Introduction: What Is IRS Form 15721?

IRS Form 15721, officially titled Consent to Suspend the Period to Conduct a Church Tax Examination, is a specialized legal consent document issued by the Internal Revenue Service (IRS). Governed by the Department of the Treasury and administered through the Exempt Organizations (EO) Examinations office within the Tax Exempt and Government Entities (TE/GE) division, this form plays a unique role in religious organization tax audits.

Unlike standard audits of commercial businesses or individuals, tax inquiries involving churches are governed by strict federal statutory safeguards under the Church Audit Procedures Act, codified in Internal Revenue Code (IRC) Section 7611. Among these protections is a mandatory statutory deadline: the IRS generally has exactly two years to complete a church examination from the date of the initial examination notice.

Form 15721 serves as the official agreement used when a church and the IRS mutually agree to pause or “suspend” the running of this two-year statutory clock. This suspension typically occurs when the IRS issues a proposed adverse finding and the church wishes to have its dispute reviewed by the IRS Independent Office of Appeals before any final revocation or tax assessment takes effect.

Purpose of the Form: Why Does Form 15721 Exist?

Congress enacted IRC Section 7611 to prevent unjustified government entanglement in religious affairs while ensuring tax accountability. Under IRC Section 7611(c)(1)(A), the IRS must conclude its examination and issue a final determination within two years, ensuring that church audits do not drag on indefinitely.

However, during an examination, an IRS agent may propose revoking the church’s 501(c)(3) tax-exempt status or assessing Unrelated Business Income Tax (UBIT). Churches have the legal right to challenge these findings administratively through the IRS Independent Office of Appeals. Because an administrative appeal requires time to file protests, hold conferences, and review complex theological and operational records, the two-year statutory clock may run out before Appeals can complete its work.

Form 15721 solves this procedural dilemma. Under IRC Section 7611(c)(2)(C), it allows the church and the IRS to mutually suspend the two-year completion period for a designated number of days. This gives the Independent Office of Appeals sufficient time to consider the church’s protest without forcing the IRS to issue an immediate, adverse final revocation notice.

Who Needs to File Form 15721?

Form 15721 is not a routine tax form; it is used only under specific audit circumstances:

Churches Facing Proposed Adverse Determinations: Recognized churches, conventions or associations of churches, and integrated auxiliaries undergoing an IRC Section 7611 examination that have received a 30-day proposed adverse determination letter (such as Letter 6487 accompanied by Form 886-A).
Churches Filing an Administrative Appeal: Religious organizations that choose to submit a formal written protest to the IRS Independent Office of Appeals to resolve audit disputes informally rather than proceeding directly to federal court.
Authorized Church Representatives: Legal counsel, certified public accountants (CPAs), or church corporate officers managing an active church tax audit.

Who Is Exempt or Not Required to File?

Because Form 15721 applies exclusively to church audits under IRC Section 7611, many entities are exempt from using it:

Secular 501(c)(3) Nonprofits: Non-church charities, private schools, and foundations are governed by general tax audit rules under IRC Section 6501 and use Form 872 (Consent to Extend the Time to Assess Tax) rather than Form 15721.
Churches Agreeing With Audit Findings: If a church accepts the IRS revenue agent’s findings and does not wish to file an administrative appeal, Form 15721 is not needed.
Churches Bypassing Administrative Appeals: A church has the legal right to refuse to sign Form 15721 and bypass the IRS Appeals process entirely, allowing the IRS to issue a final adverse determination so the church can immediately file a declaratory judgment lawsuit in federal court under IRC Section 7428.
Churches Not Under Active Audit: Religious bodies carrying out everyday worship, charitable operations, and payroll filings have no need for this form.

When to File: Deadlines and Frequency

Form 15721 follows a strict, event-driven timeline triggered by an IRS examination notice:

The 30-Day Window: When the IRS issues Letter 6487 proposing an adverse action, the church is given exactly 30 calendar days to respond with a formal written protest and the executed Form 15721.
One-Time or Staged Suspensions: The agreement suspends the two-year statutory clock for a specific number of days mutually agreed upon by the church and the IRS.
Extensions by Mutual Agreement: If the Appeals process takes longer than anticipated, the parties may execute an additional consent to suspend the deadline further.

Where and How to File Form 15721

Form 15721 is an audit-specific legal instrument delivered directly to the IRS team handling the church examination:

Submission to the Examining Agent: The signed Form 15721 must be submitted along with the church’s formal written protest packet directly to the assigned IRS Exempt Organizations revenue agent or group manager identified on Letter 6487.

Electronic Submission: If the church is communicating through the IRS Taxpayer Digital Communications portal or secure encrypted email, digital copies may be uploaded directly to the examining agent.

Physical Mail: If sending paper documents, the protest and executed Form 15721 should be mailed using certified mail with return receipt requested to the official IRS address as per instructions provided in your audit correspondence.

Step-by-Step Instructions to Fill Out Form 15721

Form 15721 is a formal legal agreement. Every section must be completed accurately to ensure that the suspension of the statutory period is legally valid.

Section / Block	Required Information	Legal & Operational Objective
Header Details	Taxpayer Name, EIN, & Address	Identifies the church, its federal Employer Identification Number, and current mailing address.
In Reply Refer To	IRS Case & Letter Reference	Connects the consent agreement to the specific IRC Section 7611 church examination case file.
Suspension Dates	Two-Year Statutory Calculation	States the date the examination began, current expiration date, number of suspension days, and new deadline.
Taxpayer Rights Notice	Statutory Disclosures	Affirms that the church understands its right to refuse and the impact of refusal on Appeals consideration.
Taxpayer Signature	Individual or Church Signing	Signed and dated by an individual taxpayer or authorized church trustee.
Representative Signature	Power of Attorney Execution	Signed by an attorney or CPA specifically authorized under a previously filed Form 2848.
Corporate Officer Signature	Corporate Seal & Authority	Corporate name followed by signatures and titles of authorized officers empowered to bind the church.
IRS Execution Block	IRS Delegated Official	Signed and dated by the IRS Exempt Organizations Group Manager under Delegation Order 7-3.

Detailed Walkthrough of Major Form Sections

Step 1: Verify Header and Case Identifiers. Enter the legal name of the church exactly as recorded in its articles of incorporation and on IRS records. Confirm the Employer Identification Number (EIN) and the IRS case reference number provided on Letter 6487.

Step 2: Review the Statutory Time Calculation. Review the fillable dates carefully. The form must state the date the examination originally began under IRC Section 7611(c)(1)(A), the current expiration date, the exact number of days the period will be suspended under IRC Section 7611(c)(2)(C), and the resulting new expiration date.

Step 3: Understand Your Rights as a Taxpayer. Form 15721 contains explicit statutory disclosures. You must review the statement acknowledging that you have the right to refuse to sign the consent, and that refusal will not forfeit your right to file a declaratory judgment action in court. However, you must also acknowledge that if you refuse to sign, the IRS Independent Office of Appeals will not consider your protest.

Step 4: Execute with Proper Corporate Authority. For incorporated churches, the form must be signed in the corporate name by authorized corporate officers (such as the President, Senior Pastor, Board Chair, or Treasurer) holding legal authority to bind the organization. If an outside attorney or accountant signs, a valid Form 2848 (Power of Attorney) must be attached.

Step 5: IRS Counter-Signature. Once submitted, the agreement is not legally binding until countersigned by a delegated IRS official—specifically an Exempt Organizations Examinations Group Manager operating under IRS Delegation Order 7-3.

Required Documents and Information Needed Before Filling

Before completing and executing Form 15721, assemble the following legal and audit records:

Letter 6487: The formal transmittal letter from the IRS proposing adverse examination actions.
Form 886-A (Explanation of Items): The revenue agent’s detailed examination report outlining proposed adjustments or revocations.
Formal Written Protest: The comprehensive legal and factual document detailing why the church disagrees with the IRS determination.
Form 2848 (Power of Attorney): Executed representation documents if outside legal counsel is handling the submission.
Corporate Bylaws or Resolutions: Church governance records confirming that the signing officers have legal authority to bind the organization in tax controversies.

Common Mistakes to Avoid

Procedural missteps during a church tax audit can have permanent legal consequences. Watch out for these frequent mistakes:

Attempting to Use Form 872: In standard corporate audits, taxpayers use Form 872 to extend assessment deadlines. Under IRM 4.70.19, standard Form 872 cannot be used for church audits; using it instead of Form 15721 is procedurally invalid.
Missing the 30-Day Protest Window: Failing to submit Form 15721 along with your written protest within 30 days of the issuance of Letter 6487 will cause the IRS to issue a final, unappealable adverse determination.
Signing Without Understanding the Trade-Off: Refusing to sign Form 15721 bars the church from accessing the IRS Independent Office of Appeals. Church leadership must consciously decide whether they want administrative appeal review or prefer to go straight to court.
Signatures by Unauthorized Personnel: Having an administrative assistant, associate minister, or committee member sign without formal corporate authority invalidates the consent.
Forgetting to Attach Form 2848: If an attorney or CPA signs on behalf of the church, failing to include an active Power of Attorney will cause the IRS to reject the filing.

Consequences and Penalties for Refusal to Sign

Signing Form 15721 is entirely voluntary. The IRS cannot impose fines, penalties, or criminal sanctions merely because a church refuses to sign the consent. However, the procedural and strategic consequences of refusal are severe:

Immediate Denial of IRS Appeals Access: If the church refuses to sign Form 15721, the IRS Independent Office of Appeals will not consider the protest, eliminating the chance for an informal administrative settlement.
Issuance of a Final Adverse Determination: The IRS will immediately issue a formal notice revoking the church’s 501(c)(3) tax-exempt status or assessing proposed taxes.
Loss of Deductibility for Contributions: Upon final revocation, donors can no longer claim charitable contribution deductions under IRC Section 170 for gifts made to the church.
Immediate Liability for Federal Taxes: The organization becomes subject to federal corporate income taxes, back employment taxes, and potential excise taxes.
Mandatory Court Litigation: To defend its tax-exempt status, the church’s only remaining option is to file an expensive declaratory judgment lawsuit in the U.S. Tax Court, U.S. District Court, or Court of Federal Claims under IRC Section 7428 within 90 days.

Related Forms and Publications

Form 15721 functions alongside several key IRS exempt organization forms, letters, and guidance manuals:

Letter 6487: Consent to Suspend the Period to Conduct a Church Tax Examination (the transmittal letter accompanying Form 15721).
Form 886-A: Explanations of Items (the revenue agent’s factual audit report).
Form 2848: Power of Attorney and Declaration of Representative.
Form 872: Consent to Extend the Time to Assess Tax (the non-church equivalent).
Form 990-T: Exempt Organization Business Income Tax Return.
Publication 1: Your Rights as a Taxpayer.
Publication 892: How to Appeal an IRS Decision on Tax-Exempt Status.
Publication 1828: Tax Guide for Churches and Religious Organizations.

Frequently Asked Questions (FAQs)

What is the two-year rule for church tax examinations?

Under IRC Section 7611(c)(1)(A), the IRS is legally required to complete any church tax examination and make a final determination within two years of the date the examination notice was issued to the church.

What does Form 15721 do?

Form 15721 temporarily pauses (suspends) the two-year statutory clock. This suspension provides the extra time needed for the IRS Independent Office of Appeals to review the church’s protest and attempt to resolve the dispute administratively.

Can the IRS revoke a church’s tax exemption if the church refuses to sign Form 15721?

Yes. If a church refuses to sign Form 15721, the IRS cannot send the case to Appeals because the two-year deadline would expire. Instead, the IRS will issue a final adverse determination letter revoking the church’s tax-exempt status, forcing the church to go to federal court to contest the decision.

Does signing Form 15721 waive the church’s right to go to federal court?

No. Signing Form 15721 does not deprive the church of its right to file a declaratory judgment action in court. If the Appeals Office sustains the adverse finding, the church can still file a lawsuit in federal court under IRC Section 7428.

Why can’t a church use standard Form 872 instead of Form 15721?

Standard Form 872 extends the general statute of limitations for assessing tax under IRC Section 6501. Because church audits are governed by unique statutory time limits under IRC Section 7611, the IRS Internal Revenue Manual specifically prohibits Form 872 and requires Form 15721.

Who must sign Form 15721 on behalf of the church?

The form must be signed by authorized corporate officers (such as the Board President, Senior Pastor, or Treasurer) who have the legal power to bind the church under its bylaws, or by an attorney/CPA authorized under an active Form 2848.

Conclusion: Key Takeaways

IRS Form 15721, Consent to Suspend the Period to Conduct a Church Tax Examination, is a critical procedural tool under the Church Audit Procedures Act. Enacted to protect religious institutions from indefinite audits, IRC Section 7611 sets a strict two-year completion deadline that can only be suspended by mutual agreement.

When facing proposed audit adjustments or status revocation, church leaders must evaluate Form 15721 carefully. Signing the form preserves the church’s right to an administrative review before the IRS Independent Office of Appeals, while refusing to sign forces an immediate final determination and courtroom litigation. Understanding the strategic implications of Form 15721 ensures that houses of worship make informed decisions to protect their legal and tax-exempt status.

IRS Form 15721 Guide: Suspend Church Tax Examination Clock