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Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

While the adverse status change issue is working in Appeals, the converted return tax case will still be on NMF. You must process that closure on NMF unless and until the revocation is sustained and posted to the EOBMF.

If the statute is imminent you must issue the SNOD. See IRM 4.70.12.3.7.11, EO Imminent Statute, for approval procedures. See IRM 4.70.14.6.6.1, SNOD Preparation and Issuance, for SNOD preparation procedures. Upon issuance of the SNOD, close the income tax case to Mandatory Review for 90-day suspense (AIMS Status 24) within 5 business days.

Appeals will notify EO Examinations if the organization has no intention to execute a consent to extend the statute date by the earlier of:

120 days prior to the statute expiration date.

The date Appeals sends its case to TEGEDC for review of the 90-day FADL.

Appeals will also inform EO Examinations:

If and when the adverse status change was approved by TEGEDC, and

When it issues a 90-day FADL.

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