Caution:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
The SFCR will have an ASED based on the filing of Form 990 or 990-EZ.
The decision to initiate deficiency procedures requires managerial approval.
Establish the SFCR on NMF pending finality of adverse status change. Managerial approval is required. You establish a converted tax return on NMF because you recognize the need to protect the converted tax, but your underlying proposed adverse status change is not yet final and posted. While the adverse status change is not final, generally don’t submit a 30-day letter and RAR to the organization, and don’t solicit an agreement to a tax adjustment until you know the adverse status change is sustained by Mandatory Review (or Appeals if protested). To establish the Form 1120 on NMF (Pending Finality of Adverse Status Change) in RCCMS:
Validate For: Establish.
Update AIMS: Unchecked.
Type: Form 1120.
Activity Codes: 338, 203 through 231 [For Form 1041, 495 or 496].
Statute date: The statute date is assumed to be the same as the statute date for the EO information return. If the organization is a non-filer, it is the date the tax return will be postmarked or filed with the examiner.
Master File type: NMF – Non-Master File.
MFT Code: 32 (Form 1120 NMF), or 21 (Form 1041 NMF).
Source Code: 44.
Status Code: 10.
Reason for Request: Protective AIMS establishment for Conversion of Form 990 to Form 1120 ; Case suspended while revocation is unagreed.
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