Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
The presence of a Form 990-T examination only impacts what goes on the proposed revocation or disqualification RAR and on the 3198-A Special Handling checksheet in RCCMS for the primary return case file. It has no effect on conversion procedures.
Incorporate the UBIT issue as an alternate position in the revocation or disqualification report. See IRM 4.70.14.2.1.3.3.8, EO – Converted Tax Return Secured – To Be Further Adjusted. Include Form 990-T at the heading of Letter 3618.
If there is no change to UBIT under examination, include a statement to that effect after the conclusion part of the revocation or disqualification RAR.
If there is a UBIT deficiency, include the deficiency as your alternative position after the conclusion part of the revocation or disqualification RAR, complete with facts, law and argument and Form 4549 marked "Alternative Position" in the top margin.
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