30

The two--year limitation can be suspended (a) if the church brings a judicial proceeding against the IRS, (b) if the IRS brings a judicial proceeding to compel compliance by the church with any reasonable request for examination of church records or religious activities, (c) for any period in excess of twenty days (but not more than six months) in which the church fails to comply with any reasonable request by the IRS for church records, or (d) if the IRS and church mutually agree.