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

Subject: Central Organization Revocation Final

On [insert date], Mandatory Review issued a 90-day final adverse determination letter proposing revocation to [insert name of central organization], which did not file a petition with the courts. Under Rev. Proc. 80-27, the group exemption is terminated. Any organization under GEN [insert GEN] is to be updated to EO BMF status 28 and is 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 subsequent years, see IRM 4.70.14.2.1.3.3 for converted returns. If pursuing revocation but no taxes, survey the case. The appropriate closing letter is a custom letter.