The church examination procedures do not apply to the following:

• Routine requests for information or inquiries on matters that do not primarily concern the organization’s tax status or liability,
• Criminal investigations,
• Termination assessments under Internal Revenue Code section 6851 or jeopardy assessments under section 6861,
• Any case involving the church’s knowing failure to file a return or willful attempt to defeat or evade tax (including failure to withhold or pay social security or other employment or income tax required to be withheld from wages), or
• Any inquiry or examination relating to the tax status or liability of persons or organizations other than the church (including contributors).

Additional information

• IRM 4.76.3
• Update on Church Examinations Under IRC 7611, 1992 EO CPE Text Topic A