If the organization...

Then...

Agrees

Stamp the received date on Form 870 or Form 870-E.

Issue Letter 2511, with copy of signed waiver form.

Prepare RCCMS Closing Record for converted tax return, DC 102.

Complete ARDI Code, on RCCMS Closing Record.

Close tax case to the EO Closing Unit

Fails to reply

Prepare RCCMS Closing Record for converted tax return, DC 604.

Close tax case to Mandatory Review to issue the SNOD.

Disagrees - Provides NO new information, or provides additional information that does not change your report

Issue Letter 5918 rebuttal to organization.

Prepare RCCMS Closing Record, for converted tax return, DC 601 or DC 604.

Close tax case to Mandatory Review to issue the SNOD.

Disagrees - Provides additional information showing no tax adjustment was necessary

Issue Letter 2656.

Prepare RCCMS Closing Record, for converted tax return, DC 107.

Close tax case to the EO Closing Unit.

Disagrees - Provides additional information that decreases the tax

Issue a corrected RAR only. Don’t issue a new 30-day letter.

Issue Letter 5918 rebuttal to organization over the part of the deficiency that remains unchanged.

Prepare RCCMS Closing Record for converted tax return, DC 07 (601) or DC 10 (604).

Close tax case to Mandatory Review to issue the SNOD.

Disagrees - Provides additional information that increases the tax

Issue a new 30-day letter, Letter 950 or Letter 3614 and a corrected RAR.

Suspend tax case for 30 days pending reply to new proposal.

Refer back to this table after organization responds.

With respect to an adjustment to a Form 990-PF converted tax return in subparagraph (6)c, the adjustment need not be limited to IRC 4940 tax, which is subject to deficiency procedures. You can also adjust non-tax items, such as the reported distributable amount, qualifying distributions, or undistributed income. If adjusting non-tax items is the only adjustment, the adjustment is subject to a nonstandard 30-day letter, with protest to Appeals, but not subject to issuance of a final 90-day letter by Mandatory Review. Consult with *TEGE EO Review Staff on a nonstandard 30-day letter. Any IRC 4942 tax resulting from non-tax adjustments is reported separately on Form 4720, which is subject to full deficiency procedures.