7.20.2  Determination Letter Processing of Exempt Organizations

Manual Transmittal

July 08, 2014

Purpose

(1) This transmits revised IRM 7.20.2, Exempt Organizations Determination Letter Program, Determination Letter Processing of Exempt Organizations.

Background

This IRM section is only updated to reflect Interim Guidance Memorandum TEGE-07-0613-06, as it relates to the Be On the Lookout (BOLO) list. No other changes have been to this IRM. Effective June 20, 2013, the IG memo suspended the use of the BOLO list.

Material Changes

(1) IRM 7.20.2.3.2(4) is revised to delete the procedure to check the Be On the Lookout (BOLO) list in compliance with Interim Guidance Memorandum TEGE-07-0613-06.

(2) IRM 7.20.2.4 is revised to delete the procedure to check the Be On the Lookout (BOLO) list in compliance with Interim Guidance Memorandum TEGE-07-0613-06.

Effect on Other Documents

This revision supersedes IRM 7.20.2, dated 8/24/2012. Interim Guidance Memorandum TEGE-0613-06, Interim Guidance on the Suspension of BOLO List Usage, is incorporated.

Audience

TEGE (Exempt Organizations)

Effective Date

(07-08-2014)

Tamera L. Ripperda
Director, Exempt Organizations
Tax Exempt and Government Entities

7.20.2.1  (08-24-2012)
Determination Letter Processing Overview

  1. Applications for tax exempt status under sections 501 and 521 (Forms 1023, 1024, and 1028), as well as group exemption requests (controlled as Form 1026), are submitted to the Cincinnati Submission Processing Center (CSPC), PO Box 12192, Covington, KY 41012-0192. CSPC processes the user fee payment in the Letter Information Network and User Fee System (LINUS) and scans the application/request into the Tax Exempt Determination System (TEDS).

  2. Initial "I" cases are created when Forms 1023, 1024, and 1028 are scanned into TEDS, and Amendment "A" cases are created when group exemption requests are scanned into TEDS. After cases are established in TEDS, the data is transmitted to the EP/EO Determination System (EDS) and hard copy case files are sent to the EP/EO Determinations Processing Section in Cincinnati, OH.

    Note:

    EDS is the determination letter application system of record.

  3. For cases processed through TEDS, the Processing Section holds the hard copy case files until they are closed, unless it is necessary to transmit the case to EO Technical or Exempt Organizations Determinations Quality Assurance (EODQA).

  4. Other determination letter requests are submitted on Form 8940 to the CSPC, PO Box 12192, Covington, KY 41012-0192. CSPC processes the user fee payment in LINUS and forwards the Form 8940 package to the EO Determinations, Correspondence Unit, PO Box 2508, Cincinnati, OH 45201. The Correspondence Unit establishes Amendment (A cases) or section 507(b)(1)(B) termination requests (P cases) in EDS, based on the block checked on Form 8940, item 8.

    1. The Exempt Organizations EDS User Manual (see IRM 7.22) provides procedures for processing determination letter requests in EDS from establishment to closing.

    2. A TEDS User Manual is under development. The TEDS User Manual will provide procedures for processing determination letter requests in TEDS from establishment to closing.

  5. Almost all determination letter requests go through an initial review, referred to as Technical Screening. See IRM 7.20.2.3 for a detailed description of the technical screening process.

  6. Cases that are not closed in Technical Screening and are not referred to EO Technical per IRM 7.20.1.4 are referred to as full-development (non-merit) cases. These cases are held in the Centralized Unassigned Inventory (Status 51) until work is requested by specialists in EO Determinations work groups. Certain types of cases are held in a reserved inventory for designated groups. See IRM 7.20.1.3.

  7. For taxpayer contact guidelines, see IRM 7.20.1.7, Authorized Persons, and IRM 7.20.1.8, Disclosure/Third Party Contact.

7.20.2.2  (08-24-2012)
Case Assignments

  1. Specialists request work by completing Form 14272, EO Determinations Group Case Request Form.

  2. When Form 14272 is completed, the group manager e-mails the completed form to the EO Determinations Processing Section mailbox at *TEGE Determinations Processing.

  3. Cases will be assigned in control (postmark) date order and by grade level according to the EO Determinations Case Assignment Guide (CAG) Case Grading Criteria Matrix (Exhibit 7.20.2-1) .

    Note:

    Certain exceptions (volumes and types of reserved inventory) apply to assigning cases in control date order. Also, cases approved for expedited handling will be assigned before other cases based on grade and reserved inventory.

  4. Because the case complexity factors and grade level distinctions of the Case Grading Criteria Matrix are extensive, a CAG Summary (Exhibit 7.20.2-2) assists specialists and managers in identifying the case grade that is predominantly associated with specific activities, purposes or issues. Although the CAG Summary is available to assist specialists and managers in assigning the proper grades to casework, the CAG Case Grading Criteria Matrix remains the method by which all activities, purposes and issues of a case are evaluated for grading purposes. Additionally, management reserves the right to review individual cases and change the grades for those cases based on the Case Grading Criteria Matrix.

7.20.2.3  (08-24-2012)
Technical Screening Overview

  1. Technical Screening is the initial review of initial determination letter requests.

  2. Initial screening is completed by EO Determination specialists, who are referred to as screeners. Because of the variety of section 501(c) subsections, as well as the variety of organizations applying under section 501(c)(3), the most experienced specialists will be assigned to screen cases.

  3. Screeners review the application package to determine, based on the facts in the case and clearly established legal precedent (statute, tax treaty, the Code, regulations, revenue rulings, court decisions) whether the case should be:

    • forwarded to the centralized unassigned inventory for full development (Status 51);

    • returned to the organization because it is not substantially complete according to Rev. Proc. 2012-9, updated annually, or the instructions to Form 1023/Form 1024 (Status 03);

      NOTE 1: Substantially complete applications are those which include a narrative description of activities, an organizing document, bylaws (if adopted), user fee, applicable schedules, pages of the application, financial statements, and signature.
      NOTE 2: If the organizing document does not contain the requisite language to meet the organizational test under section 501(c)(3), the application may be returned per Form 1023 instructions.
      NOTE 3: In cases where it appears the applicant requested exemption under section 501(c)(3) in error and the application package is not complete, the organization should not be asked to amend the organizational document to include section 501(c)(3) language when the application is "returned incomplete" .
    • approved on merit with no contact (Status 06);

    • identified as needing minor additional information or technical clarification before approval on merit (Status 71); or

    • identified for secondary screening (Status 75).

  4. Cases that appear to meet the technical requirements for exemption but lack minor procedural items needed to make the case substantially complete according to Rev. Proc. 2012–9, updated annually, or the instructions to Form 1023/Form 1024, are given a TEDS case category of Accelerated Processing (AP). The purpose of AP is to secure the missing items needed to make an application complete in order for exemption to be approved.

  5. Cases that appear to qualify for exemption but require technical clarity before exemption can be granted are given a TEDS case category of Intermediate Processing (IP). The purpose of IP is to research available sources and/or contact the applicant to clarify, verify, or secure information required before exemption may be granted.

  6. Cases that require review by employees who specialize in those particular types are given a TEDS case category of secondary screening, with a subcategory for the type of case involved ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ . The purpose of secondary screening is for a senior specialist in the designated group to determine whether the case can be approved on merit with no contact, requires minor development before approval, should be returned to the organization because it is not substantially complete, or whether it should be forwarded to the centralized unassigned inventory for full development.

7.20.2.3.1  (08-24-2012)
Expedite Requests Processed in Technical Screening

  1. All cases with expedite requests awaiting screening must be assigned to designated screeners within 2 workdays from the date the expedite request is received or the date the case is updated to Status 61 - Unassigned Inventory (Technical Screening), whichever is later.

  2. Screeners must review cases in accordance with initial screening procedures set forth in IRM 7.20.2.3.2. If the application can be approved, the screener will follow case closing procedures per IRM 7.20.2.13. The screener will place a pink folder on the outside of the orange folder before submitting the case to the manager.

  3. For cases that cannot be granted exemption based on the information submitted, the screener will:

    1. determine whether the case meets the expedite criteria per IRM 7.20.2.10,

      If so, the screener will keep the "expedite flag" on the TEDS case and will designate the appropriate case category.
      If not, the screener will remove the "expedite flag" on the TEDS case and will designate the appropriate case category.
    2. document the Form 5464-A, EP/EO Case Chronology Record (CCR) accordingly, along with reasons for approval or denial of the expedite request,

    3. route the case in TEDS to the Correspondence Unit, expedite coordinator, to prepare an expedite approval or denial letter, and

    4. follow case processing procedures.

  4. Screeners must submit expedite cases to the manager within 3 workdays from assignment.

  5. For additional information on processing expedite requests, see IRM 7.20.2.10.

7.20.2.3.2  (07-08-2014)
Initial Screening of Cases

  1. Screeners review initial determination letter requests and make decisions as to how the cases should be processed.

  2. Cases are assigned to screeners in Status 62 within 30 calendar days from the control (postmark) date.

  3. Screeners will enter the case grade per the CAG Summary, Exhibit 7.20.2-2. Case grading criteria are based on various case complexity factors set forth in Exhibit 7.20.2-1.

  4. Screeners are required to check the Excel spreadsheet that includes the Comprehensive List of Terrorists and Groups and document the results of the checks on the CCR.

  5. Screeners are required to complete applicable checksheets, checklists, and worksheets including:

    Form 14279 EO Determinations Checklist for Screening Potential Credit Counseling Cases
    Form 14260 EO Determinations Screening Checklist - Financial Literacy
    Form 14270 EO Determinations - Section 509(a)(3) Screener Checklist
    Form 14281 EO Determinations Checklist - Donor Advised Funds Cases
    Form 14259 EO Determinations Screening Checksheet
    Form 14262 EO Determinations - Missing Information Checksheet
    Form 14278 EO Determinations Worksheet - Closure of Incomplete Cases
    Form 14273 EO Determinations Screening Checklist - Hedge Funds
    Form 14283 EO Determinations Accelerated Processing Checksheet-Form 1023 Cases,
    Form 14275 EO Determinations Accelerated Processing Checksheet-Form 1024 Cases
    Form 14274 EO Determinations Checklist - Cases Requiring Intermediate Processing
    Form 14284 EO Determinations Credit Counseling Intermediate Processing Checksheet
    Form 14282 EO Determinations Intermediate Processing Checksheet - Section 509(a)(3) Status Issues
    Form 14261 Memorandum to File - EO Determinations Case Closing,
    Form 14277 EO Determinations Case Closure Documentation Worksheet
  6. If cases cannot be closed, screeners are required to import into TEDS all checksheets, workpapers, and other documents prepared.

  7. Screeners are required to close cases from their inventories within 5 workdays from the date of assignment in Status 62.

      IF the application: THEN the screener will: THEN the manager or delegate will:
    1.
    1. involves an issue or activity listed on Form 14259, EO Determinations Screening Checksheet,

    2. does not appear to involve a secondary screening issue, and

    3. is a substantially complete application package or request according to Rev. Proc. 2012-9, updated annually, and the instructions to Form 1023/1024.

    1. prepare Form 14259, EO Determinations Screening Checksheet.

    2. enter either the appropriate reserved case category or the "General Inventory" case category (only one) in TEDS based on the primary purpose/activities,

    3. update the case grade in TEDS, and

    4. update the cases in TEDS to Status 74 (Awaiting Managerial Review).


    (1) Review the case within 5 workdays from receipt.
    • If the manager agrees with the screener's recommendation, the TEDS case will be updated to Status 51 (Centralized Unassigned Inventory).

    • If the manager does not agree with the screener's recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist – Technical Screening).


    (2) Inform the screener of the issue(s) that need to be addressed.
    2.
    1. involves an issue or activity listed on Form 14259, EO Determinations Screening Checksheet.

    2. does not appear to involve a secondary screening issue, and

    3. is not a substantially complete application package according to Rev. Proc. 2012-9, updated annually, or the Instructions to Form 1023/Form 1024.

    1. complete Form 14262, EO Determinations Missing Information Checksheet,

    2. print the Additional Information Sheet (AIS) from the TEDS disclosable folder and staple it to the front of the orange folder,

    3. complete the CCR in TEDS and print a copy,

    4. complete and print Form 14278, EO Determinations Worksheet - Closure of Incomplete Cases, by indicating:

      • the appropriate filing requirements, if applicable, and

      • whether there is a Power Of Attorney (POA) that should receive a copy of Letter 1042 and Form 14262

    5. enter Proposed Closing Code 03 (Returned Incomplete) in TEDS,

    6. enter TEDS Case Category "Incomplete" ,

    7. update case in TEDS to Status 74PC (Awaiting Managerial Review), and

    8. place the orange folder in the designated bin.


    (1) Review the case within 5 workdays from receipt.
    • If the manager agrees with the screener's recommendation, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions

    • If the manager does not agree with the screener's recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist – Technical Screening).


    (2) Inform the screener of the issue(s) that need to be addressed.
    3.
    1. involves an issue or activity listed on the Form 14259, EO Determinations Screening Checksheet, and

    2. appears to involve a secondary screening issue

    1. complete applicable checksheet(s),

    2. enter the appropriate reserved case category in TEDS, and

    3. update the TEDS case to Status 74 (Awaiting Managerial Review).


    (1) Review the case within 5 workdays from receipt.
    • If the manager agrees with the screener's recommendation, the TEDS case will be transferred, as appropriate, to the designated specialty group in Status 75 (Group Unassigned) for secondary screening.

    • If the manager does not agree with the screener's recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist – Technical Screening).


    (2) Inform the screener of the issue(s) that need to be addressed.
    4.
    1. does not involve an issue or activity listed on Form 14259, EO Determinations Screening Checksheet, and

    2. can be approved based on the information submitted

    1. prepare the appropriate closing worksheet and staple it on top of the AIS below the name of the organization,

    2. enter Proposed Closing Code 06 (Merit Closure - no contact),

    3. update the case in TEDS to Status 74PC (Awaiting Managerial Review), and

    4. place the orange file folder in the designated bin.


    (1) Review the case within 5 workdays from receipt.
    • If the manager agrees with the screener's recommendation, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions.

    • If the manager does not agree with the screener's recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist – Technical Screening).


    (2) Inform the screener of the issue(s) that need to be addressed.
    5.
    1. does not involve an issue or activity listed on the Form 14259, EO Determinations Screening Checksheet.

    2. appears to be an acceptable application package or request, but

    3. lacks minor procedural items or other items needed to make the application package or request substantially complete, according to Rev. Proc. 2012-9, updated annually, or the instructions to Form 1023/Form1024.

    1. prepare Form 14275 or Form 14283 to identify why the case is being forwarded to AP.

    2. import the AP Checksheet into the non-disclosable folder in TEDS,

    3. update the case category in TEDS to "Accelerated Processing" and

    4. update the TEDS case to Status 74 (Awaiting Managerial Review).


    (1) Review the case within 5 workdays from receipt.
    • If the manager agrees with the recommendation, the TEDS case will be updated to Status 71 (Unassigned Inventory - Accelerated Processing).

    • If the manager does not agree with the screener's recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist - Technical Screening).


    (2) The manager will inform the screener of the issue(s) that need to be addressed.
    6.
    1. does not involve an issue or activity listed on Form 14259, EO Determinations Screening Checksheet.

    2. appears to be an acceptable application package or request, but

    3. requires clarification of technical issues, and

    4. may also require minor procedural items or other items needed to make the application package or request substantially complete, according to Rev. Proc. 2012-9, updated annually, or the instructions to Form 1023/Form 1024.

    1. prepare Form 14274, EO Determinations Checklist, Cases Requiring Intermediate Processing, to identify why the case is being forwarded to IP.

    2. import the Form 14274 into the non-disclosable folder in TEDS,

    3. update the case category in TEDS to "Intermediate Processing" and

    4. update the TEDS case to Status 74 (Awaiting Managerial Review)

    (1) Review the case within 5 workdays from receipt.
    • If the manager agrees with the recommendation, the TEDS case will be updated to Status 71 (Unassigned Inventory – Intermediate Processing). The manager will hand-carry Grade 13 cases to the IP manager for assignment to an IP specialist.

    • If the manager does not agree with the recommendation of the screener, the TEDS case will be updated to Status 64 (Manager Returned to Specialist - Technical Screening).


    (2) The manager will inform the screener of the issue(s) that need to be addressed.

7.20.2.3.3  (08-24-2012)
Accelerated Processing Overview

  1. Accelerated Processing (AP) is part of the screening program that involves clarifying minor procedural information and/or securing missing items needed to make an application substantially complete, according to Rev. Proc. 2012-9, updated annually, and the instructions to Form 1023/1024 before approving exemption.

7.20.2.3.3.1  (08-24-2012)
Accelerated Processing - Case Processing Procedures

  1. Cases are assigned to Processing Section tax examiners in Status 72 within 15 calendar days from the date the case was updated to Status 71 (unassigned AP/IP).

  2. Processing Section tax examiners are required to secure the items identified by the screener on Form 14283, EO Determinations Accelerated Processing Checksheet - Form 1023 Cases or Form 14275, EO Determinations Accelerated Processing Checksheet - Form 1024 Cases, within 5 workdays from the date the case was updated to Status 72. The Form 14283 or 14275 (AP Checksheet) is located in the TEDS non-disclosable folder.

  3. Prior to making contact with the organization, Processing Section tax examiners are required to review the following:

    • Case Chronology Record (CCR),

    • Case information in TEDS to verify the case category is Accelerated Processing,

    • Related cases, if applicable, to determine whether any information is needed, and

    • New Documents folder in TEDS to determine whether needed information was submitted subsequent to the screener’s review.

  4. Additional information letters prepared by the Processing Section tax examiners are limited to those items marked on the Form 14283 or 14275 (AP Checksheet) unless approved by the manager.

  5. Processing Section tax examiners are required to import into TEDS the additional information letter prepared.

  6. Processing Section tax examiners are required to make phone contact with the organization in an attempt to secure the information needed prior to placing a case in suspense (Status 37). The phone contact must be documented on the CCR.

  7. If a response is received, the Processing Section is required to update the case to the AP group unassigned inventory within 5 workdays from receipt of a complete response.

  8. Within 5 workdays of assignment to the AP group, the case will be assigned to a specialist,

  9. Within 5 workdays of assignment, the AP specialist will:

    1. determine whether a second request for information must be sent.

      • If so, the specialist will send a Letter 2382 with the AIS attached. Case processing and follow up timeframes apply, per IRM 7.20.2.4.

      • If not, and the case cannot be approved, the specialist will seek guidance from his/her manager.

    2. determine whether the case can be approved. If so,

      • prepare the appropriate closing input sheet and staple it on top of the AIS below the name of the organization,

      • enter Proposed Closing Code 09 (Merit Closure with Contact),

      • update case in TEDS to Status 74PC (Awaiting Managerial Review), and

      • place the orange file folder in the designated bin.

  10. The manager or delegate will review the case within 5 workdays from receipt.

    1. If the manager agrees with the recommendation of the AP specialist, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions.

    2. If the manager does not agree with the recommendation of the AP specialist, the TEDS case will be updated to Status 73 (Manager Returned to Specialist – Accelerated Processing). The manager will inform the specialist of the issue or issues that need to be addressed.

7.20.2.3.4  (08-24-2012)
Intermediate Processing (IP) Overview

  1. IP is part of the screening program that involves researching available sources and/or contacting the applicant to clarify, verify, or secure information in order to make a determination.

7.20.2.3.4.1  (08-24-2012)
Intermediate Processing - Case Processing Procedures

  1. Cases are assigned to IP specialists in Status 72 within 15 calendar days from the date the case was updated to Status 71 (unassigned AP/IP).

  2. IP specialists will within 5 workdays of assignment review the IP Checksheet, Form 14274, and CCR prepared by screener, as well as the application package, to determine what action is needed. As appropriate, internet and other available research (e.g., IDRS) will be conducted. Based on the results of the available research/review, the IP specialist will determine whether a case will be:

    • approved on merit with no contact,

    • approved on merit after securing minor additional information, or

    • assigned to the centralized unassigned inventory for full development because the case was inappropriately identified as IP (managerial approval is required for this action).

  3. IP specialists are required to close cases from their inventories within 5 workdays from receipt of a complete response.

  4. If cases cannot be closed, IP specialists are required to import into TEDS all checksheets, workpapers, and other documents prepared.

    IF THEN the IP specialist will: THEN the manager or delegate will:
    1. Research is sufficient to address the identified issues, and results do not need to be added to the administrative record
    1. print relevant research and/or documents that need to be scanned into the TEDS non-disclosable folder and added to the hard copy case file,

    2. prepare the appropriate closing input sheet and staple it on top of the AIS below the name of the organization,

    3. enter Proposed Closing Code 09 (Merit Closure - Contact),

    4. update case in TEDS to Status 74PC (Awaiting Managerial Review), and

    5. place the orange file folder in the designated bin.

    (1) Review the case within 5 workdays from receipt.
    1. If the manager agrees with the specialist's recommendation, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions.

    2. If the manager does not agree with the specialist's recommendation, the TEDS case will be updated to Status 73 (Manager Returned to Specialist - Intermediate Processing).


    (2) The manager will inform the specialist of the issue(s) that need to be addressed.
    2. Research is sufficient to address the identified issues, and documents are needed for the administrative record
    1. print the information secured and transmit it to the applicant with Letter 4760, Internet Transmittal Letter.

    2. prepare the appropriate closing input sheet and staple it on top of the AIS below the name of the organization,

    3. enter Proposed Closing Code 09 (Merit Closure - Contact),

    4. update the case in TEDS to Status 74PC (Awaiting Managerial Review), and

    5. place the orange file folder in the designated bin.

    (1) Review the case within 5 workdays from receipt.
    1. If the manager agrees with the specialist's recommendation, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions.

    2. If the manager does not agree with the specialist's recommendation, the TEDS case will be updated to Status 73 (Manager Returned to Specialist - Intermediate Processing).


    (2) The manager will inform the specialist of the issue or issues that need to be addressed.
    3. Research is not sufficient to address the issues identified on Form 14274, EO Determinations Checklist - Cases Requiring Intermediate Processing, and the information needed is complex.
    1. determine whether contact with the applicant will resolve the issues identified:

      • If not, the IP specialist will discuss the case with his/her manager, document the CCR that the case requires full development, enter Status 51 (Centralized Unassigned Inventory), enter "General Inventory" TEDS Case Category or other appropriate case category (only one), and update case in TEDS to Status 74 (Awaiting Managerial Review).

      • If so, the IP specialist will contact the applicant to request additional information via phone, fax, or letter. General case processing and follow-up timeframes apply, per IRM 7.20.2.4.

        Note:

        If more information is needed after a response is received, the IP specialist will have 5 workdays to request the additional information. Information should be requested by phone, if possible. Otherwise, a Letter 2382 will be sent with the AIS attached. General case processing and follow up timeframes apply, per IRM 7.20.2.4.

    (1) Review the case within 5 workdays of receipt.
    1. If the manager agrees with the IP specialist, the case will be updated to Status 51 (Centralized Unassigned Inventory).

    2. If the manager does not agree, the case will be returned to the specialist in Status 73 (Manager Returned to Specialist - IP).


    (2) The manager will inform the specialist of the issues that need to be addressed.
    4. Research, or a response from the applicant, identifies an issue listed on the Form 14259, EO Determinations Screening Checksheet.
    1. prepare and import the Form 14259, EO Determinations Screening Checksheet,

    2. ensure the appropriate case grade is assigned,

    3. enter the appropriate case category in TEDS,

    4. update the case in TEDS to Status 74 (Awaiting Managerial Review).

    Review the case within 5 workdays of receipt.
    1. If the manager agrees with the IP specialist, the case will be updated to Status 51 (Centralized Unassigned Inventory).

    2. If the manager does not agree, the case will be returned to the specialist in Status 73 (Manager Returned to Specialist - IP).


    (2) The manager will inform the specialist of the issue or issues that need to be addressed.

7.20.2.3.5  (08-24-2012)
Secondary Screening Overview

  1. Secondary Screening is a part of the screening program that involves reserved inventory cases being screened by the groups who specialize in those cases. The following reserved inventory categories have been designated for secondary screening: ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

7.20.2.3.5.1  (08-24-2012)
Secondary Screening - Case Processing Procedures

  1. Secondary screeners will screen the cases to determine whether they should be:

    • approved on merit with no contact;

    • approved on merit after securing minor additional information;

    • returned to the organization because it is not substantially complete according to Rev. Proc. 2012-9, updated annually, or the instructions to Form 1023/Form 1024; or

    • forwarded to the centralized unassigned inventory for full development.

      Note:

      If the organizing document does not contain requisite language to meet the organizational test, the application will be returned per Form 1023 instructions.

  2. Cases are generally assigned to secondary screeners in Status 62 within 15 calendar days from the date the case was updated to the designated group in Status 75 (Group Unassigned Inventory).

  3. Secondary screeners are required to enter the case grade per the CAG.

  4. Secondary screeners will complete any applicable checksheets unique to the reserved inventory category.

  5. Secondary IP cases will be worked in accordance with the Intermediate Processing procedures found in IRM 7.20.2.3.4.1.

  6. If cases cannot be closed, secondary screeners are required to import into TEDS all checksheets, workpapers, and other documents prepared.

  7. Secondary screeners are required to close cases from their inventories within 5 workdays from the date of assignment in Status 62.

    IF THEN the Secondary Screener will: THEN the manager or delegate will
    1. The application can be approved on merit based on the information in the file
    1. complete the applicable secondary screening checklists,

    2. prepare the appropriate closing input sheet and staple it on top of the AIS below the name of the organization,

    3. enter Proposed Closing Code 06 (Merit Closure No Contact),

    4. update case in TEDS to Status 74PC (Awaiting Managerial Review), and

    5. place the orange file folder in a designated bin.

    (1) Review the case within 5 workdays from receipt.
    1. If the manager agrees with the specialist's recommendation, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions.

    2. If the manager does not agree with the specialist's recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist - Technical Screening).


    (2) The manager will inform the screener of the issue(s) that need to be addressed.
    2. The application:
    1. lacks only minimal, relatively non-complex items, and

    2. the specialized group utilizes a Secondary Intermediate Processing program ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    1. prepare the applicable checksheet to identify why the case is flagged for the Secondary IP process,

    2. import the IP Checksheet into the non-disclosable folder in TEDS,

    3. add the appropriate IP case category in TEDS, and

    4. update the TEDS case to Status 74 (Awaiting Managerial Review).

    (1) Review the case within 5 workdays from receipt.
    1. If the manager agrees with the screener's recommendation, the TEDS case will be updated to Status 75 (Group Inventory). The IP case will be assigned within 15 calendar days of the date it was updated to Status 75 to an IP Specialist in the group.

    2. If the manager does not agree with the recommendation, the TEDS case will be updated to Status 64 (Manager Returned to Specialist - Technical Screening).

    (2) The manager will inform the screener of the issue(s) that need to be addressed.
    3. The application:
    1. is not sufficient to close the case on merit, and

    2. is a substantially complete application package (see note) according to Rev. Proc. 2012-9, updated annually, and Instructions to Form 1023/1024.

    1. document the CCR that the case requires full development

    2. select the appropriate case category in TEDS

    3. update case in TEDS to Status 74 (Awaiting Managerial Review).

    (1) Review the case within 5 workdays of receipt.
    1. If the manager agrees with the screener, the case will be updated to Status 51 (Centralized Unassigned Inventory).

    2. If the manager does not agree, the case will be returned to the specialist in Status 64 (Manager Returned to Specialist - Technical Screening).

    4. The application:
    1. is not sufficient to close the case on merit, and

    2. is not a substantially complete application package according to Rev. Proc. 2012-9, updated annually, or instructions to Form 1023/Form 1024

    1. complete the Missing Information Checksheet, Form 14262,

    2. print the AIS from the TEDS disclosable folder and staple it to the orange folder,

    3. complete the CCR in TEDS and print a copy,

    4. complete Form 14278, EO Determinations Worksheet - Closure of Incomplete Cases, by indicating:

      • the appropriate filing requirements, if applicable, and

      • whether there is a Power of Attorney (POA) that should receive a copy of Letter 1042 and Form 14262.

    5. enter Proposed Closing Code 03 (Returned Incomplete) in TEDS,

    6. enter TEDS Case Category "Incomplete,"

    7. update case in TEDS to Status 74PC (Awaiting Managerial Review), and

    8. place the orange folder in the designated bin.

    (1) Review the case within 5 workdays from receipt.
    1. If the manager agrees with the recommendation of the screener, the TEDS case will be updated to Status 57 (TEDS Case Awaiting Closure on EDS) and the orange file folder will be sent to Processing for case closing actions.

    2. If the manager does not agree with the recommendation of the screener, the TEDS case will be updated to Status 64 (Manager Returned to Specialist - Technical Screening).


    (2) The manager will inform the screener of the issue(s) that need to be addressed.

7.20.2.4  (07-08-2014)
Case Processing-General

  1. On the date a case is assigned, the specialist will:

    1. Add the case to his/her inventory by entering it on Form 6490 (WebETS), and

    2. Prepare a CCR noting the date the case was assigned.

      Note:

      If the case is being worked in TEDS, the TEDS CCR will be automatically updated with the date the case is assigned.

  2. Within 5 workdays of assignment, the specialist will:

    1. Verify that the case grade is correct per the Case Assignment Guide. See Exhibit 7.20.2-1 and Exhibit 7.20.2-2. If the case grade is incorrect, the specialist will consult with the group manager. If the group manager agrees that the case grade is incorrect, the specialist will take the following actions:

      • document on the CCR that the case grade was corrected with manager’s concurrence,

      • correct the case grade in EDS/TEDS,

      • manually correct the case grade, as required, on file folder identification labels, and

      • correct the case grade on his/her Form 6490 (WebETS).

    2. Assemble the case documents in case file assembly order (removing staples, other fasteners and any separator sheets. See IRM 7.20.2.12.

    3. Review the case, including the EO Determinations Screening Checksheet, Form 14259, and verify that the following were submitted with the application:

      • the correct user fee (see IRM 7.20.2.9 and Rev. Proc. 2012-8, updated annually);

      • an Employer Identification Number (EIN);

      • all applicable pages and schedules of Form 1023/1024/1028;

      • a conformed organizing document;

      • bylaws, if adopted;

      • a narrative describing the organization’s past, current, and planned activities; and

      • financial data requested in the instructions to Form 1023/1024/1028.

    4. Verify that:

      • the application form was signed by an authorized person. Form 1023 must be signed by an officer, director, or trustee of the organization. Forms 1024 and 1028 must be signed by an officer, director, trustee, or authorized representative of the organization;

      • Form 2848 and/or Form 8821, if submitted, were properly executed. If a tax form number is listed in Part 3 of Form 2848, the Form 2848 must be sent to the Centralized Authorization File (CAF) based on procedures set forth in IRM 7.20.1, and

      • the CCR includes documentation showing that the screener reviewed the Excel spreadsheet that includes a Comprehensive List of Terrorists and Groups (CLTG), and documented the results. If not, the specialist will conduct the CLTG check and document the results on the CCR. The specialist will also conduct the CLTG check and document the results on the CCR if new names/addresses of officers, directors, or other individuals are added to the application after the screening process. See IRM 7.20.6.7.

    5. Submit the case to the manager for closure (see IRM 7.20.2.13), reassignment to another group (see IRM 7.20.2.4.3), transfer to EO Technical (see IRM 7.20.1), or request additional information (see IRM 7.20.2.4.1).

7.20.2.4.1  (08-24-2012)
Requesting Additional Information

  1. EO determination specialists must carefully review each application for exemption to ensure that requests for additional information are thorough, complete, and relevant to the paragraph of section 501(c) appropriate to the applicant.

  2. Exempt status will be recognized in advance of operations if proposed operations can be described in sufficient detail to permit a conclusion that the organization will meet the particular requirements of the section under which exemption is claimed. A mere restatement of purposes or a statement that proposed activities will be in furtherance of such purposes will not satisfy these requirements. The organization must fully describe the activities in which it expects to engage, including the standards, criteria, procedures, or other means adopted or planned for carrying out the activities; the anticipated sources of receipts; and the nature of contemplated expenditures.

  3. When an organization has submitted documents in a foreign language, the specialist will request from the organization an English translation for the administrative record.

  4. If additional information is required, Letter 1312 will be prepared and mailed to the organization within 5 workdays of case assignment, requesting a response within 21 days from the date of the letter. If additional clarification is needed after the organization responds to Letter 1312, the specialist has 5 workdays to prepare and mail Letter 2382 with the due date set at 14 days from the date of the letter. Response due dates should be noted as the follow-up dates on the CCR.

  5. Information requests should be professional in tone, grammatically correct, free of spelling errors, formatted properly, complete, and material to the determination requested. Specialists should avoid asking for information that is already included in the case file. See IRS Correspondence Manual, IRM 1.10.1 for guidance on preparation of IRS correspondence.

  6. Specialists may find it helpful to contact applicants by telephone to clarify information on the application prior to issuing an additional information letter. If the information is not critical to exempt status, documentation of the conversation on the CCR (including the name and title of the person spoken to, details of the conversation and action to be taken) will be adequate. However, if the information concerns inurement, discrimination, political activity or anything else that is a deciding factor for qualification for exemption, the information must be submitted in writing over the signature of an officer or authorized representative.

7.20.2.4.2  (08-24-2012)
Actions Taken When Response Received or Due

  1. When a response to additional information is received, the specialist will document the date of receipt on the CCR and will take action as follows:

    IF THEN the specialist will:
    The organization responds to a request for information by the response due date and the response is complete Review the response and close the case within
    • 5 workdays of receipt date stamped on the letter (hard copy cases),

    • 5 workdays of the date the TEDS status changes indicating a response has been received (TEDS cases), or

    • 10 workdays for a denial or other adverse determination beginning on the receipt date stamped on the letter (hard-copy cases) or the TEDS status change date (TEDS cases).

    A response is received to Letter 1312 or Letter 2382 and the response is incomplete or, based on the response, additional information is required Review response and issue Letter 2382 within 5 workdays of the date the response was stamped "Received" in EO Determinations. The response due date for Letter 2382, which is used for second and subsequent requests for additional information, is 14 calendar days from the date of the letter.
  2. When a response to additional information is not received by the due date, the specialist will take action as follows:

    IF the organization: THEN the specialist will:
    Fails to respond to Letter 1312 or Letter 2382 Contact the organization or authorized representative by telephone on the first workday after the missed response due date to inquire about the status of the organization’s response.
    1. In the event the organization requests an extension of time to respond, the specialist may grant 14 calendar days. The specialist will document the telephone conversation, and new response due date (if extension is granted) on the CCR.

    2. In the event the specialist is unable to reach the organization or authorized representative by telephone, Letter 4423, 14-day Follow-Up Letter, will be prepared and issued. A copy of the referenced Letter 1312 or Letter 2382 will be attached to Letter 4423. The response due date for Letter 4423 is 14 days from the date of issue.

    Cannot respond within the 21-day period or the 14-day extended period and requests an additional extension Consult with the group manager as to whether any further extension beyond 35 days should be granted. After consulting with the group manager, the specialist will contact the organization to inform them whether the extension requested was granted or denied. (1) If the extension request was granted, the specialist will telephone the organization to:
    • Inform the organization of the extended response due date,

    • Explain Suspense/Failure to Establish (FTE) procedures in the event a response is not received by the extended response due date. See IRM 7.20.2.13.2.


    (2) If the extension request was not granted, the specialist will telephone the organization to:
    • Explain suspense/FTE procedures, and

    • Inform the organization that the case will be closed FTE if a response is not received by the 90-day response due date. See IRM 7.20.2.13.2.

     
    Fails to respond to the request for additional information and all reasonable extensions of time to respond have been granted
    1. contact the organization or authorized representative by telephone on the workday following the missed response due date.

    2. explain to the organization or authorized representative that the case is being suspended due to lack of response to request(s) for additional information, and

    3. emphasize that the organization will have 90 days in which to submit the additional information requested and if a response is not received within 90 days the case will be closed. After the 90 days, the organization will be required to submit a new application package and a new user fee payment if it wishes to pursue exemption. See IRM 7.20.2.13.2.

      Note:

      See IRM 7.20.4 for Failure to Establish procedures applicable to foreign organizations.

     

7.20.2.4.2.1  (08-24-2012)
Requests for Extension of 90-Day Response Due Date

  1. The initial 90-day response due date, along with subsequent due dates, will be extended unless the organization supplies no valid reason for the extension request. After three extensions have been granted, the group manager or delegate will review subsequent requests to determine whether additional extensions should be granted.

  2. If the specialist receives a telephone call or correspondence requesting an extension of the 90-day response due date or subsequent due dates, the specialist will prepare Form 14265, Request for Extension of 90-Day Response Due Date-EO Determinations Case and will forward it immediately to the Processing Section.

    NOTE 1: The Processing Section will prepare Letter 4799, Approval of 90-day User Fee Extension or Letter 4720, Denial of 90-day User Fee Extension, and will send it within 5 workdays of receipt of the request. Extensions will be granted in 30-day increments.
    NOTE 2: Specialists are not authorized to grant an extension of the 90-day response due date.

7.20.2.4.3  (08-24-2012)
Transferring Cases to Other Groups

  1. If a specialist believes his/her case should be transferred to another group, he/she will consult with his/her group manager.

  2. If the group manager agrees that the case should be transferred, the manager will transfer the case to the appropriate group in Status 75 (Group Unassigned Inventory).

    1. If the case is being transferred between POD’s and is a TEDS case, it will be transferred to the recipient group in TEDS.

    2. If it is a hard copy case, the case file will be transferred to the recipient group in Status 58 (Case In Transit). Upon receipt, the receiving group will update to Status 75 (Group Unassigned Inventory).

  3. If the case is required to be transferred to EODQA for mandatory review, the case will be transferred to EODQA in hard copy in its entirety. For TEDS cases:

    1. The specialist will request the hard copy case be assigned from the Records Unit.

    2. After receiving the hard copy case, the specialist will ensure all documents imported or scanned to TEDS that aren’t in the hard copy file are printed from TEDS.

    3. The specialist will print a current CCR from TEDS and include it in the hard copy file.

    4. The specialist will place all imported or scanned documents and the CCR in the hard copy case file in case file assembly order (see IRM 7.20.2.12.2).

    5. The specialist will update the case in TEDS to Status 74 (For Manager Review).

    6. The manager or delegate will update the case in TEDS to Status 59 (Owned by EDS).

    7. The case will then be processed according to normal processing and case file assembly procedures. (See IRM 7.20.2.12.7 for information on case file assembly of denials of exemption and/or adverse foundation status).

    8. When the case is ready to be transferred to EODQA, the Processing Section or group secretary will transfer the case to Group 7810 (EODQA) but must not close the case in EDS

  4. If the group manager does not agree with proposed transfer, he/she will explain to the specialist the reason(s) why the proposed transfer is not appropriate.

7.20.2.5  (08-24-2012)
Section 508(a) Overview

  1. Organizations applying for exemption under section 501(c)(3) are subject to the notice provisions of section 508(a) and related regulations, which generally require an organization to submit Form 1023 within 15 months from the end of the month in which it was organized. See IRM 7.20.2.5.2 for information on the 12-month extension that applies to organizations applying for exemption under section 501(c)(3).

  2. Section 508(c) provides that the 15-month filing requirement described in section 508(a) does not apply if the organization is:

    1. Not a private foundation described in section 509(a) and its annual gross receipts are normally not more than $5,000. (see IRM 7.20.2.5.1),

    2. A church, interchurch organization of local units of a church, convention or association of churches, or integrated auxiliary of a church. See section Treas. Regs. section 1.6033–2(h) regarding the definition of integrated auxiliary of a church;

    3. A subordinate organization (other than private foundations) covered by a group exemption letter. See Treas. Regs. section 1.508–1(a)(3)(c).

    4. Formed solely for the purpose of sections 507, 508(d)(1), 508(d)(2)(A) and 508(d)(3), 508(e), 509 and chapter 42, a trust described in section 4947(a)(1). However, a trust described in section 501(c)(3) which was organized after October 9, 1969, shall be exempt under section 501(a) by reason of being described in section 501(c)(3) only if it files such notice. See Treas. Regs. section 1.508–1(a)(3)(d); and

    5. Any other class of organization that the Commissioner from time to time excludes from the requirement of filing notice under section 508(a).

  3. If an organization is not described in (2)(a) through (2)(e) above, and does not file its Form 1023 within 27 months from the end of the month in which it was organized, then it may file for relief from the section 508(a) filing requirement pursuant to Rev. Proc. 92-85. Relief is covered under Treas. Regs. section 301.9100-1 and -3.

7.20.2.5.1  (08-24-2012)
Gross Receipts Defined for Section 508 Purposes

  1. To determine whether an organization satisfies the exception for filing under section 508(c)(1)(B) because its annual gross receipts are normally not more than $5,000, the specialist must review the organization’s financial statements to verify that:

    1. During the first taxable year of the organization, the organization has received gross receipts of $7,500 or less;

    2. During its first two taxable years the aggregate gross receipts received by the organization are $12,000 or less; and

    3. In the case of an organization which has been in existence for at least three taxable years, the aggregate gross receipts received by the organization during the immediately preceding two taxable years plus the current year are $15,000 or less.

    Note:

    This exception applies only if the organization does not apply for exemption within the first 27 months of its existence.

  2. The organization has 90 days from the end of the fiscal year in which it fails the gross receipts test to submit an application for relief from the section 508(a) filing requirement.

7.20.2.5.2  (08-24-2012)
Relief under Section 301.9100

  1. IRM 7.20.2.5.2 does not apply to organizations whose exemption has been automatically revoked.

  2. Delegation Order 183 (as revised) authorizes group managers in Exempt Organizations to grant a reasonable extension of time for section 505(c) and 508(a) matters. This authority may not be re-delegated. Section 508(a) applies to organizations requesting exemption under section 501(c)(3). Section 505(c) applies to organizations requesting exemption under section 501(c)(9) or (c)(17).

  3. Treas. Reg. section 301.9100-2 provides an automatic 12-month extension of the 15-month period for filing Form 1023 to organizations requesting recognition of exemption under section 501(c)(3), and for filing Form 1024 to organizations requesting recognition of exemption under section 501(c)(9) or (c)(17). The automatic 12-month extension applies if the organization submits a completed Form 1023 or Form 1024 within 12 months after the end of the initial 15-month filing period. This gives applicants a total of 27 months to submit applications in order to be compliant with sections 508(a) or 505(c).

  4. If the organization does not submit its application within 27 months from the date it was formed, then section 301.9100-3 provides that an additional extension of time may be granted if the applicant submits an affidavit demonstrating that it acted reasonably and in good faith, and that the granting of relief will not prejudice the interests of the Government.

    Note:

    If the organization completes Schedule E of Form 1023, it does not need to submit a separate affidavit.

  5. An organization may satisfy the affidavit requirement of Treas. Reg. section 301.9100-3 if it:

    1. Meets the requirements for tax exemption from the end of the month in which it was created;

    2. Files its application before the Service discovers the organization’s failure to timely file the Form 1023 or 1024; and

    3. Was not, or is not, under examination.

  6. The affidavit requirement of Treas. Regs. section 301.9100-3 will not automatically be applied if an organization files a Form 990 to meet its filing requirements but has not filed an application form and is contacted by the Ogden Campus to resolve the unpostable condition.

  7. If an affidavit is necessary, it should be signed and dated by an officer of the organization attesting to the facts surrounding the organization’s failure to file.

  8. If relief under section 301.9100-3 is granted, the specialist will note this in the Form 14261, Memorandum to File - EO Determinations Case Closing along with a brief statement on the reason(s) for granting relief.

7.20.2.5.3  (08-24-2012)
Section 301.9100 Relief Not Granted

  1. If the specialist recommends that section 301.9100 relief should not be granted, and the group manager agrees, the specialist should discuss the proposed adverse determination with the organization before issuance of a determination letter.

  2. If Treas. Regs. section 301.9100 relief is not granted by EO Determinations, then the applicant seeking exemption under section 501(c)(3) may request exemption under section 501(c)(4) for the period preceding the effective date of exemption under section 501(c)(3):

    1. Page 1 of Form 1024 must be filed by the organization to receive consideration of exemption under section 501(c)(4),

    2. Exempt status under section 501(c)(4) will be effective from the date of formation until the date of recognition of exemption under section 501(c)(3), and

    3. The determination letter for exemption under section 501(c)(3) will include an addendum that sets forth the dates the organization was exempt under section 501(c)(4).

  3. If there is disagreement between the organization and the Service regarding the effective date of exemption that cannot be resolved at the group level, the specialist will prepare a proposed adverse determination (see IRM 7.20.2.11) on the effective date of exemption that will be subject to mandatory review by EODQA.

7.20.2.6  (08-24-2012)
Effective Date of Exemption

  1. A section 501(c)(3) applicant, except if described in section 508(c), must file its application within 15 months from the end of the month in which it was organized for the effective date of exemption to be retroactive to the date of formation. See Treas. Reg. section 1.508-1(a). Treas. Reg. section 301.9100-2(a)(2)(iv) provides an automatic 12-month extension to organizations applying under section 501(c)(3).

  2. The filing date is the postmark date stamped on the envelope in which the exemption application is mailed. If the envelope is not postmarked, or the postmark is illegible, the filing date is the date the completed application is stamped received by the Service.

  3. If the organization is not described in any subsection of 501(c) from the time it was formed, the effective date of exemption will be the date when the organization is first described in section 501(c). If this is the situation, the specialist will explain the effective date of exemption issue to the organization.

    1. If the organization agrees, a written statement must be secured from the organization similar to the following:

      "We agree with the conclusion of the Internal Revenue Service concerning the effective date of our exempt status under section 501(c)(3) of the Code. We also agree that from _____ through _____ we did not qualify for recognition of exemption from Federal income tax under section 501(c)(3) of the Code and that contributions during this period are not deductible under section 170 of the Code."

    2. If the organization does not agree, the case will be processed as an adverse case. See IRM 7.20.2.11.

  4. In the case of a non-section 501(c)(3) organization operated in an exempt manner as an unincorporated association before its incorporation, the determination letter should state that the period of exemption includes the period during which the organization, now a corporation, operated in unincorporated status. See Rev. Rul. 54-134. For section 501(c)(3) organizations, see Rev. Rul. 73-422 and Rev. Rul. 77-116.

  5. A tax-exempt organization that requests a change in subsection is required to submit a new application for exemption. The effective date of the exemption under the new subsection would be the postmark date of the new application.

    • The determination letter would include the following addendum: The effective date of exemption under section ___ (enter new subsection) is ________ (enter date). You were exempt under section _____(enter former subsection) from the period ______ to ______ (enter dates)

    • The effective date on Form 8670 will be the original exemption date.

  6. A tax-exempt corporation that reincorporates in a new state is required to file a new application for exemption. See Rev. Rul. 67-390. The effective date of exemption for the new corporation will be the date of formation of the new corporation if the application is timely filed and the organization otherwise meets requirements for exemption.

  7. A section 501(c)(9) or (c)(17) applicant must file its application within 15 months from the end of the month in which it was organized for the effective date to be retroactive to the date of formation. See Treas. Reg. 1.505(c)-1T, and also see IRM 7.20.2.5.2 for information on the 12-month extension that applies to applications for exemption under section 501(c)(9) or (c)(17).

7.20.2.7  (08-24-2012)
Establishing Cases on EDS

  1. If the specialist receives information that requires the establishment of a case on EDS, a Form 14263, Request for Case Establishment on EDS, will be prepared and placed in the designated bin.

  2. If the specialist discovers that the application or request was incorrectly established on EDS, the incorrectly established case will be closed according to procedures in IRM 7.20.2.13. If a new case needs to be established, Form 14263 will be prepared and placed in the designated bin.

  3. If the specialist is working a case that includes multiple related requests, the specialist will ensure that each type of request is properly established on EDS. A Form 14263 should be prepared to have the related case(s) established so that the cases may be worked simultaneously. Upon establishment, the case(s) will be assigned to the specialist working the related case.

7.20.2.7.1  (08-24-2012)
Change in Subsection

  1. The establishment of a new Initial "I" case is required when an organization requests a change in subsection during the application process by submitting Form 1023 to replace the original Form 1024, or vice versa. For example, if an organization that applied for exemption under section 501(c)(3) on Form 1023 withdraws its request and submits a Form 1024 requesting exemption under section 501(c)(4), it is necessary to establish a new "I" case for the Form 1024.

  2. It is not necessary to establish a new case when an organization requests a change in subsection on Form 1024 during the application process by submitting a revised Form 1024 page 1 and applicable schedule. For example, an organization applies for exemption under 501(c)(7) and changes its request to section 501(c)(4).

  3. When an organization requests a change in subsection, the following procedures apply:

    IF THEN
    During the processing of an application the applicant decides to change subsections and submits a Form 1024 to replace a Form 1023 or vice versa Upon receipt of new application, the following actions are taken:
    1. The specialist will:

      1. print all TEDS documents that need to be added to the hard copy case file;

      2. request establishment of new Initial "I" case by preparing Form 14263, Request for Case Establishment on EDS, and attach all documents to be included in the new case file;

      3. update EDS to Status 04 (Withdrawn by T/P),

        Note:

        No letter is prepared.

      4. prepare Form 14290, Closing Worksheet for Letter 2244, for the withdrawn application with the time charged for working the case;

      5. process the new case file/application according to case processing procedures.

    2. The manager will close the withdrawn case Status 59 in TEDS and Status 04 in EDS.

    The applicant submits Form 1024 and subsequently requests exemption under a different subsection on Form 1024. The specialist will update the subsection field in TEDS (or EDS for hard copy cases) to reflect the new subsection.
    The applicant was previously exempt under section 501(a) and submits a new application requesting exemption under a different subsection The applicant is required to submit a new user fee. Application is established as Initial “I” case on EDS and worked according to case processing procedures.
    See IRM 7.20.2.6 regarding the effective date of exemption.
  4. If an organization fails to respond in a timely fashion to a request for additional information about its subsection modification request, follow suspense/FTE procedures set forth in IRM 7.20.2.13.2 with the following exceptions:

    1. An addendum will be added to the FTE letter stating that the organization is still exempt under the subsection under which it was originally granted exemption, and

    2. Input "990" as the filing requirement in Letter 1314, 501(c)(3) Exemption Application Will be Closed for Failure to Supply Requested Information, and close the case Status 12.

7.20.2.8  (08-24-2012)
Employer Identification Numbers

  1. An employer identification number (EIN) is a number assigned to each organization by the Internal Revenue Service. All organizations applying for exemption must have an EIN that is uniquely theirs. See Rev. Rul. 73-526. If there is any indication that the EIN provided is not correct, the specialist should request IDRS information to verify that the organization is using the correct EIN.

  2. If the organization is not using the correct EIN, the specialist will determine, through IDRS research, whether the organization has been assigned an EIN of its own. If the organization does not have an EIN, the organization should complete an EIN application online at www.irs.gov.

  3. If the organization does not have an EIN and is unable to complete an on-line application it can obtain an EIN by any of the following methods:

    1. using the EIN Toll-Free Telephone Service (see IRM 21.7.13.3.5),

    2. by mail (see IRM 21.7.13.3.6), or

    3. by fax (see IRM 21.7.13.3.7).

  4. A determination specialist may obtain an EIN for a organization only in those situations where there is an immediate need for the EIN and the organization is unable to obtain the EIN without assistance from the determinations specialist. See IRM 7.21.7.13.3.8 for procedures.

  5. An application cannot be approved or denied until a valid EIN is secured.

  6. If a specialist discovers that an organization has been assigned more than one EIN, the EIN’s will be merged following the procedures set forth below.

    1. The specialist will obtain Master File research through IDRS on all EINs (e.g., INOLES, ENMOD, BMFOLO)

    2. The specialist will request that the organization confirm the EIN which is to survive. It is preferable that an organization retain the EIN under which any tax returns were filed or to which any tax payments were applied (BMFOLO will show this information). However, if the organization chooses to retain another EIN as the surviving EIN, the organization's preference should be honored.

    3. The specialist will prepare Form 14271 an EIN Merger Memo, to be sent to the Ogden Campus, Entity Control Unit. This form advises Ogden which EINs are to be merged/consolidated. Copies of applicable research prints and a copy of the organization’s letter requesting merger/consolidation of EINs (if applicable) should be attached to the EIN Merger Memo. Two copies of the EIN Merger Memo will be placed on the top left side of the case file or orange folder. Special Instructions on Form 3198-A, TE/GE Special Handling Notice, should state: "Forward to Processing Section - EIN Merger Memo to Ogden."

  7. A tax-exempt organization must file a new application for exemption and secure a new EIN if it changes its form from a non-incorporated association or trust to a corporation, see IRM 21.3.8.12.20 and Rev. Rul. 67–390. Because the corporation is treated differently than an unincorporated association or trust for Federal income tax purposes, a new EIN is required. See Rev. Rul. 73-526.

  8. If a tax-exempt corporation reincorporates in another state, it is required to file a new application for exemption. See Rev. Rul. 67-390. If it conducts the same activities with the same assets in the new state, the reincorporation constitutes a reorganization under section 368(a)(1)(F) of the Code and a new EIN is not required. See Situation 3 in Rev. Rul. 73-526. If, however, the reincorporation does not meet the requirements of a reorganization under section 368(a)(1)(F), a new EIN is required. See Situation 4 in Rev. Rul. 73-526.

  9. If the State permits a corporation to change from a for-profit to a non-profit or from a stock corporation to a non-stock corporation by filing an amendment to the existing corporation, then a new EIN is not needed; however, if new Articles are needed to effect a change, then a new EIN is needed.

  10. An LLC is not required to secure a new EIN if it has an existing EIN and is merely changing from an LLC to a corporation.

  11. Although an organization requesting a change in subsection is required to file a new application, it is not required to secure a new EIN.

  12. Specialists are responsible for ensuring that EDS, TEDS, and LINUS reflect the correct EIN for the organization and will, if necessary:

    1. correct the EIN on EDS and TEDS (if the specialist has access to the case in TEDS) if a new EIN is obtained for the organization or the EIN is otherwise incorrect on EDS/TEDS,

      Note:

      If the case is being worked in TEDS, do not modify EDS; make the change only in TEDS.

    2. send a secure e-mail to the manager of the Adjustments Unit requesting that the EIN be corrected in LINUS (and TEDS if the specialist does not have access to the case in TEDS). The request should include the organization’s name, the EDS/TEDS case number, the incorrect EIN, and the correct EIN, and

    3. follow EIN merger procedures in (6) above if one or more EINs are being merged.

7.20.2.9  (08-24-2012)
User Fees

  1. A user fee is required for processing individual and group ruling exemption applications, as well as the following types of requests (Refer to Rev. Proc. 2012-8, updated annually:

    1. advance approval of set-asides described in section 4942(g)(2),

    2. advance approval of voter registration activities described in section 4945(f),

    3. advance approval of grantmaking procedures described in section 4945(g),

    4. exemption from section 6033 filing requirements,

    5. advance approval that a potential grant or contribution constitutes an unusual grant under sections 170(b)(1)(A)(vi) or 509(a)(2),

    6. change in type [509(a)(3) organization],

    7. reclassification of foundation status including voluntary requests from public charities for private foundation status,

    8. termination of private foundation status under section 507(b)(1)(B) – advance ruling request, and

    9. termination of private foundation status under section 507(b)(1)(B) – 60 month period ended.

  2. User fee payments are submitted with the application for exemption to the Cincinnati Submission Processing Center (CSPC):

    1. CSPC notes the amount of the user fee paid by the applicant on page 12 of Form 1023. For Form 1024 and Form 1028 applications, CSPC notes the amount of the user fee paid on Form 8718, User Fee for Exempt Organization Determination Letter Request.

    2. The user fee payment field in EDS and TEDS is flagged as follows:

      • "C" - complete payment,

      • "I" - insufficient, additional user fee required (if user fee paid is less than $450),

      • "O" - overpayment, refund due (if user fee paid is more than $850),

      • "U" - unknown, or

      • Blank

    3. The dishonored check field in EDS and TEDS is flagged as follows:

      • "Y" - yes, there is a dishonored check

      • "N" - no, there is not a dishonored check

      • Blank

    4. See IRM 7.20.2.9(6) for an explanation of the impact on case closing of flags in the dishonored check and/or user fee fields.

  3. It is the specialist’s responsibility to ensure that the correct user fee is paid. The specialist will review the financial information submitted by the applicant, along with the description of its activities, to determine whether the correct user fee has been paid. If the applicant did not pay the correct user fee, the specialist will solicit the payment in an additional information request, Letter 1312 or Letter 2382, as appropriate. The specialist will advise the applicant to make checks or money orders payable to "United States Treasury."

  4. If the information in the case file or in EDS/TEDS is unclear, the amount of user fee paid can be verified on LINUS. If a specialist does not have access to LINUS, research is obtained from the group secretary or the Adjustments Unit.

  5. If an applicant submits the correct user fee but, as part of case development subsequently:

    1. submits a new application for exemption under a different subsection, the user fee previously paid by the applicant will automatically be applied to the new application.

    2. files page 1 of the Form 1024 to request exemption under section 501(c)(4) for the period prior to the effective date of Form 1023 because it does not qualify or did not apply for relief under section 301.9100-1, no additional user fee payment is due.

  6. The following is an explanation of how flags in the EDS/TEDS user fee payment and dishonored check fields impact case closing:

    Dishonored Check Field User Fee Field Effect on Case Closing
    Y C, I, O, U, Blank Case can be closed in a non-approval status (closing codes 03, 04, 11, 12, and 30) but cannot be closed in an approval status (closing codes 01, 06, 09).
    N C Case can be updated or closed normally in any status
    N I Case can be closed in a non-approval status (closing codes 03, 04, 11, 12, and 30) but cannot be closed in an approval status (closing codes 01, 06, 09).
    N O Case can be updated and specialist can close case to manager but manager cannot close case until flag is updated by User Fee Adjuster.
    N U Case can be closed in a non-approval status (closing codes 03, 04, 11, 12, and 30) but cannot be closed in an approval status (closing codes 01, 06, 09).
    N Blank Case can be updated or closed normally in any status
    Blank C Case can be updated or closed normally in any status
    Blank I Case can be closed in a non-approval status (closing codes 03, 04, 11, 12, and 30) but cannot be closed in an approval status (closing codes 01, 06, 09).
    Blank O Case can be updated and specialist can close case to manager but manager cannot close case until flag is updated by User Fee Adjuster.
    Blank U Case can be closed in a non-approval status (closing codes 03, 04, 11, 12, and 30) but cannot be closed in an approval status (closing codes 01, 06, 09).
    Blank Blank Case can be updated or closed normally in any status
  7. Prior to closing a case, the specialist should take the following actions:

    1. If the user fee field is I or U, the specialist should contact the Adjustments Unit by e-mail (*TE/GE-EO-Adjustments) to verify the user fee paid and take action necessary for Adjustments to update the flag.

    2. If the user fee field is O, Form 14268, User Fee Refund Request, should be prepared and sent to Adjustments immediately so that the flag can be updated and the case closed,

    3. If the dishonored check fee is Y, the specialist should request the user fee from the organization through an additional information letter. When it is received, Adjustments will update the flag and send a copy of the response to the specialist so that the specialist can close the case.

7.20.2.9.1  (08-24-2012)
Processing Additional User Fees

  1. If an additional user fee payment is received during the processing of a case, the following procedures apply.

    IF THEN
    Additional user fee is received on case assigned to specialist in Cincinnati The Processing Section, Correspondence Unit, opens all mail directed to Cincinnati specialists and forwards the mail with checks to the Adjustments Unit. The Adjustments Unit processes all user fee payments received, and updates the user fee payment fields in EDS/TEDS. In the event a user fee check is received directly by a specialist, the payment will be taken immediately to the Processing Section, Adjustments Unit.
    Additional user fee is received on case assigned to specialist outside Cincinnati The group secretary will process the payment. Specialists who do not have a group secretary on site will process the payment. The payment must be processed within 24 hours of receipt.
    1. If the check or money order is made payable to other than "United States Treasury" , the group secretary or specialist will stamp the back of the check with a United States Treasury stamp.

    2. If the payment is being applied to a Form 1023, the group secretary or specialist will prepare a "dummy" Form 1023, page 12, by entering his/her initials, the payment amount, and the applicant’s name and EIN (where appropriate).

    3. If the payment is being applied to other than a Form 1023, the secretary or specialist will prepare a "dummy" Form 8718 by entering his or her initials, the payment amount, and the applicant’s name and EIN (where appropriate). The group secretary or specialist will date stamp the "dummy" page 12 or Form 8718, print the case status from EDS/TEDS, and make copies of these documents to be associated with the case file.

    4. The group secretary or specialist will prepare Form 14267, User Fee Check Transmittal. Group secretaries and specialists will attach the payment and the documents listed in (b) or (c), above.

    5. Group secretaries or specialists outside Cincinnati will send the payment and documents directly to CSPC via overnight mail. If the user fee payment received applies to a case that has been closed Failure To Establish (FTE), the secretary or specialist will indicate on the User Fee Check Transmittal "Case Established in Group Outside of Cincinnati – Process Payment Only." When the payment is entered in LINUS, EDS/TEDS will be updated automatically.

    6. Group secretaries or specialists in Cincinnati will hand-carry the payment and documents to the Processing Section, User Fee Adjuster, in Cincinnati. If the payment received applies to a case that has been closed FTE, the remarks on the User Fee Check Transmittal will indicate "Case Establishment." When the payment is entered in LINUS, EDS/TEDS will be updated automatically.

    7. The group secretary or specialist will follow up within 7 calendar days if the acknowledgement transmitting the user fee payment is not received.

    8. The specialist will document the CCR with the date the user fee payment was received.

7.20.2.9.2  (08-24-2012)
Dishonored User Fee Checks

  1. If a user fee is paid by personal check by the applicant and is returned by the bank for insufficient funds, the Processing Section, User Fee Adjuster, inputs "Y" (Yes) into the Dishonored Check field in EDS and TEDS. This flag will prevent the specialist from recommending the case for approval. The correct user fee must be paid, and this flag must be updated by the User Fee Adjuster before the case can be approved.

  2. IF THEN
    The case is assigned to a specialist The specialist notifies the organization that the check has not cleared the bank and that the organization must pay the user fee either by check or money order.
    1. If the payment is received, the payment is processed as usual. The User Fee Adjuster will update the Dishonored Check flag in EDS to "C" and the case can then be processed as usual.

    2. If the payment is not received, the specialist will notify the applicant that their case is being suspended/closed Failure To Establish for failure to pay the required user fee. An addendum will be added to Letter 4587 or Letter 1314 as follows: "The user fee required to process your application has not been received. A check or money order made payable to United States Treasury must be submitted in the amount of $XXX.XX to continue the processing of your application."

    The case is assigned to a screener in Status 62 The case is returned to the Processing Section, Adjustments Unit.

7.20.2.9.3  (08-24-2012)
Refund of User Fees

  1. Specialists are responsible for determining that the correct user fee has been paid for processing an application. If the applicant overpays the user fee, is not required to pay a fee, or is due a refund in accordance with Rev. Proc. 2012-8, Section 10, the specialist will prepare a User Fee Refund Request, Form 14268.

  2. The specialist will indicate the reason for the refund on the User Fee Refund Request, for example:

    1. the applicant overpaid the required fee,

    2. the fee was paid as a result of an IRS error,

    3. the applicant is already exempt (if it is discovered by the specialist prior to processing the case),

    4. the applicant is covered by a group exemption and does not wish to apply for individual exemption (if it is discovered by the specialist prior to processing the case), or

    5. the applicant is withdrawing its application because it does not wish to pay the higher user fee that is required for processing the application. See (3), below.

  3. If an applicant withdraws its application and is eligible for a user fee refund based on the provisions of Rev. Proc. 2012-8, Section 10, updated annually, a composed addendum will be added to Letter 2244, EO Withdrawal Letter, as a 9001 paragraph.

    Example:

    Based on provisions of Rev. Proc. 2012-8, updated annually, the user fee you paid with your application will be refunded because you chose not to pay the higher user fee required. Your refund is being processed separately.

  4. Refunds will be initiated as soon as it is determined that one is due, with the following exceptions:

    1. when the screener identifies a case for Accelerated/Intermediate processing or full development (non-merit) processing, or

    2. when the financial information provided or the activities of the organization are in question.

  5. When the refund is being initiated, the specialist will take the following actions:

    1. Prepare Form 14268, User Fee Refund Request, and attach the following to the form:
      page 1 of the application,
      page 12, if a Form 1023; Form 8718 if a Form 1024; or, a cover letter if for other than Forms 1023 or Form 1024 (e.g. group ruling), and
      copy of Form 2848 (if applicable)

    2. If the Form 14268, User Fee Refund Request is completed at the time of case closing, prepare Form 3198-A, TE/GE Special Handling Notice, check "User Fee Refund" on Form 3198-A, and attach it to the outside of the file folder.

  6. The determination specialist’s group manager must approve all user fee refunds by signing and dating the User Fee Refund Request.

  7. The specialist, group secretary, or manager will:

    1. Hand-carry the User Fee Refund Request and attachments to the Processing Section, Adjustments Unit. POD’s outside Cincinnati will fax these documents to the Adjustments Unit at 513-263-3522.

    2. Monitor EDS/TEDS for update of the user fee payment flag by the Adjustments Unit,

    3. Follow-up with the manager of the Adjustments Unit if the user fee payment field is not updated within 7 days, and

    4. Close the case in EDS only after the EDS/TEDS user fee payment flag is updated to "C" .

  8. If the applicant claims that a user fee refund is due for other than the reasons listed above, the specialist should follow the waiver of the fee procedures outlined below.

7.20.2.9.4  (08-24-2012)
Waiver of User Fee

  1. The Manager, EO Determinations Quality Assurance (EODQA), maintains authority to approve or deny user fee waiver requests. If the specialist receives a request from an applicant for waiver of an additional user fee, the request will be considered and a recommendation made by the specialist to either approve or deny the request.

    1. The specialist will ensure that the request is signed by an authorized person and that it contains an explanation of the reason for the waiver request including a chronology of events from the date the response was due to the date of the waiver request.

    2. The specialist will consider all facts and circumstances to determine whether a recommendation to approve or deny the request will be made to the Manager, EODQA. The specialist will prepare a Form 14269, User Fee Waiver Request, indicating why the request should be approved or denied.

    3. If the manager agrees with the recommendation, he or she will sign Form 14269 and the case will be forwarded to EODQA via a transmittal. The case will be updated to EODQA in Status 75 (group unassigned inventory) and placed in specialist number 31893 (EODQA’s group unassigned inventory number).

      Note:

      TEDS cases will be transferred in hard copy (see IRM 7.20.2.4.3 (3)).

    4. When the case is returned from EODQA, the specialist will prepare Letter 4721, User Fee Waiver Approval/Denial Letter, advising the applicant of the decision.

  2. If a Service error has occurred, the group manager can approve the waiver by documenting the CCR. The case will not be sent to EODQA but will be processed as usual. Service error may include a lost case or a case that was not reopened when additional information was timely submitted by an applicant in response to a Letter 4587, Suspense Letter for Forms 1023/1024/1025.

7.20.2.10  (08-24-2012)
Expedite Requests

  1. EO Determinations screens determination letter requests in control date order. An organization may submit a request asking for expedited handling.

  2. "Expedited handling" means the assigning of a case ahead of control date order. It does not mean we will make an immediate decision as to the organization’s tax exempt status and does not include assurance that the organization will qualify for exemption or that any letter ruling or determination letter will be processed by the time requested.

  3. "Expedited handling" is limited to those applications that meet the criteria described in Rev Proc. 2012-4, updated annually. For the Service to determine whether the request meets the criteria for expedited handling, the request should include the following information:

    1. nature of grant(s) pending

    2. name/address of grantor(s)

    3. amount of grant or property the organization will receive

    4. date the organization’s determination letter is needed

    5. a description of the adverse impact on the organization’s ability to continue operations if a determination letter is not received on or about the date the organization indicated the letter was needed.

    6. if the purpose is to provide disaster relief, details of the immediate need for disaster relief and of the manner in which the organization will provide relief, and

    7. if Service error, nature of error(s) in detail, including dates.

  4. The Service has discretion for granting a request for expedited handling. The Service may grant a request when a factor outside an organization's control creates a real business need to obtain a letter ruling or determination letter before a certain time in order to avoid serious business consequences.

    1. Examples of situations that will be considered a sufficient reason to process a request ahead of control date order include:

      • A court or governmental agency has imposed a deadline for the completion of a transaction, or

      • A transaction must be completed expeditiously to avoid an imminent business emergency and the need for expedited handling resulted from circumstances that could not reasonably have been anticipated or controlled by the organization.

    2. Examples of situations that will not be considered a sufficient reason to process a request ahead of control date order include:

      • The scheduling of a closing date for a transaction or a meeting of the board of directors or shareholders of a corporation, without regard for the time it may take to obtain a letter ruling or determination letter, or

      • The possible effect of fluctuation in the market price of stocks on a transaction.

  5. Expedite requests are reviewed by designated individuals in the Technical Screening Group, if the request is submitted with the application or received prior to or during the technical screening process.

    IF THEN
    The technical screener closes the case on merit or refers case to Accelerated Processing (AP). No action is taken on the expedite request since these actions constitute expedite treatment.

    Note:

    If the case is not closed in AP and sent to IP or general inventory for full-development, the specialist assigned the case should process any expedite requests received.

    The technical screener approves the expedite request and identifies the case for Intermediate Processing (IP) or general inventory.
    1. The technical screener documents the CCR to reflect the approval of the expedite request, then routes the case to the Correspondence Unit for issuance of an expedite approval letter

    2. The Correspondence Unit then routes case to IP and/or general inventory.

    3. Cases approved for expedite treatment are assigned and worked before other cases.

    Technical screener denies the expedite request and identifies case for IP or general inventory.
    1. Technical screener documents CCR to reflect the denial of the expedite request, then routes case to Correspondence Unit for issuance of an expedite denial letter

    2. Correspondence Unit then routes case to IP and/or general inventory.

  6. Expedite requests are reviewed by the specialist assigned to work the case, if the request is received after the case has been assigned, and it is the specialist’s responsibility to make a recommendation for approval/denial to the group manager.

    IF Expedite treatment is THEN the specialist will take the following actions:
    Denied
    • notify the organization by telephone of the reason(s) for expedite denial

    • document the telephone conversation on the CCR, and

    • process the case in control date order.

    Approved
    • notify the organization

    • process the case ahead of other cases in his/her inventory, and

    • place the case in a pink folder to notify the manager of the expedite approval when the case is submitted for managerial review

7.20.2.11  (08-24-2012)
Adverse Case Overview

  1. Adverse determinations include denials of exemption as well as adverse determinations on foundation status, effective date, section 170 deductibility, section 4945(g) individual grant making procedures, unusual grants, section 4942 set-asides, group rulings and other issues. An organization may receive a favorable determination on exempt status under section 501(c)(3) but receive an adverse determination on other issues.

  2. When a specialist concludes that an adverse determination on exemption and/or foundation classification is likely in a particular case, he/she will discuss the reasons for the adverse determination with his/her group manager. If the group manager concurs that an adverse determination is appropriate, the specialist will proceed with the proposed adverse determination. Involvement of the group manager in the proposed adverse determination should be documented on the CCR.

  3. Specialists will attempt to resolve potential adverse determination cases at the earliest possible time and at the lowest possible level. Therefore, it is advisable to hold an informal telephone conference with an organization prior to issuance of a proposed adverse determination letter. Such a telephone conference will provide the specialist with an opportunity to:

    1. discuss each and every unagreed issue, both primary and alternative, with the organization so that the organization’s position on each unagreed issue can be effectively rebutted in the proposed adverse letter,

    2. explain to the applicant, in the case of a denial of exemption, the disclosure provisions of section 6110. See IRM 7.28.4, Public Inspection of Written Determinations Under IRC 6110.

  4. IF THEN
    The specialist and manager conclude that a telephone conference with the organization to discuss the proposed adverse determination may be beneficial The specialist telephones the organization to discuss the proposed adverse determination. The group manager may or may not be present for the conference. The discussion should include:
    • reasons for the proposed adverse determination,

    • clarification of facts in the case, including activities and purposes;

    • possible alternative tax exempt status under section 501(a);

    • possible alternative foundation status classification under section 509;

    • disclosure provisions of section 6110 (if a proposed denial of exemption); and

    • Appeal Rights

    A telephone conference is held and the organization agrees to submit additional information that will support a favorable determination. Within 5 workdays of the telephone conference, the specialist will prepare and issue Letter 2382 requesting the organization describe in writing any corrections it offered to make in the pre-adverse teleconference. The additional information letter request will have a 14-day response due date.
    A telephone conference is held and the organization states that it has no additional information to submit. Specialist will prepare a proposed adverse determination letter with protest rights within 10 workdays of the telephone conference.
    A telephone conference is held, additional information discussed is submitted, and the specialist and manager conclude that the organization does not qualify for a favorable determination. The specialist will prepare a proposed adverse determination letter with protest rights within 10 workdays of receiving the additional information.
    The specialist and manager concur that a telephone conference is not necessary. The specialist will prepare a proposed adverse determination letter with protest rights within 10 workdays of the decision that a telephone conference is not necessary.

7.20.2.11.1  (08-24-2012)
Preparation of Proposed Denial of Exemption Letter

  1. The specialist will prepare the appropriate proposed denial letter and a redacted copy of the proposed denial letter:

    1. Letter 4036, Proposed Denial of Exemption, Section 501(c)(3)

    2. Letter 4034, Proposed Denial of Exemption, Other Than Section 501(c)(3)

  2. The specialist will follow the general drafting principles and procedural guidance set forth in IRM 7.28.4, Public Inspection of Written Determinations under IRC 6110.

  3. In preparing a proposed denial of exemption, the specialist will generally follow the format below:

    Issues
    • Issues should be posed in the form of a question.

    • Separate issues should be listed if there are separate reasons for the denial or separate issues such as exemption and deductibility.

    Facts
    • State how formed and date formed (corporation, trust, association).

    • State purposes (normally as stated in the organizing document).

    • State any governance issues (e.g., from the bylaws) that affect exemption and/or classification.

    • Summarize the relevant facts as known by the IRS at the end of the development process. Specific dates of IRS and applicant letters during the development of the case are usually not required.

    • If the applicant has a mix of qualifying and non-qualifying activities, the facts section should discuss their relative significance, preferably in percentages.

    • Describe proposed and/or actual income and expenses.

    Law
    • Cite the most pertinent law supporting the denial in the order set forth in IRM 7.28.4. Also, list any precedents that the applicant cited or that seem to favor the applicant. The Code and Regulations may be recited verbatim or partially cited or paraphrased. Revenue rulings, revenue procedures, and court cases should be summarized.

    Application of Law
    • Apply the law to the facts. Describe how the applicant’s situation is similar or dissimilar to the situation described in each citation.

    • If there is a mix of qualifying and non-qualifying activities, explain why the applicant fails to meet the relevant criteria for exemption.

    Applicant’s Position:
    • If the applicant provides law that it believes is applicable to its case, it should be analyzed and briefly summarized in the proposed denial letter.

    Service Response to Applicant’s Position
    • Law provided by the applicant should be directly addressed.

    • A statement should be prepared by the specialist that states where the Service agrees or disagrees with the applicant’s position and explains why the Service position is adverse to the applicant’s position.

    Conclusion:
    • Prepare a brief summary of why the applicant does not qualify for exemption.

    • The conclusion should be succinct and answer the question(s) posed in the Issues section of the proposed denial letter.

7.20.2.11.2  (08-24-2012)
Closing a Proposed Denial of Exemption

  1. In closing a proposed denial, the specialist will take the following steps:

    1. Prepare case according to procedures listed in IRM 7.20.2.4.3(3) for transferring cases to EODQA.

    2. Review proposed denial letter and redacted proposed denial letter for technical, grammatical, and typographical accuracy; readability; and brevity.

    3. Complete Form 14280, EO Determinations Checklist - Denials,

    4. Complete the Checklist for IRC 6110 Written Determinations – Adverse, Exhibit 7.28.4-1, IRM 7.28.4.

    5. Save the proposed denial letter, the redacted proposed denial letter including POA copies, and the Checklist for IRC 6110 Written Determinations using the common format that begins with the EIN followed by the type of letter or form.

      Example:

      nn-nnnnnnn Proposed Denial
      nn-nnnnnnn Redacted Proposed Denial
      nn-nnnnnnn Denial Checklist
    6. Print one copy of the proposed denial letter and one copy of the redacted proposed denial letter.

    7. Prepare an index and tab the right side of the case file.

    8. Acco-fasten the entire right side of the case file excluding the proposed denial letter and the redacted proposed denial letter. See IRM 7.20.2.11.1.

    9. Place proposed denial letter followed by redacted proposed denial letter on top of index.

    10. Complete Form 8670 worksheet and update case in EDS to Status 40. If the organization is exempt under another subsection, and is retaining exemption, the case will be closed Status 12 (rather than Status 40).

    11. Complete Form 3198-A indicating Mandatory Review and identify the case as adverse. If applicable, identify specialty cases.

      Example:

      Adverse - Partnership, Adverse - LLC

  2. After managerial review and approval of the proposed denial:

    1. the specialist or manager will send the following, via encrypted e-mail, to the EODQA Mailbox at *TE/GE-EO-Determinations QA.

      • the proposed denial letter,

      • the redacted proposed denial letter, and

      • the Checklist for IRC 6110 Written Determinations

    2. The subject line of the e-mail should only include the type of composed letter and, if a denial, the UIL specialty category. In the body of the e-mail, specify the name of the case, type of case, and case number.

    3. The Processing section or the group secretary will manually transfer the case to EODQA but must not close the case on EDS.

7.20.2.12  (08-24-2012)
Case File Assembly for Initial "I" Cases

  1. Specialists are responsible for ensuring that documents in a case file are in the proper order and correctly placed in the case file according to case file assembly procedures set forth in this section.

  2. Proper case file assembly:

    • helps managers, reviewers, appeals officers, and others review the case,

    • reduces the risk of an improper disclosure by separating non-disclosable documents from documents that are available for public inspection,

    • ensures a complete administrative record of the case in the hard copy case files sent to the Federal Records Center,

    • facilitates the distribution of documents to other business units as required, and

    • ensures that documents that do not support the determination are purged or discarded.

  3. Non-disclosable documents include, but are not limited to, the following. Note that all documents listed will not be present in every case file. If present, non-disclosable documents are assembled in the following order:

    1. TEDS and manual CCR's in chronological order with oldest date on top

    2. Form 14261, Memorandum to File, EO Determinations Case Closing (required for all full development cases)

    3. Checksheets/checklists/worksheets including, but not limited to:

      • screening checksheets/worksheets (AP/IP/Full Development)

      • Form 14261 or Form 14277 EO Determinations Case Closure Documentation Worksheet

      • private school checksheet/worksheet

      • public support computation worksheet

    4. File copies of internal forms/memoranda and attachments including, but not limited to:

      • Form 5060, Report of Adverse Determination on Private Foundation Status

      • Form 5456, Reviewer’s Memorandum

      • Form 5457, Response to Reviewer’s Memorandum

      • Form 5666, Exam Referral

      • Form 14266, EO Determinations Referral to Review of Operations Unit

      • Form 14271 , EIN Merger Memo

    5. File copies of EOMF/BMF document (e.g., Form 2363 or Form 2363-A) including the group exemption pilot voucher and list of subordinates.

    6. EOMF research prints

    7. Copies of Form 8670 with prior case numbers assigned to the organization

    8. Any other non-disclosable information (e.g., non-disclosable personally identifiable information PII, patents, trade secrets, copies of checks (including user fee checks), and copies of bank statements)

    9. EDS closing worksheet

  4. Information that is open for public inspection is referred to as disclosable documents. Note that all documents listed below will not be present in every case file. If present, disclosable documents are assembled in the following order:

    1. Final determination letters (original plus file copy for the applicant and original plus file copy for each POA authorized to receive a copy).

    2. Publication 4221

    3. Form 2848, Power of Attorney, if filed and properly executed. If not properly executed, see IRM 7.20.1. If a Form 2848 is rescinded during case processing, the rescinded Form 2848 should be placed behind the correspondence stating that it has been rescinded.

    4. Form 8821, Tax Information Authorization, if filed and properly executed. If not properly executed, see IRM 7.20.1. If a Form 8821 is rescinded during case processing, the rescinded Form 8821 should be placed behind the correspondence stating that it has been rescinded.

    5. Form 1023 Checklist (I cases)

    6. Application Form 1023, 1024, or 1028 and all related schedules and attachments

    7. Form 8718 if filed

    8. Organizing document

    9. Amendments to organizing document in chronological order of filing

    10. Bylaws and amendments in chronological order of date adopted

    11. Documentation of nondiscriminatory policy required by Rev. Proc. 75-50 (if applicant operates a private school) or, if applicant operates a charter school, the documents related to the charter agreement.

      Note:

      Most Rev. Proc. 75-50 information will appear after Schedule B or the bylaws. However, facts and circumstances will need to be applied. For example, information imbedded within the text of a letter should remain in the correspondence section.

    12. Form 5768, Election/Revocation of Election by an Eligible Section 501(c)(3) Organization to Make Expenditures to Influence Legislation (file copy). The specialist forwards the original Form 5768 to the Processing Section, Adjustments Unit, upon identification of the Form 5768 in case file. Form 5768 should be transmitted via routing slip (Form 1725) with note to Processing Section to "Forward Form 5768 to Ogden Campus."

    13. Correspondence issued to the organization and correspondence, forms, schedules, and attachments subsequently received from the organization in chronological order with oldest on top.

    14. Printed materials or publications which support the determination including non-scannable items.

    15. Envelope showing the postmark date for section 508/505 purposes, if necessary.

  5. Documents, if present, to be forwarded to other business units are placed in the case file in the following order:

    1. Original forms/memorandum (and attachments) requiring signature and documents to be forwarded to other functions including, but not limited to:

      • Form 5060, Report of Adverse Determination on Private Foundation Status

      • Form 5457, Response to Reviewer’s Memo

      • Form 5666, Exam Referral

      • Form 12412, Operational Assistance Request (OAR)

      • Form 14266, EO Determinations Referral to Review of Operations Unit

      • Form 14271, EIN Merger Memo

    2. Original EOMF/BMF documents to be input (e.g., Form 2363 or Form 2363-A).

  6. During case processing, specialists may need to keep some materials that will be purged at case closing whereas other materials may be discarded. Specialist will clearly label and bundle the items that will be purged at case closing and place them directly behind the disclosable documents.

    1. The following items may be purged at case closing:

      • AIS sheets in the hard copy case file

      • EO Determination Input Sheet

      • Form 14263, Request for Case Establishment on EDS

      • Publications, booklets, brochures, pamphlets, newsletters

      • Leases or reasonable 3rd party agreements not material to the determination

    2. The following items must be discarded by the specialist during processing:

      • Duplicate letters and forms

      • Blank forms and pages

      • Envelopes with no section 508 or section 505 Issues

7.20.2.12.1  (08-24-2012)
Case File Assembly - Initial "I" Cases Established and Worked in TEDS

  1. When a specialist is assigned an "I" case established in TEDS and worked in TEDS, the specialist is responsible for maintaining an orange folder for the purpose of:

    1. storing documents that have not been scanned into TEDS and

    2. storing documents that must be added to the hard copy case file.

  2. The original hard copy case file, which includes all documents originally scanned into TEDS by CSPC, is maintained by the Records Unit.

  3. At case closing, the screener/specialist must print all documents in the case file that were not scanned into TEDS (to be placed on the right side of the orange folder) and all documents in the case file that must be added to the hard copy case file to be placed on the left side of orange folder. See table in (4) below:

  4. The following are procedures for "orange folder case file assembly for cases established and worked in TEDS" :

    • Outside the folder.

    • Inside on the left.

      Note:

      This includes documents forwarded to other business units and that are added to the hard copy file.

    • Inside on the right.

      Note:

      This includes documents are scanned into TEDS.

    OUTSIDE OF FOLDER INSIDE LEFT INSIDE RIGHT
    1. Form 3198-A - If special instructions are required

    2. Full Development Cases: Form 8670 Closing Worksheet

    3. AP/Screening Cases:

      1. Application Identification Sheet (AIS)

      2. 8670 Closing Worksheet - Folded on top of AIS Sheet so that barcode/name on AIS sheet are visible.

    1. Original documents (forwarded to other business units), – see IRM 7.20.2.12(5) for document order.

    2. Non-Disclosable Documents for the Hard copy Case File Control Sheet - All non-disclosable documents that need to be printed from TEDS for the hard copy case file. See IRM 7.20.2.12(3)

    3. Disclosable Documents for the Hard copy Case File Control Sheet - Correspondence (from specialist and organization) or other documents that needs to be printed from TEDS for the hard copy case file. See IRM 7.20.2.12(4) (see note below)

    1. Final Letter Control Sheet-Applicant (Salmon) - Final letter to Applicant and Pub 4221

    2. Final Letter Control Sheet-POA (Salmon) - Final letter to POA (if applicable) and Pub 4221

    3. Final Letter Control Sheet-POA (Salmon) -Final letter to second POA (if applicable) and Pub 4221

    4. Disclosable Documents Control Sheet (Yellow) - Any disclosable documents that have not been scanned into TEDS. See IRM 7.20.2.12(4)

    5. Non-Disclosable Documents Control Sheet (Blue) - Any non-disclosable documents that have not been scanned into TEDS. See IRM 7.20.2.12(3)

    6. Purge materials - see IRM 7.20.2.12(6)

    Note:

    Do not re-print correspondence that was sent to CSPC and scanned into TEDS; CSPC will forward these documents to the Records Unit to include in the hard copy case file. Re-print only correspondence that was generated by the screener/specialist and NOT scanned into TEDS by CSPC.

  5. When the case is approved by the group manager, the group secretary (or Processing Section for Screening or AP/IP cases) distributes documents that require forwarding to other business units, places Form 8670 on top right inside of orange folder, discards purge materials, and transmits the orange folder to the Records Unit.

  6. The Records Unit associates the orange folder with the (brown) hard copy case file folder and forwards both folders to CSPC. After CSPC scans necessary documents into TEDS, both case file folders are sent to the Federal Records Center.

7.20.2.12.2  (08-24-2012)
Case File Assembly – Initial "I" Cases Established in TEDS and Worked as Hard Copy

  1. When a specialist is assigned a case established in TEDS that will be worked as hard copy, the specialist is responsible for maintaining the original hard copy case file folder. When the case is assigned to the specialist, the hard copy case file will include all documents originally submitted by the organization, any documents imported into TEDS by the screener or AP/IP specialist, and documents created in TEDS (such as the case chronology record) by the screener or AP/IP specialist.

  2. In addition to maintaining the original hard copy case file folder, the specialist will create and maintain an orange folder for storing documents that have not been scanned into TEDS.

  3. Case file assembly procedures for the original hard copy case file folder are summarized in the table below:

    Original Hard Copy Case File (Brown) Folder Assembly
    Outside of Folder Inside Left Inside Right
    1. Form 3198-A – If special instructions are required

    2. Full-Development Cases:

      1. Form 8670, Closing Worksheet

    3. Screening/AP Cases:

      1. 8670 closing worksheet - Folded on top of case input sheet so that name/EIN of organization are visible

    1. Documents to be forwarded to other business units – see IRM 7.20.2.12(5)

    2. Non-Disclosable information that has been scanned into TEDS – see IRM 7.20.2.12(3)

    1. Disclosable information that has been scanned into TEDS- see IRM 7.20.2.12(4)

    2. Purge materials - (see IRM 7.20.2.12(6)

  4. Case file assembly procedures for the orange folder are summarized in the table below:

    Orange Folder Case File Assembly
    Outside of Folder Inside Left Inside Right
    (Empty) (Empty)
    1. Final Letter Control Sheet-Applicant (Salmon) Final letter to Applicant and Pub 4221

    2. Final Letter Control Sheet-POA (Salmon) Final letter to POA (if applicable) and Pub 4221

    3. Final Letter Control Sheet-POA (Salmon) Final letter to second POA (if applicable) and Pub 4221

    4. Disclosable Documents Control Sheet (Yellow)

    5. Disclosable information that has NOT been scanned into TEDS

    6. Non-Disclosable Documents Control Sheet (Blue)

    7. Non-disclosable information that has NOT been scanned into TEDS

    Note:

    Colored separator sheets with barcodes used when scanning documents into TEDS should not be photocopied. Each group should maintain a supply of original forms.

  5. At case closing, the properly assembled orange folder is placed within (or behind) the properly assembled hard copy case file (brown) folder, rubber-banded together, and submitted to the group manager.

  6. When the case is approved by the group manager, the group secretary (or Processing Section for Screening or AP cases) distributes documents that require forwarding to other business units, places Form 8670 on top right inside of orange folder, discards purge materials, and transmits the orange and hard copy case file (brown) folders to the Records Unit.

  7. The Records Unit forwards both folders to CSPC. After CSPC scans necessary documents into TEDS, both case file folders are sent to the Federal Records Center.

7.20.2.12.3  (08-24-2012)
Case File Assembly - Initial "I" Cases Not Established or Worked in TEDS

  1. When assigned a hard copy case that has not been established in TEDS, the specialist maintains the original hard copy case file only. An orange folder is not created or maintained.

  2. Case file assembly procedures for the hard copy case file are summarized below:

    Original Hard Copy Case File (Brown) Folder Assembly
    Outside Left Right
    1. Form 3198-A – If special instructions are required

    2. Full-Development/IP Cases:

      1. Form 8670

    3. Screening/AP Cases:

      1. 8670 closing worksheet - Folded on top of case input sheet so that name/EIN of organization are visible

    1. Documents to be forwarded to other business units - see IRM 7.20.2.12(5)

    2. Non-Disclosable information - see IRM 7.20.2.12(3)

    1. Disclosable information - see IRM 7.20.2.12(4)

    2. Purge materials - see IRM 7.20.2.12(6)

  3. When the case is approved by the group manager, the group secretary or Processing Section distributes documents that require forwarding to other business units, discards purge materials, and transmits the hard copy folder to the Records Unit.

  4. The Records Unit transmits the case to CSPC where it is scanned into TEDS then forwarded to the Federal Records Center.

7.20.2.12.4  (08-24-2012)
Case File Assembly – Change in Subsection

  1. If an organization changes its subsection request during case processing, and submits a complete Form 1024 to replace Form 1023 or vice versa, separate folders will be maintained for the "withdrawn" application and the "new" application.

  2. When an Initial "I" case is established for the new application, a new hard copy case file will be created. With the exception of the withdrawn Form 1023 or Form 1024, documents from the original case file (e.g., organizing document, bylaws, correspondence, workpapers) may be transferred to the new hard copy case file unless there are concerns that a denial of exemption or other adverse determination may be issued. In those cases, all documents submitted with or related to the original application will be kept in the original (withdrawn) application folder and the specialist will request re-submission of documents to support the new application as required (e.g., organizing document, bylaws).

  3. The withdrawn application case file will be closed Status 04 (Withdrawal) upon establishment of an "I" case for the new application. A letter is not issued and an orange folder is required only in situations where:

    1. there are documents remaining in the withdrawn hard copy case file that have not been transferred to the new hard copy case file and

    2. those documents have not been scanned into TEDS

  4. After the group manager approves the withdrawal and signs Form 8670, the hard copy case file for the withdrawn application will be returned to the specialist and rubber-banded behind the hard copy case file for the new application.

  5. The new application will be processed according to case processing procedures. It will not be necessary to create an orange folder for the new application since the new application was not scanned into TEDS.

7.20.2.12.5  (08-24-2012)
Case File Assembly – Incomplete Applications

  1. An orange folder will be prepared for TEDS screening cases that are identified as incomplete and returned to the applicant. The screener should include the following documents in the orange folder or in the hard copy folder for non-TEDS cases.

    • CCR

    • Form 14262, EO Determinations - Missing Information Checksheet

7.20.2.12.6  (08-24-2012)
Case File Assembly – Failure to Establish/Suspense Cases

  1. Case file assembly procedures are followed when an Initial "I" case is placed in suspense (Status 37) when the organization has not responded to requests for information and will ultimately be closed FTE if no response is received.

7.20.2.12.7  (08-24-2012)
Case File Assembly - Denial of Exemption and/or Adverse Foundation Status

  1. For TEDS cases, no orange folder is prepared and submitted to EODQA on proposed denials of exemption and adverse foundation status determinations. The case file is maintained as if the case was not established or worked in TEDS (See IRM 7.20.2.12.3) See IRM 7.20.2.11 for additional information on adverse determination case file assembly.

7.20.2.13  (08-24-2012)
Case Closing

  1. A Case Chronology Record (CCR) must be completed for each case to record all actions taken on the case including, but not limited to, case assignment, date case reviewed and letters prepared/mailed, follow up dates, date responses are received, contacts, delays in processing beyond timeframes provided in the IRM, research completed, significant involvement by the group manager, and reasons for excessive or unusual time taken.

    1. Accurate and complete preparation of the CCR is vital to case processing. To ensure legibility, all entries must be typed rather than handwritten. The entries must include in the appropriate columns, dates, action codes, time charged, individuals contacted, and an explanation of the actions taken. For every telephone call, the name of the person contacted and his/her telephone number must be shown.

    2. The total time reflected on the CCR (screener time and specialist time) must be charged to the case on TEDS/EDS when the case is closed. The time charged on the CCR by the specialist working the case will match Form 6490 (full development/non-merit cases).

  2. A Memorandum to File - EO Determinations Case Closing, Form 14261, and/or EO Determinations Case Closure Documentation Checksheet, Form 14277, must be prepared to document risks taken on each case in which exemption is recommended without securing all information identified through clearly established precedent and/or where potential private benefit or inurement issues are not fully developed.

    1. The Form 14261, Memorandum to File is only required on a merit closure case (Status 06 or 09) when there is a Form 14266, EO Determinations Referral to Review of Operations (ROO) referral or risk is taken to approve the case. For merit closure cases, only items 2 and 3 on the Memorandum to File are required.

    2. The entire Memorandum to File must be completed for all Initial "I" full development cases and should include a brief description of the organization’s activities, issues identified and resolutions (if significant), examples of law supporting the determination, and conclusions reached regarding exempt status. An "Issues" section is required whenever a EO Determinations – Referral to Review of Operations Unit (ROO), Form 14266 referral is made.

  3. Prepare Form 3198-A when special instructions are required, such as place case in suspense, process Form 5768, etc.

  4. For TEDS cases, the screener or specialist closing the case will:

    1. print the TEDS CCR,

    2. empty the TEDS "New Documents" folder by moving documents to the appropriate folder,

    3. move all documents in the TEDS Working folder to the TEDS Non-Disclosable folder,

    4. click on the Blue (i) button in TEDS next to the "Case Information" folder to verify the "Entity Data" information (name, EIN, etc.) matches the application. If not, make appropriate changes to the Case Information folder,

    5. assemble the orange folder (see IRM 7.20.2.12),

    6. print the AIS (found in the TEDS Disclosable Folder) and staple it to the front of the orange file folder,

    7. determine and enter the appropriate closing code,

    8. prepare the appropriate closing input sheet

      EDS Closing Worksheet - Letter 947, Form 14285
      EDS Closing Worksheet - Letter 948, Form 14286
      EDS Closing Worksheet - Letter 1075, Form 14287
      EDS Closing Worksheet - Letter 1076, Form 14288
      EDS Closing Worksheet - Letter 4587 and Letter 1314, Form 14289
      EDS Closing Worksheet - Letter 2244, Form 14290
    9. staple the closing input sheet to the front of the orange folder, so the AIS entity information is visible, and

    10. update the case to Status 74PC (Awaiting Managerial Review).

  5. For hard copy cases not worked in TEDS, specialists will:

    1. assemble the case file (see IRM 7.20.2.12), and

    2. prepare the appropriate closing letter and Form 8670 worksheet.

  6. If an OAR (Form 12412) is pending, refer to IRM 7.20.2.18.

  7. For cases being recommended for approval, the specialist must include the applicable Publication 4221 (PC, PF, NC) in the case file/orange folder for each determination letter recipient.

  8. On the same day that a case is updated for closure in TEDS or EDS, the hard copy case file and orange folder, if applicable, must be submitted to the group manager. Each group has a designated place for closed cases.

    Note:

    In those situations where the specialist’s group manager is in different post of duty (POD), the specialist will update the case in EDS to Status 58 (Case in Transit) and transmit the case the same day via overnight mail to the group manager. Upon receipt of the case, the group secretary/Processing Section will update the case in EDS to the proposed closing status and will give the case to the group manager.

  9. If there is more than one case being closed for the same organization, all related cases should be kept together.

  10. If the specialist discovers that the application or request was incorrectly established on TEDS/EDS and a new case needs to be established, a Request for Case Establishment on EDS, Form 14263, is prepared by the specialist and submitted to the Processing Section (either Processing Section pick up or sent to the Processing Section mailbox (*TEGE DETERMINATIONS PROCESSING). Upon receipt of the newly established case, Form 8670 will be prepared for the incorrectly established case: 1) updating the case to EDS Status 30 (Correction Disposal) and 2) given to the group manager for immediate closure.

    1. If time was charged to the incorrectly established case, it should be transferred to the correctly established (new) case.

    2. If a new case does not need to be established and time was charged to the incorrectly established case, the case will be closed Status 12 (Other) on EDS.

7.20.2.13.1  (08-24-2012)
National Taxonomy of Exempt Entities (NTEE) Codes

  1. All cases approved in EDS Status 01, 06, or 09 require a National Taxonomy of Exempt Entities (NTEE) code. These codes are assigned to each section 501(a) organization based on organizational type. They are commonly referred to as the NTEE codes. Special care should be exercised in selecting the appropriate code for each organization as the NTEE coding structure is relied on as a source of data by the IRS Statistics of Income (SOI) Program, the Urban Institute, Guidestar, various grant makers, and many other public and private-sector entities. The NTEE codes can be found on the Internet website of the National Center for Charitable Statistics at www.nccs.org.

  2. NTEE codes should be assigned based on the primary activity of the organization.

  3. If EDS will not accept the identified NTEE code, the specialist should choose the next best code that EDS will accept and elevate the NTEE code that was identified and not accepted to the group manager.

7.20.2.13.2  (08-24-2012)
Suspense/Failure To Establish (FTE) Cases

  1. If all attempts to secure additional information have failed, the specialist will remove all case categories in TEDS Case Information that are associated with an EDS T# (TEDS cases only), complete Form 14289, EDS Closing Worksheet - Letters 4587 and 1314, (staple to front of the case file with a completed Form 3198-A) and update the case to Status 74 (Awaiting Managerial Review).

    1. If the organization is requesting a change in subsection and is, therefore, already exempt, input "990" as the filing requirement on the Form 14289, EDS Closing Worksheet - Letters 4587 and 1314.

    2. Update a full development case on Form 6490 (WebETS) to reflect suspense status by adding "37" before the name of the organization.

    3. If there is an outstanding Operations Assistance Request (OAR), complete Sections V and VI of Form 12412 indicating the case has been placed in suspense and complete Form 3198-A to instruct the Processing Section to "Send Form 12412 and a copy of the suspense letter to Programs and Support" .

  2. If the manager agrees that the case should be placed in suspense, the manager will update the case as follows:

    1. For a TEDS case, the manager will update the case in TEDS to 75 - Group 7848. Cincinnati managers will place the orange folder in the designated case pick up location. Outside POD managers will forward the orange folder to the Adjustments Unit.

    2. For a hard copy case, Cincinnati managers will place the case file in the designated case pick up location. The Adjustments Unit will update the case to status 75 and the Adjustments Unit EDS unassigned inventory number (31848) in EDS. Outside POD managers will update the case in EDS to the Adjustments Unit EDS unassigned inventory number (31848) and forward the case file to the Adjustments Unit. Cases shipped from outside PODs will be updated to Status 58 (Case in Transit) in EDS on the date they are mailed.

  3. Upon receipt of the case file, the Adjustments Unit will:

    • Prepare Letter 4587

    • Make a copy of the last additional information letter for each recipient and for the file copy

    • Update the case to Status 37 (Group Suspense)

    • Stamp all copies of Letter 4587 with the date the case was updated to Status 37 and the signature; add the 90-day response due date; attach a copy of the last additional information letter to Letter 4587; and mail the letter(s)

    • Attach a copy of the last additional information letter to the file copy of Letter 4587 for the administrative record

  4. The case will be held in suspense by the Adjustments Unit for a total of 90 days (unless an extension is granted).

  5. While the case is in suspense, the Adjustments Unit will be responsible for responding to telephone calls and other inquiries regarding the case, including requests for extension of the 90-day response due date.

    Note:

    Letter 4587 includes the Adjustments Unit’s telephone number. If a specialist receives a request for an extension, he/she will complete Form 14265, Request for Extension of 90-Day Response Due Date EO Determinations, and forward it to the Adjustments Unit.

  6. If the Adjustments Unit receives an inquiry that requires technical expertise, the call will be referred to the specialist of record. The specialist will document the phone conversation and actions taken on a new Form 5464-A (CCR) and will forward it to the Adjustments Unit The specialist will input additional time charged on the case on Form 6490 (WebETS). Time will be charged to the case if it is open on WebETS or charged to Telephone/ Correspondence/Other Customer Service (742/0999) if the case has been closed.

  7. If the organization responds during the 90-day timeframe, the Adjustments Unit will reassign the case within 3 workdays of receipt of the response to the specialist of record. The case will be reassigned in either Status 52 or 72 depending on whether the case is AP, IP, or full development. The date of reassignment on EDS will be the actual date of reassignment to the specialist, not the postmark or received date of the response. If a specialist receives a response on a case placed in suspense, it should be forwarded or faxed (outside PODs) promptly to the Adjustments Unit at 513-263-3522.

  8. If the organization does not respond during the 90-day timeframe, the Adjustments Unit will:

    • Prepare Letter 1314 and complete Form 8670 based on the Form 14289

    • Update the CCR to indicate the case is being closed FTE because no response was received and sign the entry

    • Submit the case for managerial review

  9. When the case is closed FTE, the Adjustments Unit will notify the specialist of record via e-mail that the case has been closed. At that time, the specialist will remove the "37" from before the name of the case and close the case on WebETS

7.20.2.13.3  (08-24-2012)
Withdrawals

  1. An organization may request, in writing, withdrawal of its application any time before the determination letter or proposed adverse determination letter is issued. Even though the application is withdrawn, the application and all supporting documents will be retained by the Service and not returned to the applicant. The request must be signed and dated by an officer/director/trustee of the organization.

  2. Determination specialists will not take any direct or indirect action that may be interpreted as a solicitation of a withdrawal of an application. Specialists may, however, discuss with an organization its options which include withdrawing its application. If the option of withdrawing its application is discussed with an organization, the specialist will document the discussion on the Case Chronology Record.

  3. For user fee issues related to withdrawals, see IRM 7.20.2.9.3

    • If the user fee cannot be refunded, the organization should be advised. Also, the organization should be advised that the application will not be processed further.

    • If a user fee refund is due, complete a User Fee Refund Request and compose addendum to Letter 2244.

  4. Prepare Form 2363 to have appropriate filing requirements added to the Business Master File, if there is an organizational document.

    Note:

    The filing requirement for homeowners’ associations electing to file Form 1120-H is 1120 -10.

  5. If the organization is already exempt and is withdrawing a request for change in subsection, the specialist will prepare EDS Letter 2244 acknowledging that the application has been withdrawn. The letter should include an addendum stating that exemption under section 501(c)(X) is still in effect.

  6. If during processing of an application it is discovered that an organization is already exempt, the specialist will take the following actions:

    1. notify the organization by telephone that it is already exempt, that a user fee refund will be issued, but that no letter will be issued.

    2. document the conversation with the organization on the CCR,

    3. prepare Form 14268, User Fee Refund Request, and

    4. close the case Status 12 with no letter

7.20.2.13.4  (08-24-2012)
Managerial Review/Return of Cases

  1. After a case is submitted for closure, suspense, reassignment to another group, or forwarding to EO Technical, the group manager or other designated individual will have 5 workdays to review the case and take necessary action.

  2. Upon review of the case, the group manager or delegate will:

    1. approve the recommended action,

      Note:

      See IRM 7.20.2.13.2(2) for transferring Suspense/FTE cases.

    2. place the orange folder in the designated bin within the Group for pick-up by the Processing Section (Cincinnati Groups), or

    3. return the case to the specialist to have procedural errors corrected or to have further technical development completed. The case will be returned to the specialist either with a:

      • Post-it note identifying minor corrections to be made. This type of case will be hand-carried/electronically transferred to the specialist for correction. The necessary changes must be made promptly and the case returned to the group manager for closure the same day, or

      • Feedback Comments Sheet describing corrections and/or further development required.

    4. return the case to the specialist in one of the following EDS status codes:

      • Full development cases – Status 53

      • Initial screening cases – Status 64

      • Accelerated/Intermediate Processing cases – Status 73

  3. The specialist will review the Feedback Comments Sheet provided by the manager/delegate and take the following actions within 5 workdays:

    IF THEN
    The specialist agrees with recommended corrections and/or further development The specialist will make necessary corrections and/or initiate further development required. When needed corrections and/or further development are complete, specialist will update TEDS/EDS and resubmit case to manager.
    The specialist needs clarification on manager/delegate comments The specialist will discuss with manager/delegate
    The specialist disagrees with manager/delegate comments The specialist will discuss his/her position with the group manager

7.20.2.13.5  (08-24-2012)
Preparation of Closing Letter and Document for Cases Worked In TEDS

  1. After the manager or delegate approves the case, the group secretary or Processing Section will have 5 workdays to prepare the closing letter and closing document and to close the case on EDS or to forward cases identified for Quality Measurement review or mandatory review to EO Determinations Quality Assurance

  2. When a TEDS case is selected in EDS for Quality Measurement review by EODQA at closure, the following actions are taken:

    1. For groups outside of Cincinnati or cases closed directly by groups in Cincinnati:

      The group secretary/group will place the determination letters and closing worksheet in the orange folder.
      The group secretary/group will prepare Form 3198-A notating under Special Instructions: "Forward to Records Unit for association with hard-copy file and send to EODQA - SQMP/DQMP" . Staple Form 3198-A to the front of the orange folder
      Records Unit will place hard-copy scanned responses in the hard-copy case file (if not already completed) and will associate the hard-copy file with the orange folder.
      Records Unit will forward the orange folder and hard-copy case to EODQA.
    2. If case is closed by the Processing Section, since the hard-copy case file is associated with the orange folder before the closing letter/document is prepared, the Processing Section must ensure all hard-copy responses are placed in the hard-copy file before the case is forwarded to EODQA.

7.20.2.14  (08-24-2012)
Commonly Used Forms

  1. Commonly used forms in determination letter processing are listed in the table below. See IRM 7.20.2.12, Case File Assembly, for specifics on where each of the forms is placed in the case file

    Form Description/Use
    Form 1725, Routing Slip A transmittal sheet (also known as a buck slip)
    Form 2363, Master File Entity Change This form is used to make changes (names, addresses, dates, etc.) to the Business Master File (BMF) and Individual Master File (IMF). The completed form is forwarded to the Processing Section, Adjustments Unit for input into IDRS.
    Form 2363-A, Request for IDRS Input for BMF-EO Entity Change This form is used to establish or change the EO sub-module or entity information on the Business Master File (BMF). If changes are needed to the EO sub-module or Master File entity but the closing action on EDS does not provide a second screen, Form 2363-A is required. Group Rulings (IRM 7.20.3.7.6) and section 507(b)(1)(B) Termination closures (IRM 7.20.3.6) require completion of a Form 2363-A. The completed form is forwarded to the Processing Section, Adjustments Unit for input into IDRS. See IRM 25.7.2.3 for detailed instructions on preparation of Form 2363-A.
    Form 2848, Power of Attorney and Declaration of Representative This form is used to designate individuals to represent an organization. If Form 2848 authorizes representation for Form 990 and/or other returns, see IRM 7.20.1.7.2 for instructions on processing Form 2848 to the Centralized Authorization File (CAF).
    Form 3198-A, TE/GE Special Handling Notice Provides special handling/routing instructions for certain cases (e.g., mandatory review, EO Technical referrals, Exam/ROO referrals, cases with user fee refund, etc.)
    Form 3778, EO Technical Transmittal Memo A transmittal memo that explains why a case is being referred to EO Technical pursuant to IRM 7.20.1.4.2.
    Form 5456, Reviewer’s Memo This form is prepared by EO Determinations Quality Assurance to return a case to a group or to make an advisory on a case.
    Form 5457, Response to Reviewer’s Memo This form is prepared in response to an EO Determinations Quality Assurance inquiry.
    Form 5464-A, Case Chronology Record (CCR) Included in every case file to record all actions taken on the case.
    Form 5768, Election/Revocation of Election by an Eligible Section 501(c)(3) Organization to Make Expenditures to Influence Legislation This form is used by section 501(c)(3) organizations to make an election under section 501(h) regarding their expenditures for legislative activities. If a Form 5768 is included with an application or received by a specialist during case processing, the specialist will prepare a Form 3198-A when the case is closed with instructions to "Forward Form 5768 to Ogden Campus."
    Form 8670, EO Control Sheet This form is an EDS-generated closing sheet attached to the outside front of all closed case files.
    1. For Initial cases established in TEDS, the specialist prepares a Form 8670 closing worksheet (Form 14285 -14292). When the case is approved by the group manager, the group secretary/Processing Section will input the closing worksheet data into EDS.

    2. For cases established on EDS, the specialist inputs Form 8670 closing data directly into EDS when the case is closed to the group manager.

    3. Form 8670 is not prepared for cases transferred to EO Technical.

    Form 14259, EO Determinations Screening Checksheet Checksheet used for initial screening of cases.
    Form 14260, EO Determinations Screening Checklist - Financial Literacy EO Determinations Screening Checklist for cases where organization conducts financial literacy activities other than as a primary activity.
    Form 14261, Memorandum to File - EO Determinations Case Closing Items 2 and 3 of this form must be prepared for all merit closures where a Review of Operations (ROO) referral is made or where risks are taken to approve the case. The entire form must be completed for all Initial “I” full development cases and should include a brief description of the organization’s activities, issues identified and resolutions (if significant), examples of law supporting the determination, and conclusions reached regarding exempt status.

    Note:

    An "Issues" section is required whenever a Review of Operations (ROO) referral is made.

    Form 14262, EO Determinations - Missing Information Checksheet Checksheet for EO Determinations specialist to identify missing items when a case is being returned as Incomplete.
    Form 14263, Request for Case Establishment on EDS Form used to request establishment of case on Exempt Organizations Determinations System (EDS)
    Form 14264, Request for Employee Plans or Exempt Organizations Administrative File Form requesting closed administrative file for Employee Plans or Exempt Organizations Determinations Case, from EO Determinations Records Unit.
    Form 14265, Request for Extension of 90-Day Response Due Date EO Determinations Form for transmitting action on request to extend due date for response to an Exempt Organizations Determinations adverse letter.
    Form 14266, EO Determinations - Referral to Review of Operations Unit Form for EO Determinations specialist to recommend follow-up contact by Review of Operations Unit in EO Examinations.
    Form 14267, User Fee Check Transmittal Form Form used to transmit user fee checks from EO Determinations to TEGE User Fee Adjustments Unit.
    Form 14268, User Fee Refund Request Form used to process requests for refund of user fees paid.
    Form 14269, User Fee Waiver Request Form used to process requests for waiver of user fees paid.
    Form 14270, EO Determinations - Section 509(a)(3) Screener Checklist Checklist used in screening cases involving requests for foundation status classification under section 509(a)(3) of the Internal Revenue Code.
    Form 14271, EO Determinations EIN Merger Memo Memorandum from Exempt Organizations Determinations to EO Branch Entity Manager requesting consolidation of two EIN accounts assigned to one entity.
    Form 14272, EO Determinations Group Case Request Form Form for Exempt Organizations Group Manager requesting that cases be assigned to group.
    Form 14273, EO Determinations Screening Checklist – Hedge Funds EO Determinations Screening Checklist for Form 1023 cases involving organizations with investments in hedge funds
    Form 14274, EO Determinations Checklist – Cases Requiring Intermediate Processing Checklist used by screeners for cases requiring intermediate processing.
    Form 14275, EO Determinations Accelerated Processing Checksheet – Form 1024 Cases Checksheet used by to process certain Form 1024 exemption application cases.
    Form 14277, EO Determinations Case Closure Documentation Worksheet Worksheet used to document issues addressed in processing case.
    Form 14278, EO Determinations Worksheet – Closure of Incomplete Cases Worksheet used to document processing steps in closing incomplete cases.
    Form 14279, EO Determinations Checklist for Screening Potential Credit Counseling Cases Checklist used to process certain cases involving possible credit counseling issues/organizations
    Form 14280, EO Determinations Checklist - Denials Checklist used to document steps taken in cases involving denial of exempt status.
    Form 14281, EO Determinations Checklist – Donor Advised Funds Cases Checklist used to document consideration of certain donor advised funds issues.
    Form 14282, EO Determinations Intermediate Processing Checksheet – Section 509(a)(3) Status Issues Checksheet used to process certain cases involving section 509(a)(3) Foundation Status Issues
    Form 14283, EO Determinations Accelerated Processing Checksheet – Form 1023 Cases Checksheet used to process certain Form 1023 exemption application cases.
    Form 14284, EO Determinations Credit Counseling Intermediate Processing Checksheet Checksheet used to process certain credit counseling cases.
    Form 14285, EDS Closing Worksheet – Letter 947 Closing worksheet for case closed with issuance of EO Determinations Letter 947.
    Form 14286, EDS Closing Worksheet - Letter 948 Closing worksheet for case closed with issuance of EO Determinations Letter 948.
    Form 14287, EDS Closing Worksheet, Letter 1075 Closing worksheet for case closed with issuance of EO Determinations Letter 1075.
    Form 14288, EDS Closing Worksheet, Letter 1076 Closing worksheet for case closed with issuance of EO Determinations Letter 1076.
    Form 14289, EDS Closing Worksheet - Letters 4587 and 1314 Closing worksheet for case closed with issuance of EO Determinations Letter 4587 or Letter 1314.
    Form 14290, EDS Closing Worksheet - Letter 2244 Closing worksheet for case closed with issuance of EO Determinations Letter 2244.
    Form 14291, List of classification and Foundation Status Codes Used EDS Closing Worksheet - List of Classification and Foundation Status codes used.
    Form 14292, EDS Closing Worksheet - List of Selective Paragraphs Used EDS Closing Worksheet - List of selective paragraphs used.

7.20.2.15  (08-24-2012)
Commonly Used Letters

  1. Commonly used determination letters are listed in the table below. See IRM 7.20.2.12, Case File Assembly, for specifics on where determination letters are placed in the case file.

    Letter Description/Use
    EDS Letter 947, 501(c)(3) Exemption With Definitive Ruling of Public Charity Status EDS-generated determination letter informing an organization that it is exempt from federal income tax under section 501(c)(3) of the Internal Revenue Code and it is not a private foundation.
    EDS Letter 948, Determination Letter for non- 501(c)(3) Organizations EDS-generated determination letter informing organization that it is exempt from federal income tax under section 501(a) of the Internal Revenue Code [other than section 501(c)(3)].
    EDS Letter 1075, 501(c)(3) Exemption – Private Operating Foundation EDS- generated determination letter informing an organization that it is exempt from federal income tax under section 501(c)(3) and classified as a private operating foundation under section 4942(j)(3).
    EDS Letter 1076, 501(c)(3) Exemption – Private Foundation EDS-generated determination letter informing an organization that it is exempt from federal income tax under section 501(c)(3) and classified as a private foundation.
    Letter 1312, Request for additional information, 501(c)(3) and 501(a) Letter used to request additional information needed to determine if organization is exempt under section 501(c)(3) or 501(a).
    EDS Letter 1314, Final Failure to Establish (FTE) Letter used to inform organization that exemption application will be closed for failure to supply requested information.
    EDS Letter 2244, Withdrawal Letter EDS-generated letter to acknowledge withdrawal of an application for exemption.
    Letter 2382, Second and Subsequent Requests for Additional Information Letter used for second and subsequent requests for additional information.
    Letter 4034, Initial Adverse Determination Letter Under Section 501(a) other than 501(c)(3) Initial letter used when an applicant for exemption under section 501(a) [other than 501(c)(3)] does not qualify.
    Letter 4036. Initial Adverse Determination Letter Under Section 501(c)(3) Initial letter used when an applicant for exemption under section 501(c)(3) does not qualify.
    Letter 4423, 14-Day Follow-Up Letter Letter used to follow-up when requested information with respect to an application for exemption has not been received.
    Letter 4587, Initial Failure to Establish (FTE) Letter Letter issued to place an applicant's status in suspense for 90 days because the organization failed to respond to requests for information.
    Letter 4720, Denial of 90-Day User Fee Extension Letter used to deny a request for extension of the 90-day user fee date.
    Letter 4721, User Fee Waiver Approval/Denial Letter Letter used to approve/deny a request for waiver of a user fee.
    Letter 4799, Approval of 90-Day User Fee Extension Letter used to approve a request for extension of the 90-day user fee date.

7.20.2.16  (08-24-2012)
Requesting Administrative Files

  1. Closed EO Determinations case files are stored in several ways:

    1. Prior to July 2004 - all closed cases are stored on DVD

    2. Post July 2004 – cases are either available in TEDS or the hard copy is stored in the EP/EO Determinations Processing Section or at the Federal Records Center.

  2. Material information received for closed cases should be forwarded to the Processing Section, Records Unit, to be added to the Administrative File.

  3. Specialists will take the following actions if they need an Administrative File:

    IF THEN
    Case was closed before 7/2004 Complete a Request for EP/EO Administrative File, Form 14264.
    I & S case closed after 7/2004 Check TEDS. If case cannot be found on TEDS, complete a Request for EP/EO Administrative File, Form 14264.
    A, F, P, T cases closed after 7/2004 Complete a Request for EP/EO Administrative File, Form 14264.

7.20.2.17  (08-24-2012)
EO Returns Processing

  1. Exempt organizations, other than private foundations or excepted organizations, must file an annual information return on Form 990, Form 990-EZ or Form 990-N.

    • An organization whose gross receipts are normally more than $50,000 is required to file a Form 990 or 990-EZ.

      Note:

      Organizations classified under section 509(a)(3) are required to file Form 990 or Form 990-EZ regardless of their gross receipts.

    • Small tax-exempt organizations with gross receipts under $50,000 must file Form 990-N, Electronic Notice e-Postcard.

  2. Regardless of their annual gross receipts, all exempt organizations that incur unrelated business income in excess of $1,000 are required to file Form 990-T.

  3. Private foundations are required to file Form 990-PF annually regardless of their gross receipts.

  4. Returns are not generally solicited through the determination process. However, if an original return is received, it should be date stamped and forwarded to the Ogden Campus for processing. The date stamped on the return should be the postmark date on the envelope or the IRS received date if there is no postmark evident or legible. After date stamping the return the specialist will:

    1. complete a routing slip (Form 1725) and forward the date-stamped return to: Ogden Campus, Ogden, UT 84201-0027 and

    2. keep a copy of the return in the case folder if it contains vital information not found elsewhere in the open case. It is not necessary to keep a copy if there is no open case.

7.20.2.18  (08-24-2012)
Taxpayer Advocate Service (TAS), Governmental Liaison (GL), Disclosure, Media Relations, and Criminal Investigations Inquiries

  1. TE/GE, EO Determinations, designates a contact person for Taxpayer Advocate Services (TAS), Governmental Liaison, Disclosure, Media Relations, and Criminal Investigations inquiries. The designated contact person is assigned to the EO Determinations Programs and Support group. Telephone calls, correspondence, or emails related to these type inquiries should be forwarded to the EO Determinations, Programs and Support group.

7.20.2.18.1  (08-24-2012)
Operations Assistance Requests (OAR)

  1. TAS uses the Operations Assistance Requests (OAR) process to refer cases to EO Determinations when TAS lacks either the statutory or delegated authority to resolve an organization’s problem. TAS utilizes Form 12412, Operations Assistance Request, to initiate the OAR process.

  2. If the OAR relates to an open application assigned to an EO Determinations specialist, the specialist takes the following actions:

    1. forwards a copy of all correspondence sent to the organization to the TAS caseworker,

    2. negotiates response/follow up dates with the TAS caseworker, and

      Note:

      For Suspense/FTE cases, notify the TAS caseworker that the case is being placed in suspense, explain suspense/FTE procedures, and negotiate a new completion date that covers the 90-day period, if necessary.

    3. for cases being closed:

      • completes Sections V and VI of the OAR,

      • attaches a copy of the completed page 2 of the OAR and a copy of the determination letter to a copy of the OAR transmittal sheet,

      • clips these documents together and places on the left-hand side of the closed case folder, and

      • prepares Form 3198-A with instructions to forward completed OAR and determination letter to the EO Determinations TAS Liaison upon approval of the case by the group manager.

7.20.2.18.2  (08-24-2012)
Taxpayer Advocate Orders (TAO)

  1. When TAS determines that TE/GE or other operating division is not taking appropriate timely action on an issue for which TAS has issued an OAR, they may issue a Taxpayer Advocate Order (TAO) instructing TE/GE or other operating division to take immediate action to resolve the issue. If an EO determinations specialist or manager receives a TAO, it should be immediately forwarded to the Manager, EO Determinations, who will address the TAO.

7.20.2.18.3  (08-24-2012)
Other TAS Requests

  1. If a determination specialist receives telephone or e-mail communication from a TAS caseworker regarding an open case in the specialist’s inventory, the specialist can provide the information to the caseworker as long as that caseworker has an open control on the case in question in his/her inventory. This is covered under need to know in IRM 11.3.22.4.1. The specialist should ask the caseworker for the TAMIS Case File Number to document the CCR.

Exhibit 7.20.2-1 
Case Assignment Guide (CAG) Case Grading Criteria Matrix

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Exhibit 7.20.2-2 
EO Determinations Case Assignment Guide (CAG) Summary

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≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

  • ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡   ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
    ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡    
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

Note:

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
  ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡  
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
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