Example:

(2) Assume the same facts as Example (1) but in addition, the organization refuses to extend the statute of limitations after both the examiner and Appeals coordinated their solicitations to extend the statute for their respective short statute returns. The statute expiration date is within 90 days and the revocation matter is not yet settled. The examination group wants to issue an SNOD for income tax. The examination group can inform Appeals of its plan to issue an SNOD because the communication is restricted to the prospect, method and timing of issuing a SNOD. Protecting the government's interest for separate returns sharing the same statute date is a procedural matter. The communication is permissible so long as the substance of issues and the contents of the SNOD are not discussed. See section 2.03(2)(a) of Rev. Proc. 2012-18.