Reports and Closing Letters for Change Cases

(1) Where FTS is a viable option to an eligible taxpayer for unagreed issues, give the taxpayer Pub 5092, Fast Track Settlement A Process Resolution of Tax Exempt and Government Entities (TEGE) Tax Issues, with the initial report.

(2) If a statute date is imminent and there isn’t time to send a standard 30-day letter, consider issuing a replacement transmittal letter for the report. Consult with TEGEDC concerning the content, format, and timing of issuing a letter that replaces a 30-day letter. Refer to the TAS Directory https://organization.ds.irsnet.gov/sites/tas/SiteAssets/TAS%20Directory.aspx. for the current list of Taxpayer Advocate offices. Generally:

Summarize in the letter why you can’t use a standard 30-day letter. See Sections 9.10 and 12.02 of Rev. Proc. 2019-5 (updated annually).

Ensure the replacement transmittal letter contains the standard Taxpayer Advocate paragraph, as shown in the 30-day letter..

A suspense date for the letter is not required.

The transmittal letter can direct the taxpayer toward availing themselves the opportunity for Appeals Office consideration, such as by promptly submitting a valid consent to extend the statute date.

Examination Result

Type of Report

Report Forms and Letters

Revocations -

IRC 501(c)(3)

IRC 501(c)(9)

IRC 501(c)(17)

Formal reports only (issued by group)

Letter 3618, 30-day letter

Form 6018, at Line 1

Form 4621-A

Form 886-A

Pub 892

Pub 3498

Closing Letter

90-day FADL issued by Mandatory Review or Appeals

Revocations -

All other 501(c) or (d)

Formal reports only (issued by group)

Letter 3618, 30-day letter

Form 6018, at Line 2

Form 4621-A

Form 886-A

Pub 892

Pub 3498

Closing Letter

90-day FADL issued by Mandatory Review or Appeals

Disqualifications -

Status 36 Organizations

Formal reports only (issued by group)

Letter 3618, 30-day letter

Form 6018, at Line 3

Form 4621-A

Form 886-A

Pub 892

Pub 3498

Closing Letter

90-day FADL issued by Mandatory Review or Appeals

Disqualifications -

IRC 501(c)(12)

IRC 501(c)(15)

Formal reports only (issued by group)

Letter 4700, 30-day letter

Form 6018 at Line 3

Form 4621-A

Form 886-A

Pub 892

Pub 3498

Closing Letter

90-day FADL issued by Mandatory Review or Appeals

Reclassification of Foundation or Public Charity Status - with an effective date

Formal reports only (issued by group)

Letter 3620, 30-day letter

Form 6018, Lines 4 through 9

Form 4621-A

Form 886-A

Pub 892

Pub 3498

Closing Letter

90-day FADL issued by Mandatory Review or Appeals

Non-declaratory status changes that are subject to appeal - with an effective date