Using Section 7428 to Resolve Exempt Status Controversies
Taxation of Exempts
IRS examinations of tax-exempt organizations can be, and often are, long, arduous processes that can span several years. This is especially true of examinations that result in proposed adverse determinations. During IRS examinations it is important that tax-exempt organizations have the benefit of all available tools and strategies that can be used to exert a greater level of control over the duration of the examination and the administrative appeals process. In some cases the Service's own administrative delays can be used to the advantage of organizations facing potential adverse determinations.
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