Note:

For purposes of the FADL, treat IRC 7428 declaratory judgment cases as unagreed even if you received a signed Form 6018, Consent to Proposed Action, except that TEGEDC review of cases with a signed Forms 6018 is not required.

Upon issuing a 90-day FADL to an organization, perfect the case file.

Check for a completed Form 2363-A, Request for IDRS Input for BMF/EO Entity Change

Make corrections as needed or prepare a new Form 2363-A.

See Exhibit 4.70.14-46, EO Form 2363-A Instructions: IRC 501(c)(3) Revocation or Exhibit 4.70.14-47, EO Form 2363-A Instructions: IRC 501(c)(3) Foundation Status Modification, for instructions in preparing Form 2363-A.

Sign and email Form 2363-A to the *TEGE FAST unit for processing. Your signature assures the FAST you reviewed the adverse determination.

When you've finished creating the 90-day letter package, save it along with any power of attorney cover letters in the RCCMS Office Documents folder and re-index the administrative record, if necessary. See IRM 4.70.14.2.1.5.9, EP & EO Administrative Record.

Prepare a brief memo to Area Counsel requesting pre-issuance review of the 90-day letter. See Exhibit 4.70.14-41, EO Memorandum to TEGEDC. Consult Chief Counsel's website for the appropriate TEGEDC office: http://ccintranet.prod.irscounsel.treas.gov/OrgStrat/Offices/TEGE-DC/General%20Documents%20and%20Links/Area%20Counsel%20Geographic%20Jurisdiction%20Map.pdf.