An organization has not exhausted its administrative remedies before the earlier of: The time it completes certain steps and the IRS sends it a notice of final determination by certified or registered mail, or Expiration of a 270-day period in which the IRS has not issued a notice of final determination and the organization has taken, in a timely manner, all reasonable steps to secure a ruling or determination. The steps described will not be considered completed until the Internal Revenue Service has had a reasonable time to act upon the appeal or protest, as the case may be.