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2012 WorkplanFINALDRAFT
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Organizations
Customer Education
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102012
2012 WorkPlan
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Exempt Organizations
Customer Education
212013
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IRS TEGE
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Flax Nikole
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MEMORANDUM FOR
ALL
FROM
Nanette
M Downing
Director
SUBJECT
EO
Procedures
Examinations
for
Possible Political
EO
continues
We
expenditures
activities with
new
to enforce
political
Be
campaign intervention
checked
against
alleging
committee
possible
The
will
be
political
attached
learned
document
from past
handled through
to focus
on
political
examination
intervention
EO
has developed
risk
with respect to
in reporting
will
our standard
intervention
where no
referrals
will
continue
intervention
identified
through
process
to
to
be
compliance
risk
modeling
reviewed
by a
issues involving
of
Form 990
data
for evaluation
Any
referral
cases
and campaign
projects
Form 990
political
models
for examination
campaign
a committee
campaign intervention
to
cases
servants
campaign
sent to
campaigns
to political
and inconsistencies
These
Involving
data and
of career civil
political
referrals
for Issues
Intervention
noncompliance
Assist in identifying
Referrals
have
of impermissible
allegations
gather additional
relating
we
to identify potential
possible
also
the rules
models
Campaign
on serious
resources
We
work
its
4 2012
involving
possible
process should be
political
directed
Attachment
Referral Track
Processing
Standard
Referrals
EO
referral
Alleging
procedures apply
intervention Organizations
Campaign
Political
to processing
information indicating
Alleging
the organization
Campaign
Political
referrals
alleging
EO submodule
do not have an
that
Intervention
are included
an exempt
is
Intervention
all
campaign
political
process
in this
if
organization
501 c subsections
Step 1
A referral is
received
as
identified
in Classification Referrals
alleging
entered
an exempt organization
that
has engaged
database
and
in prohibited political
campaign intervention
Step 2
The
by an experienced
referral is classified
process
dual track
but the
would
between
Step
3a
501
c3
political
not have
to wait for
501
Therefore
Step
or not
3b Other
Because
campaign
these
c3
501 c
intervention
to confirm
political
process and
of the close
continue
review
periodically
will
in the
activities
allegations should
be
make a
will
are permitted
generally
return
relative
go
ROO
determination
a year and
the return
is
to
be
to
those
appropriate
organizations
to
be
we do
prohibited
action
ROO group
filed
to
filed
conduct
needed
return
limited
in order
campaign
political
to properly evaluate
all
of
campaign intervention
the organization
is
compliance
of Operations
has not
delinquent
PARC See
to
EOCA to
If
therefore
appears
Examinations
is
to its political
to
c3
before considering
filed
is
501
organizations
or for
by
cases
than
return to
return
exclusion
in this
Because
for referrals
legislative
legislative
intervention
referrals
activities
If
process
says
line
Matter Experts
that
not be included
will
it
Organizations
Because
whether
Subject
Political Activity
If
activity
it
campaign and
political
and circumstances
facts
all
included
the subject
if
a UBI issue
follow
relationship
review
For instance
alleges only
letter
classifier
or legislative
political
to
filed
be
8 with
for
will
more
delinquent
Classification Referrals
Steps 7 and
ROO
return
will
forward
the recommendation
for
EO
conduct a compliance
check
If
it
appears
not been
operating
be
will
Other
These
501 c
referrals
than
a year
manager to
Note The
ROO
unit
the case
is
the organization
returned
has
to the
The
becomes
when
Manager
Referrals
because
filed
the return
is filed
or
Referrals
3c
more
resent to the
delinquent
Step
return
Referrals
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case
that
are sent to
filed
a return
ROO
Step 4
The
entity
was examined
PACI and
is
referrals
and forwarded
retrieved
under the
previously
Political Activity
ROO
to the
If
it
whether the
to determine
Compliance
Initiative
for consideration
along
prior
case
file
allegation
Step 5
The
ROO secures
Form
the
filed
Form 990
along
returns such as
Step 6
The
ROO tests
sheet
return
to
the organizations
has been
filed
risk
step
this
Form 990
is
skipped
ROO
identified
a check
also completes
lead sheet
If
no
on the
case
Step 7
The case
file
Committee
including
and
is forwarded
to Classification Referrals
for review
by a
Political Activities
for updating
Referral
PARC
Step 8
The
PARC reviews
the case
file
and determines
the following
Not selected
for
Examination
Check
Selected
for
Compliance
Selected
for
Examination
OCEP
Selected
for
Examination
field
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for
Examination not
Transfer
to
ROO
political
research
for additional
of
of
EO
have
will
career
servant
civil
basis for
employees
a minimum
EOCA
of the
operating
PARC
PARC
however
comprised
at all times
are
generally
positions
year The
period of one
PARCs
and
PARC
one
at least
EPR Manager
filled
on a
rotational
and assign
Managers of EPR
will solicit
operations
any case
experienced
of three
decision
selection
PARCs
Step 9
If
the case
is
Selected
for
PARC
Examination the
Delivery
CSD
results in the
If
the
for
immediate assignment
IRS concluded
intervened
in
in
a group
prior examination
that
the case
will
to
501
Case
10
receipt
c3
of
other which
or
a case order
had
organization
be
classified
to determine
whether
automatically
is
and
Selection
See Step
pending
in Classification
campaign
political
to
determines
as
high
priority
Otherwise the
categorized
PARC
factors
be
should
it
as a high priority
The amount
of
money expended
measured
either
in absolute
terms
or in
The
exposed
The
significance
was
for
The
frequency
of the political
national
office in
of the alleged
intervention
occurred
The degree
of specificity
support opposition
organization
The degree
was
five or
campaign
intervention
of candidate
to identify
participation
was an
officer
Any
to
a mechanism
For instance
or
fewer
election
race
one time
the candidate
it
was
event
or the
very clear
whom the
exempt
or opposing
campaign intervention
constructed
donation
to
intervention
used
supporting
of
contested
closely
political
thousands
The degree
to the alleged
of
in
promote
is
For instance
or director
of the
exempt organization
his or her
candidacy
soliciting contributions
to support
its
to solicit
political
by the organization
of
and
contributions versus
one time
Step 10
the
After
PARC makes
a decision
and
Cases
for
selected
Cases
selected
receipt
of
Cases
If
for
exam
as
High
PARC are
by the
Priority
forwarded
CSD
to
immediate assignment
the
exam
Cases
other
as
as compliance
selected
PARC decides
be updated
5666
for
will
be retained
pending
in Classification
a case order
in
checks
selected
for
future
Report
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be forwarded
will
EOCA
to
that
filed
will
require
ROO will
year
future
will
file
not selected
as
year examination
for that
the case
ROO to
forward
Form
prepare
Form 5666
to
Classification Referrals
For cases
that
the additional
Data Analytics
Cases
identify
501
Form 990
noncompliance
potential
to evaluate
ROO
research
for additional
to the
PARC
for
ROO
do
will
review
Track
c3
to
research
and
organizations
with the
the
The goal
campaign
political
by law
established
limits
information
in selecting
intervention
cases
prohibition
501 c
for other
these
to
is
for
and
organizations
models
Step 1
The CSCI
Form 990
analyzes
Organizations
answer
3
4
organizations
No
recognition
5 501 c4
Section
file
report
Part
political
IV question
not report
political
expenditures
on Schedule
and
campaign
activity
on Form 990
but
file
501
527
exemption
or
organizations
that
have terminated
6 organizations
or
file
and
2 have
for
a high percentage
that
report
political
expenditures
of
on Schedule
political
at the
Organizations
c4
contributions
but do not
established
do
that
of
income from
activity
models
1120 POL
Newly established
campaign
political
that
Form 990
to
Organizations
a Form
report
that
risk
a Schedule
2 501 c 3
organizations
same address
reporting
ceasing
within
payments
of
operations
one
to federal
with
501
c4
year
state or local
public
officials
Step 2
The CSCI
researches
previously
under the
prior
exam case
file
to determine
Compliance
Political Activities
and forwarded
is retrieved
PACI
Initiative
to
ROO
to
ROO
project
for consideration
If
so the
along
the
with
Step 3
The
list
The
ROO secures
organizations
of identified
is forwarded
Step 4
any relevant returns such as Form
990 T
and Form
1120 POL
Step 5
sheet
Step 6
The
PARC reviews
the case
file
and determines
of
the following
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for
Examination
Check
Selected
for
Compliance
Selected
for
Examination
OCEP
Selected
for
Examination
field
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for
Examination not
Transfer
to
ROO
political
research
for additional
Step 7
After
PARC makes
the
a decision
to
ROO
for
database
updating
ROO forwards
Cases
If
the
selected
for
compliance
PARC decides
be returned
Cases
5666
cases selected
that
ROO for
to
selected
for
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for examination
checks
CSD
for
be forwarded
to
assignment
EOCA
future
year examination
for that
the case
file
will
non select
closing as a
Report
will
to
future
will
year
require
ROO will
ROO to
forward
Form
prepare
Form 5666
to
Classification Referrals
For cases
that
the additional
to
ROO
for additional
of
to the
research
PARC
for
ROO
review
will
do
Page
Flax Nikole
From
Lerner Lois
Sent
Friday
To
Flax
Cc
Grant Joseph
Subject
We have
November
Nikole
456 one
about
21 2013
of
more
1175
Exempt
57
AM
Director
02201210
Clarke Stephen
thing
in
our
filing
Organizations
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