Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
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If the case is unagreed, an index is also required. See Exhibit 4.70.14-36, EO Sample Administrative Record Index through Exhibit 4.70.14-38, EO Examples of Documents Not Included in the Administrative Record and Solutions for Getting the Documents or Information Included.
EO: Declaratory judgment rights for IRC 501(c)(3) organizations have been extended to all 501(c) & (d) organizations under the PATH Act of 2015.
EO: We no longer modify the exempt status of an organization which is:
Not exempt under the code section for which it was granted exempt status.
Filing its return under another code section.
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