount of the initial deficiency or overassessment of taxes imposed under IRC § 4941 or IRC §4951.
  711 Enter the amount of the additional deficiency imposed under IRC § 4941 or IRC § 4951.
  712 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4942.
  713 Enter the additional deficiency imposed under IRC § 4942.
  714 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4943.
  715 Enter the amount of the additional deficiency imposed under IRC § 4943.
  716 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4944.
  717 Enter the amount of the additional deficiency imposed under IRC § 4944.
  718 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4945 or IRC § 4952.
  719 Enter the amount of the additional deficiency imposed under IRC § 4945 or IRC § 4952
  727 Enter the fair market value of any property recovered by the charity or other person as a result of the correction of any Chapter 42 violations.
  728 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4958.
  729 Enter the amount of the amount of additional deficiency imposed under IRC § 4958.
  730 Enter the amount of the deficiency or overassessment of taxes imposed under IRC § 4955.
  731 Enter the amount of additional deficiency imposed under IRC § 4955.
  738 Enter the amount of the deficiency or overassessment of taxes imposed under IRC § 170(f)(10).
       
For Form 990-PF complete the following item if applicable.
  ITEM NO. INSTRUCTIONS
  709 Enter the amount of the deficiency or overassessment imposed under IRC § 4940.
For Form 990-BL complete the following items if applicable.
  ITEM NO. INSTRUCTIONS
  710 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4941 IRC § 4951.
  711 Enter the amount of additional - enter the additional deficiency imposed under IRC § 4941 or IRC § 4951.
  718 Enter the amount of the initial deficiency or overassessment imposed under IRC § 4945 or IRC § 4952.
  719 Enter the amount of additional - enter the additional deficiency imposed under IRC § 4945 or IRC § 4952.
For Form 990-T complete the following items if applicable.
  ITEM NO. INSTRUCTIONS
  720 Enter the amount of the deficiency or overassessment imposed under IRC § 511.
  739 Enter the amount of the proxy tax deficiency or overassessment imposed under IRC § 6033(e)(2).
For Forms 940, 941, 942, 943, 945, CT-1, CT-2, and 1042 complete the following item if applicable.
  ITEM NO. INSTRUCTIONS
  722 Enter the deficiency or overassessment.
For IRC § 507, termination tax, complete the following item if applicable.
  ITEM NO. INSTRUCTIONS
  723 Enter the amount of tax imposed under IRC § 507.
For Form 1120-POL complete the following item if applicable.
  ITEM NO. INSTRUCTIONS
  724 Enter the increase or decrease in tax imposed under IRC § 527.
For penalties imposed complete the following items if applicable.
  ITEM NO. INSTRUCTIONS
  725 Enter the penalty imposed on any section of chapter 42 tax under IRC § 6684 here and on Form 4881.
  732 Enter the penalty imposed under IRC § 6652(c)(1)(A)(i) on the organization for the failure to file a return required by under IRC § 6033, relating to returns by exempt organizations or IRC § 6012(a)(6), relating to returns by political organizations, on the date and in the manner prescribed therefore (determined with regard to any extension of time for filing).
  733 Enter the amount of the penalty imposed under IRC § 6652(c)(1)(A)(ii) for the failure to include any of the information required to be shown on a return filed under IRC § 6033 or IRC § 6012(a)(6) or to show the correct information on a return.
  734 Enter the amount of the penalty imposed on a manager under IRC § 6652(c)(1)(B) for failure to comply with a written demand by the Secretary on any organization subject to penalty under subparagraph IRC § 6652(c)(1)(A) specifying therein a reasonable future date by which the return shall be filed or the information furnished.
  735 Enter the amount of the penalty imposed under IRC § 6652(c)(1)(C) for failure to make annual returns and reports available for public inspection.
  736 Enter the amount of the penalties imposed by IRC § 6652(c)(1)(D) for failure to make an application for exemption or notice of status available for public inspection.
  737 Enter the amount of the additional penalty imposed under IRC § 6685 on any person who is required to comply with the requirements of IRC § 6104(d) and fails to so comply with respect to the public inspection of any return or application.
  728 Enter the penalty imposed by any other IRC section.

Exhibit 4.75.16-2  (05-13-2003)
Form 2363-A Required Input

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Exhibit 4.75.16-3  (05-13-2003)
Form 2363-A - Instructions for Completion

The Form 2363-A, Exempt Organization BMF-EO Entity Change, is the form used to establish or change accounts on the BMF. An examiner is required to complete the form to record changes to the organization's account resulting from the examination.

Exhibit 4.75.16-2 shows the required fields that must be completed when preparing a Form 2363-A. To use the exhibit, find the "type of change" being made (e.g. address, name, etc.) in column 1 and then follow across the row to determine which items must be completed on the Form 2363-A. The numbers in the column headings correspond to the item numbers on the form. Those required for a particular change are marked with an "X." The Transaction and/or Definer Codes that must be input are also shown.

Note:

The table provides the required input for changes relating to a single organization. For mass changes to subordinates covered under a group ruling, Document Code 81 should be used.

Form 2363-A Line Item Instructions1
ITEM: ENTER:
Item 1, Employer ID Number The 9 digit employer identification number.
Item 2, Name Control The four digit name control. The name control for an exempt organization is derived from the first four significant characters of the name. The first position must be an alpha or numeric character. The remaining positions must be alpha or numeric, blank, ampersand or hyphen. Blanks in the Name Control are permissible only at the end of the Name Control to make it a four-position Name control. When the word "the " begins the organization's name, it should not be used to form the name control. Also, for "trusts" select a Name Control from the surname.
Item 3, Document Codes 80 "X" to update one account on the BMF or may also be used to update one subordinate of a group ruling.
  81 "X" for mass establishments, additions or changes for organizations covered under a group ruling.
Item 4 Transaction Codes "X" in the appropriate box. Only one transaction code (TC) is allowed per form. The transaction codes determine the consistency and validity checks that will be performed.
Item 5, Definer Codes Definer code(s) "A" "B" and/or "C" , as appropriate. These codes are used with TC 012 and TC 016. Up to three definer codes may be entered with TC 016. Definer code "A" is the only code that can be used with TC 012.
Item 7, New Name Control The new name control when the organization's name is being changed.
Item 8, Primary Name The legal name of the organization.
Item 9, Continuation of Primary Name The continuation of the legal name of the organization.
Item 10, Sort Name The name the organization is doing business under. It may be different from the Primary Name. The "Sort Name" can be deleted by entering two dollar signs ($$) in Item 10.
Item 11, "In care of" name The "in care of" name if specified by the organization. The "In care of" Name can be deleted by entering two dollar signs ($$) in Item 11.
Item 12 Foreign Street The street address for an organization located in a foreign country.
Item 13, Mailing Street or foreign city/ZIP The street address where the organization receives its mail. For foreign organizations enter the city/ZIP in this field.
Item 14, Mailing city/state/ZIP or foreign country The city/state/ZIP where the organization receives its mail. For foreign organization enter the country.
Item 15, Location street address The street address where the organization is physically located.
Item 16, Location city/state/ZIP The city/state/ZIP where the organization is physically located.
Item 17, Subsection The subsection code from Document 6379.
Item 18, Foundation Code The foundation code must be input if subsection code is "03." Valid foundation codes are:
  02 Exempt operating foundation
  03 Private operating foundation
  04 Private non-operating foundation
  09 Suspense
  10 Church - IRC § 170(b)(1)(A)(i)
  11 School - IRC § 170(b)(1)(A)(ii)
  12 Hospital IRC § 170(b)(1)(A)(iii)
  13 Organizations operated for the benefit of a college or university - IRC § 170(b)(1)(A)(iv)
  14 Federal, State or local government unit - IRC § 170(b)(1)(A)(v)
  15 Organization receiving support form governmental unit or general public - IRC § 170(b)(1)(A)(vi)
  16 General, public charity - IRC § 509(a)(2)
  17 Public charity supporting organization - IRC § 509(a)(3)
  18 Public Safety - IRC § 509(a)(4)
Item 19, Classification Code Appropriate classification code from Document 6379 if the TC is 000, 012 or 016.
Item 20 Affiliation Code The affiliation code. Valid affiliation codes are:
  1 Central Organization (Individual ruling)
  2 Intermediate organization (Individual ruling)
  3 Independent organization (Individual ruling)
  6 Parent of a group ruling (not a church)
  7 Intermediate parent (subordinate by state)
  8 Parent of a church
  9 Subordinate of a group ruling (also, group return)
Item 21 Type of Organization The type of organization code. Valid type of organization codes are:
  1 Corporation
  2 Trust
  3 Cooperative
  4 Partnership
  5 Association
  6 NECT (Subsection must equal 91 or 92)
Item 22 Status Code and Date   The status (SS) of the organization and the date (YYYYMM) the status became effective (SSYYYYMM). Valid status codes are:
  00 EO section established without status
  01 Unconditional exemption-Active
  02 Conditional exemption-Active
  06 State operated university or college filing Form 990-T
  07 Church filed a Form 990-T Active
  10 Pre-examination of church-Active
  11 School certification-Active
  12 A formal exemption not granted - filing an EO Return - (Form 990 Under IRC 4947(a)(1); Form 990-PF Under IRC 4947(a)(1); Form 5227, Non-Exempt Charitable Trust)
  18 Temporary revocation of private foundation (Trust). Required to file Forms 990-PF and 1041 - Active
  19 Revocation of private foundation. Required to File Forms 990-PF and 1120 - Active
  20 Termination-Inactive (Out of Business, etc.)
  21 Unable to locate-Inactive/Active New address needed
  22 Revocation-Inactive
  23 507(a) Termination-Inactive
  24 507(b)(1)(A) Termination-Inactive
  25 507(b)(1)(B) Termination-Inactive
  26 Termination merger - Inactive
  28 No longer a member of group ruling.
  29 A group ruling has been dissolved.
  40 Application pending-Inactive-No exemption
  41 No reply to solicitation - Inactive - No exemption
  42 Extension of time to file
  70 Denied - Inactive - No exemption
  71 Incomplete application - No exemption granted
  72 Refusal to rule - Inactive - No Exemption
Item 23, Ruling Date Date the determination or ruling letter was issued.
Item 24, Activity Codes Leave Blank. These codes were obsolete after 1/1/2002.
Item 25, Deductibility Code The deductibility code (CC) and year (YYYY) in CCYYYY format. Valid deductibility codes are:
  1 Contributions are deductible
  2 Contributions are not deductible
  3 Contributions are deductible under treaty provisions.
Item 26, From GEN The group exemption number (GEN) when changing a GEN or updating a group exemption.
Item 27, New GEN The new GEN to change an individual determination/ruling to a group determination/ruling.
Item 28, File Folder Number File folder number as assigned to the determination file/microfiche. Usually this number should not be changed. The file folder number can be found on IDRS using command codes INOLE, BMFOL or ENMOD.
Item 29, District Location The two digit universal location code from IRM 25.7.2, Exhibit 25.7.2-5 to reflect the where the principal place of business is located.
Item 30, Pension Plan Enter the applicable pension plan code, as follows:
  1 Yes
  2 No or not known
Item 31, Adv. Ruling Date   The date when advance ruling period is due to expire.
Item 32, Large Case Code The appropriate large case code if the case is or has previously been included in the Team Examination Program (TEP), previously known as the Coordinated Examination Program (CEP). Valid large case codes are:
  1 When a case is to be included in Team Examination Program.
  2 Was previously a Team Examination Program. case.
  9 To remove a case from the Team Examination Program.
Item 33, Cumulative List Indicator The Cumulative List Indicator code to identify an organization that is to be included in the Cumulative List (Pub. 78) Supplement. Valid Cumulative List Indicator codes are:
  3 to include EO in next quarterly supplement of Publication 78
  9 to delete a Cumulative List Indicator
Item 34, Employment Code A "W" for a IRC § 501(c)(3) organization (other than an instrumentality of a state, municipality or other local governmental unit) not subject to FUTA tax.
  Exception: Do not enter a "W" for churches that have timely filed Form 8274, electing exemption from employer social security taxes. The Service Center establishes the employment code for these entities.
Item 35, Fiscal Year/Month Month in which the exempt organization's fiscal year ends
Item 36, NTEE National Taxonomy of Exempt Entities Code from IRM 25.7.2 Exhibit 25.7.2-9.
Item 37, NAICS Code North Atlantic Industry Classification System Code from IRM 25.7.2 Exhibit 25.7.2-8.
Item 38, Filing Requirements Filing requirement codes from Document 6379.
  Note:When changing from one filing requirement to another, be certain to enter a zero (0) or two zeros (00) in the filing requirement box to be deleted.
  For example, if changing from a public charity to a private foundation enter "1" in the 990-PF box and "00" in the 990 box.
Item 39, Remarks A description of change to leave a history for future reference, e.g., Foundation Code follow-up. Remarks must consist of 10-35 characters with no consecutive blanks.
Item 40, Prepared by The examiner's name and the current date. Although "Current Date" is not preprinted on the 11/99 revision of Form 2363-A, it is required.
Item 41, Organization Symbols Group Number
Item 42, Prepared from Source for the change being requested, e.g., examination, amended articles of incorporation, correspondence, inquiry, etc.
1Detailed instructions, explanations, and allowable codes for each item can be found in IRM 25.7.2, EO/BMF Processing Procedures.

Exhibit 4.75.16-4  (05-13-2003)
Instructions for Preparing Form 4881, Chapter 42 Taxes-Disqualified Person/Foundation Manager

The following items should be completed by the examiner unless otherwise noted.

Item Description Definition
Form No. Enter the appropriate Form Number (either 4720 or 990-BL).
MFT For Form 4720, enter MFT 50. For Form 990-BL, enter MFT 56.
Tax Period Enter the Tax Period (in YYYYMM format) for which Chapter 42 taxes are being assessed.
  Reminder:
    Prepare a separate Form 4881 for each Tax Period in which Chapter 42 taxes are being assessed.
Name/
Address/Zip Code of Taxpayer 		If available, attach an address label from the temporary EIN account established on AIMS. If a label is not available, enter the complete name and address of the person or organization being assessed Chapter 42 taxes.
  Reminder:
    When more than one person or organization is being assessed taxes, complete a separate Form 4881 for each one involved.
Taxpayer Identification No. (TIN) Enter the SSN of the person (or the EIN of the organization) being assessed Chapter 42 taxes.
Adjustments Enter the following information as applicable. Use a separate column for each type of tax being assessed.
IRC Section Enter the appropriate 4-digit IRC section number.
  4941 For self-dealing
  4944 For investments which jeopardize charitable purposes.
  4945 For taxable expenditures
  4958 For excess benefit transactions
Abstract Code Enter the appropriate 3-digit code:
  150 For IRC § 4941
  152 For IRC § 4944
  154 For IRC § 4945
  Blank For IRC § 4958
    Note: As of 3/2003 an abstract code had not been programed for IRC § 4958. This item should be left blank until an abstract code is programed and published.
Initial Tax Enter the amount of the initial tax.
Additional Tax If applicable, enter the additional tax. If additional tax is not to be assessed, leave this item blank.
Total Tax Enter the sum of the Initial and Additional Taxes.
Penalty Type Enter the applicable type of penalty (6651 or 6684). If a penalty is not being imposed, leave blank.
Penalty Amount If a penalty is being imposed, enter the amount. In all other instances, leave blank.
Related Private Foundation/Organization
Name/
Address/Zip Code of Taxpayer 		Enter the complete name and address of the private foundation or organization to which the person or organization being assessed Chapter 42 taxes is related.
Taxpayer Identification No. Enter the EIN of the private foundation or organization to which the person or organization being assessed Chapter 42 taxes is related.
Form No. Enter the Form Number of the primary return filed by the private foundation/organization related to the person or organization being assessed Chapter 42 taxes.
Tax Period Enter the Tax Period (in YYYYMM format) of the return filed by the private foundation/organization related to the person or organization being assessed Chapter 42 taxes.
Prepared By Enter the name of the person preparing this report.
Area Office Enter the Area Office in which the examination was conducted.
Date Enter the date of the report.
Other Information Use this item to record any additional information pertinent to the case.
  Note:
    Review staff must enter the annotation "REVIEWED" along with the Reviewer’s initials and the date.

Exhibit 4.75.16-5  (05-13-2003)
Cover Sheet for Documents to be Added to Determination File/Microfiche

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Exhibit 4.75.16-6  (05-13-2003)
Case Assembly

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Exhibit 4.75.16-7  (05-13-2003)
Documents Attached to the Return

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