EO Secure Email message from Manager, Mandatory Review, to Area Managers Regarding the…

Subject: Central Organization Revocation, Final Adverse Determination Letter Issued

On [insert date], Mandatory Review issued a 90- day adverse final determination letter proposing revocation to [insert name of central organization]. Under Rev. Proc. 80-27, the group exemption is terminated. Any organization under GEN [insert GEN] will now be updated to EO BMF status 28 and be subject to a Form 1120 filing requirement.

Please check your inventory to see if you have any subordinate organizations included in the group ruling of the aforementioned parent under examination. If you have cases in status 10, please survey the case. If you have cases in status 12, continue to pursue any excise and/or employment taxes. For income tax purposes for years prior to [insert effective date of revocation], continue to pursue unrelated business income. For years after that date, follow the instructions in IRM 4.70.14.2.1.3.3 for converted returns. For any cases where you are pursuing revocation but no taxes, survey the case. The appropriate closing letter is a custom letter.