Concurrent Examinations

A central organization’s group ruling terminates when:

A central organization notifies the IRS that it is going out of existence by filing a return.

Its exemption is revoked (automatically or manually).

It files a final return.

The IRS revokes the group ruling letter.

The action impacts any current examination of a subordinate organization. All members of the group ruling are updated to EO BMF status 28. Any former subordinate organizations who later file a Form 990 series return are updated to status 40 or 36, depending on the code section claimed on the return. Subordinate organizations are also placed in status 40 or 36 when a central organization notifies them that it’s dissolving its group ruling (but not terminating).

When possible, attempt to coordinate exams of central and subordinate organizations. If you’re examining subordinate organizations, check AIMS to see if the central organization and/or the group return is under exam. Contact the examination group to discuss the exam issues and coordinate actions.

Mandatory Review follows these actions when these events occur:

For all central organization revocations:

Mandatory Review or Appeals issues the final letter (revocation or FADL to the central organization.)

The reviewer, or Appeals, notifies the manager, Mandatory Review, of the issuance of the letter to the central organization.

The manager, Mandatory Review, in turn notifies the Area Manager, GL\FIU, of the revocation of the central organization.

The manager, Mandatory Review, secure emails the area managers giving directions on any subordinates in their inventories. See Exhibit 4.70.14-32, EO Secure Email message from Manager, Mandatory Review, to Area Managers Regarding the Revocation of a Central Organization (501(c)- FADL Issued), for all 501(c) revocations.

As all 501(c) Organizations Are Subject to IRC 7428:

When the waiting period per IRC 7428 ends, either the statute coordinator, Mandatory Review, or Appeals, depending on the file’s location, notifies the manager, Mandatory Review of whether a petition was filed with the court.

The manager, Mandatory Review, informs the applicable area manager.

If no petition was filed, the manager, Mandatory Review, secure emails the area managers to proceed with final actions. See Exhibit 4.70.14-33, EO Secure Email message from Manager, Mandatory Review, to Area Managers Regarding the Revocation of a Central Organization - FADL Not Petitioned.