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EP – Solicitation of Form 1041

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

If your examination results in the proposed revocation/non-qualification of a trust’s tax-exempt status and the issue couldn’t be resolved under EPCRS or a DO 8-3 closing agreement, the trust becomes taxable and the trustee must file Form 1041 for all open years.

Forms 1041 are filed on a calendar year basis per IRC 644(a).

The statute of limitations on the trust year runs with the filing of the Form 5500 for the plan year in which the trust year ends.

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▸Contents — Internal Revenue Manual Part 4. Examining Process
Internal Revenue Manual Part 4. Examining Process

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