An organization has not exhausted its administrative remedies before the earlier of:

  1. The time it completes certain steps and the IRS sends it a notice of final determination by certified or registered mail, or
  2. Expiration of a 270-day period in which the Service 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.


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