Religious, Charitable, etc., Institutions and Community Chest

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
TEGE:EO Examinations
1100 Commerce Street, MC 4920 DAL
Dallas, TX 75242
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Date: December 02,2014
Number: 201514012
Release Date: 4/3/2015
Person to Contact:
Identification Number:
Contact Telephone Number
Telephone:
Fax:
UIL: 501.03-00 EIN:
CERTIFIED MAIL - Return Receipt Requested
Dear
This is a final revocation letter as to your exempt status under section 50l(c)(3) of the
Internal Revenue Code. Our favorable determination letter to you dated June 19XX recognizing you as an organization described in section 501 ( c )(3 ), is hereby revoked effective January 1, 20XX.
The revocation of your exempt status was made for the following reasons:
Treas. Reg. section 1.501(c)(3)-l(a)(l) provides that in order to be exempt as an organization described in IRC section 50l(c)(3), an organization must be both organized and operated exclusively for one or more exempt purposes. Your organization no longer conducts any activities, has liquidated all assets, and has provided no indication of plans to resume operations at any point. Therefore, you have failed to establish that you are operated exclusively for exempt purposes.
As such, you failed to meet the requirements ofi.R.C. Section 501(c)(3) and Treasury
Regulation Section 1.501(c)(3)-1(a)(1) in that you failed to establish that you are operated exclusively for exempt purposes within the meaning of Internal Revenue Code section 501(c)(3).
Contributions to your organization are no longer deductible under section 170 of the
Internal Revenue Code, effective January 1, 20XX.
You are required to file Federal income tax returns on Form 1120. These returns should be filed with the appropriate Service Center for the year ending December 31, 20XX, and for all subsequent years.
Processing of income tax returns and assessment of any taxes due will not be delayed should a petition for declaratory judgment be filed under section 7428 of the Internal Revenue Code.
If you decide to contest this determination in court, you must initiate a suit for declaratory judgment in the United States Tax Court, the United States Claim Court or the District Court of the United States for the District of Columbia before the 91 st day after the date this determination was mailed to you. Contact the clerk of the appropriate court for the rules for initiating suits for declaratory judgment. Please contact the clerk of the respective court for rules and the appropriate forms regarding filing petitions for declaratory judgment by referring to the enclosed Publication 892. Please note that the United States Tax Court is the only one of these courts where a declaratory judgment action can be pursued without the services of a lawyer. You may write to the courts at the following addresses:
United States Tax Court
400 Second Street, NW
Washington, DC 2021 7
US Court of Federal Claims
71 7 Madison Place, NW
Washington, DC 20005
2
U. S. District Court for the District of Columbia
333 Constitution Ave., N. W.
Washington, DC 2000 1
You also have the right to contact the office of the Taxpayer Advocate. However, you should first contact the person whose name and telephone number are shown above, since this person can access your tax information and can help you get answers. Taxpayer Advocate assistance cannot be used as a substitute for established IRS procedures, formal appeals processes, etc. The Taxpayer Advocate is not able to reverse legal or technically correct tax determinations, nor extend the time fixed by law that you have to file a petition in the United States Tax Court.
The Taxpayer Advocate can, however, see that a tax matter that may not have been resolved through normal channels gets prompt and proper handling.
You may call 1-877-777-4 778 and ask for Taxpayer Advocate assistance. If you prefer, you may contact your local Taxpayer Advocate at:
Internal Revenue Service
Office of the Taxpayer Advocate
If you have any questions, please contact the person whose name and telephone number are shown in the heading of this letter.
Enclosures:
Publication 892
Envelope
Sincerely yours,
Stephen A. Martin
Acting Director, EO Examinations
3
Internal Revenue Service
Tax Exempt and Government Entities Division
Exempt Organizations: Examinations
3730 Elizabeth Ave.
Independence, Mo 64057
Certified Mail- Return Receipt Requested
Dear
Department of the Treasury
Date: May 27, 2014
Taxpayer Identification Number:
Form:
Tax Year(s) Ended:
Person to Contact/ID Number:
Contact Numbers:
Telephone:
Fax:
Manager's name/ID number:
Manager's contact number:
Response due date:
Why you are receiving this letter
We propose to revoke your status as an organization described in section 501 (c)(3) of the
Internal Revenue Code (Code). Enclosed is our report of examination explaining the proposed action.
What you need to do if you agree
If you agree with our proposal, please sign the enclosed Form 6018, Consent to Proposed
Action- Section 7428, and return it to the contact person at the address listed above (unless you have already provided us a signed Form 6018). We'll issue a final revocation letter determining that you aren't an organization described in section 501 (c)(3).
After we issue the final revocation letter, we'll announce that your organization is no longer eligible for contributions deductible under section 170 of the Code.
If we don't hear from you
If you don't respond to this proposal within 30 calendar days from the date of this letter, we'll issue a final revocation letter. Failing to respond to this proposal will adversely impact your legal standing to seek a declaratory judgment because you failed to exhaust your administrative remedies.
Effect of revocation status
Letter 3618 (Rev. 6-2012)
If you receive a final revocation letter, you'll be required to file federal income tax returns for the tax year(s) shown above as well as for subsequent tax years.
What you need to do if you disagree with the proposed revocation
If you disagree with our proposed revocation, you may request a meeting or telephone conference with the supervisor of the IRS contact identified in the heading of this letter. You also may file a protest with the IRS Appeals office by submitting a written request to the contact person at the address listed above within 30 calendar days from the date of this letter.
The Appeals office is independent of the Exempt Organizations division and resolves most disputes informally.
For your protest to be valid, it must contain certain specific information including a statement of the facts, the applicable law, and arguments in support of your position. For specific information needed for a valid protest, please refer to page one of the enclosed Publication 892, How to Appeal an IRS Decision on Tax-Exempt Status, and page six of the enclosed Publication 3498, The Examination Process. Publication 3498 also includes information on your rights as a taxpayer and the IRS collection process. Please note that Fast Track Mediation referred to in Publication 3498 generally doesn't apply after we issue this letter.
You also may request that we refer this matter for technical advice as explained in Publication
892. Please contact the individual identified on the first page of this letter if you are considering requesting technical advice. If we issue a determination letter to you based on a technical advice memorandum issued by the Exempt Organizations Rulings and Agreements office, no further IRS administrative appeal will be available to you.
Contacting the Taxpayer Advocate Office is a taxpayer right
You have the right to contact the office of the Taxpayer Advocate. Their assistance isn't a substitute for established IRS procedures, such as the formal appeals process. The Taxpayer Advocate can't reverse a legally correct tax determination or extend the time you have (fixed by law) to file a petition in a United States court. They can, however, see that a tax matter that hasn't been resolved through normal channels gets prompt and proper handling. You may call toll-free 1-877-777-4778 and ask for Taxpayer Advocate assistance. If you prefer, you may contact your local Taxpayer Advocate at:
Internal Revenue Service
Office of the Taxpayer Advocate
For additional information
If you have any questions, please call the contact person at the telephone number shown in the heading of this letter. If you write, please provide a telephone number and the most convenient time to call if we need to contact you.
2 Letter 3618 (Rev. 6-2012)
Thank you for your cooperation.
Enclosures:
Report of Examination
Form 6018
Publication 892
Publication 3498
Sincerely,
Mary A. Epps
Acting Director, EO Examinations
Letter 3618 (Rev. 6-2012)
3
Form 886A
I
N arne of Taxpayer

# Issue

Whether tax- exempt status.

# Facts

Department of the Treasury- Internal Revenue Service
Explanation of Items
Schedule No. or
Exhibit
Year/Period Ended
Dec. 31, 20XX should retain its 501 (c)(3) has declared Chapter 7 bankruptcy and has been inactive for a number of years. has forfeited their not for profit corporation status with the State of

# Law

Treasury Regulation §1.501(c)(3)-1(a)(1) states," in order to be exempt as an organization described in section 501 (c)(3), an organization must be both organized and operated exclusively for one or more of the purposes specified in such section. If an organization fails to meet either the organizational test or the operational test, it is not exempt."
Taxpayer's Position: verified that the organization has been inactive for extended period of time. has not provided it position regarding the revocation.
Government's Position: is no longer operating within the meaning of section
501 (c)(3). has not voluntary terminated its 501 (c)(3) tax-exempt status, therefore their tax- exempt status should be revoked as of January 1 , 20XX.

# Conclusion

501(c.)(3) tax-exempt status should be revoked as of
January 1, 20XX, since they are no longer active ..
Form 886-A(Rev.4-68)
Department of the Treasury- Internal Revenue Service
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