EO – Revocations, any other loss of tax exemption, and foundation reclassifications
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
In general, EO Mandatory reviewers prepare and issue 90-day letters for unagreed without protest cases, with these exceptions:
Special Review prepares and issues 90-day letters in cases they reopen.
The FSL/ET group manager approves all final adverse employment tax determinations (pending Counsel approval). The Reviewer date stamps and mails the Notice of Determination of Worker Classification (NDWC).
Groups holding short statute cases prepare and issue the 90-day letters. The Area Manager approves and signs 90-day letters. Examiners work directly with Counsel on cases with imminent statute.
Don’t prepare 90-day letters for unagreed employment tax deficiencies - non-worker classification, and for miscellaneous excise taxes, such as gaming excise taxes. In these situations, the 30-day letter serves as the final letter if not protested.
Mandatory Review Statute Coordinator- When you receive a case from a group:
Acknowledge receipt of Form 3210, Document Transmittal.
Return one copy of the Form 3210 to the group.
Upload it to the Reporting Compliance Case Management System (RCCMS).
Verify the assessment statute of expirations date (ASED). Notify the Mandatory Review manager if statute procedures (including proper use of alpha code "PP" ) aren’t followed.
Get a plain-English answer with a citation back to this text.
Ask AI about this code