Example:

(3) Examiner T is examining XYZ’s 2014 Form 990. XYZ is exempt under IRC 501(c)(3). T determines XYZ’s exempt status should be revoked effective 1/1/2014. Based on T’s examination of the 2014 books and records, T estimated XYZ’s income tax liability for 2014 to be $6,000. After inspecting the 2015 Form 990 return alone, T also estimates the income tax liability for 2015 to be $8,000. To protect the income tax for both tax years, T establishes the 2014 and 2015 Form 1120 SFR on AIMS Non-Master File for later adjustment pending the final outcome of your proposed revocation. XYZ appeals T’s proposed revocation. T closes the Form 990 case file to Mandatory Review, with the Form 1120 case file riding with the package. Mandatory Review later forwards the Form 990 case file to Appeals. Two months later, both the 2014 Form 990 and the 2014 SFR Form 1120 become short statute returns. Because Appeals has primary responsibility for protecting the statute for income tax in 2014, T may initiate contact with Appeals to follow-up on their request to extend the statute of limitations for income tax for 2014 without violating ex parte rules.