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IRS memorandum for TE/GE employees; church claims for refund or abatement

IRS memorandum for TE/GE employees

The IRS released a memorandum as guidance for employees of the Tax Exempt and Government Entities (TE/GE) Division regarding how to inform churches of their option to authorize the IRS to consider church claims for refund or requests for abatement without following the procedures required by section 7611.


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The guidance memo—TE/GE-04-0720-0006 [PDF 100 KB]—includes instructions that IRS examiners are to follow in informing churches of the option to authorize the IRS to consider church claims for refund or requests for abatement without following the procedures under section 7611.

According to the TE/GE memo, there are several compliance steps before the IRS can commence an inquiry or examination of a church.  The memo sets out these steps and lists procedures that examiners must follow if the return is a claim or abatement request submitted by a church.

The IRS has developed a voluntary written waiver process that allows more expeditious processing of these claims or requests by churches. The process is applicable only with regard to claims for refund or requests for abatement. When applicable, the IRS will contact a church, in writing, to offer the option to execute a written waiver allowing the IRS to consider its claim or request without following the procedures contained in section 7611. The church is under no obligation to agree to a waiver. If the church organization does not respond by the due date or indicates it is not authorizing a waiver, the IRS will continue processing the claim by following section 7611 procedures and issuing a “Notice of Church Tax Inquiry.”

For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Ruth Madrigal | +1 202 533 8817 |

Preston Quesenberry | +1 202 533 3985 |

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