Note:

TEGEDC must approve a formal examination report and closing letter for a church for issues covered under IRC 7611 before Mandatory Review issues it within the two-year examination period. Submit a proposed adverse determination to Mandatory Review at least 120 days before the two-year period expires.

After issuing an initial examination report, create a formal examination report by modifying the initial examination report based on any taxpayer responses. These modifications can include, but aren't limited to:

Corrections of facts stated.

Changes in expense allocations.

Additions or subtractions of items (income, expenses, reclassified workers).

Additions of legal references.

Recomputations of taxes.

Additions to the taxpayer's position.

Revisions of the government's position to rebut the taxpayer's position.