Example:

(5) Assume in Example (4) that Appeals has issued a 90-day final adverse determination letter (FADL) notifying XYZ of the final revocation of its exempt status. Because Appeals is closing its case, Appeals is no longer primarily responsible for protecting the statute of limitations for the 2014 income tax. T now assumes primary responsibility for protecting the statutes for both the 2014 and 2015 income tax while Form 1120 SFR returns in T’s inventory. Appeals’ issuance of a FADL does not suspend the statute of limitations for any tax year. Only Mandatory Review’s or T’s issuance of a 90-day SNOD will suspend the statute of limitations for assessment if the taxpayer won’t extend the statute.

If the organization refuses to extend the ASED for short statute converted tax returns, discuss your next course of action with your manager. Generally, you will prepare the tax case for closure to Mandatory Review for issuance of a SNOD in order to protect the government's interest, even if the revocation issue is undecided in Appeals.