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PLR 201620015

Religious, Charitable, etc., Institutions and Community Chest

Official textIRS Written Determinations (PLR · TAM · CCA)irs.gov
Summarize

# Issues

Whether ____ .continues to qualify for exemption under Section 501 (c)(3) of the Internal Revenue Code?
Whether ____ has operated as a not-for-profit organization?
Whether ____ has failed to file required forms?
Whether ____ qualifies for revocation from the date of inception?

# Facts

Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code
____ filed Articles of Incorporation with the State of on February 02, 19XX. Article Two of the Bylaws states that EO is organized exclusively for charitable purposes within the meaning of Code §501 (c)(3). The article goes on to state that the specific objectives and purposes of the corporation shall be to assist seniors with their independent living, charitable giving and ability to live their own lives with respect and dignity.
The Form 1023, Application for Recognition of Exemption Under Section 501 (c)(3) of the Internal Revenue Code, stated that the organization planned to do this by:
1. Providing counseling, planning, transportation, and funding to seniors on a case by case basis.
2. Building wheelchair access ramps leading into the home.
3. Installation of safety railings within bathtub or shower areas.
4. Making adjustments to kitchen and bathroom countertops to make them more easily accessible to seniors.
The Form 1023 stated that the organizations sources of financial support would be "Contributions, benefits".
The Form 1023 listed as President and as Vice President.
On July 12, 20XX and August 13, 20XX, , an Exempt Organization Specialist with the IRS, requested additional information to clarify answers given on the Form 1023 using Letters 2382 and 1312.
In response to Question #6 of the letter dated August 13, 20XX, "Please provide a complete list of the names, titles, and mailing addresses of all your current directors and/or trustees along with any applicable compensation amounts.", replied as follows:
Form 886-A
Department of the Treasury-Internal Revenue Service Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX
____ , Executive Director, approx. $ annual compensation;
____ , Marketing, Board Member, no compensation;
____ , Secretary, no compensation;
1.
2.
3.
4. ____ , Attorney, Board Member, no compensation; (Note: was criminal defense attorney at that time.)
5. ____ , Attorney, legal Counsel, no compensation (Note: was ____ _ law partner and co-counsel at that time.)
6. ____ , Attorney, Legal Counsel, no compensation (Note: was criminal defense attorney at that time.) Each of these letters included a list of additional questions to clarify the Form 1023 application. The letters' instructions said that any response to the questions in the letter should be accompanied by the following declaration:
Under penalties of perjury, I declare that/ have examined this information, including accompanying documents, and, to the best of my knowledge and belief, the information contains all the relevant facts relating to the request forthe information, and such facts are true, correct, and complete.
The declaration was signed by ____ at the end of both responses.
Deputy District Attorney (DDA) of the contacted attorneys , and
____ by phone; both advised that they were not then, nor had they ever been board members of
____ and expressed surprise that had listed them as board members on documents submitted to the IRS. Both and advised that they had never attended any meetings for the board members, officers, directors, or trustees of ____ _ DDA contacted attorney by phone; he advised that he was not then, nor had he ever been, associated with said that he was retained to represent
____ only in the criminal charges. related that he was unaware that ____ _ had identified him on any document as a legal counsel for . He related that he had never attended any meetings for the board members, officers, directors, or trustees of ____ _ Exemption was granted under Section 501 (c)(3) and Section 170(b)(1 )(A)( vi) of the Internal Revenue Code, on September 02, 20XX, as a publicly supported organization.
Operation as a Not-For-Profit Company The stated primary focus of the organization was to assist seniors with their independent living, charitable giving and ability to live their own lives with respect and dignity.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX Numerous complaints were filed by elderly residents in stating that , and coconspirators and were selling the elderly residents worthless living trusts and fraudulent annuities through their companies and ____ _ The investigation by the local police and the District Attorney's Office has revealed that
____ and his co-conspirators, and , were utilizing and another entity, ____ , to operate a "trust mill scam" to sell elderly residents worthless living trusts and fraudulent annuities. The defendants were representing to elderly victims that the granted 501 (c)(3) status proved that was a legitimate charitable organization.
The officers of and , along with another individual
____ ( ), identified as a member of the Board of Directors and in charge of marketing for , have been arrested by the Sheriff's Office for selling elderly residents worthless living trusts and fraudulent annuities through their companies (_) and
____ . Two preliminary hearings have been held on the cases and all defendants have been bound over for felony trial.
During the preliminary court hearing on , 20XX , an expert witness rendered an opinion that officers were operating __ and_ as a "trust mill scam," in which they solicited elders to allow them to draft living trust or living trust updates for the victims, in order to gain access to the victims financial information and assets. The defendants then solicited the victims, who had assets, to invest in the
____ annuity. The expert witness and the Department of Insurance have advised that is not authorized to sell annuities in and considered the ____ _ annuity was fraudulent.
On 0 1-31-20XX, 07 -19-20XX, and 03-28-20XX, DDA ____ and DAI conducted free talk interviews with in the presence of defense attorney . The interviews were all conducted at the District Attorney's Office at the . Some of the admissions, implications, and statements made by are set forth below.
1. , , and ____ met in approximately 20XX or 20XX, when they were all employed as salesmen by at in ____ _
____ characterized as essentially a "trust mill" operation.
2. In approximately 20XX/20XX, established ____ in ____ , as a business to sell living trusts and living trust updates. lived in at that time.
3. In approximately 20XX, ____ terminated his association with ____ and
____ and ____ continued to work with until it went out of business in about 20XX.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX
4. ____ moved to , near the border with ____ ,, and started working with ____ selling living trusts and trust updates with ____ .
5. In about 20XX/20XX, ____ and ____ formed a partnership and ____ _ gave the business to to own and operate.
6. and continued to work together primarily in , with
____ selling living trusts and living trust updates to elderly clients and --- notarizing the trusts and trust updates for , while also soliciting the elderly clients to purchase insurance annuities from through various insurance companies.
____ was a commissioned Notary Public and a licensed insurance agent in ____ _
7. was not a Notary Public or a licensed insurance agent in ____ _
____ told that had a previous criminal theft conviction in
____ and had served time in a state prison. also told
____ that had previously been a licensed insurance agent and a licensed stock broker in ____ .
8. In late 20XX and early 20XX, and formulated an agreement to establish as a 501(c)(3) tax exempt organization and identify and market ____ _ as a non-profit charitable organization to help senior citizens remain living independently.
____ admitted that he and agreed and planned to operate and
____ as a "trust mill scam," which they both knew to be an illegal operation.
9. advised he and --- had numerous discussions and made numerous agreements about how to operate and Most of the discussions and agreements took place in condo residence in ____ _
10. advised that came up with the idea of selling seniors a "private annuity" through as a way to make money, which and ____ _ intended to invest to enrich themselves.
11. admitted he and never intended to be a non-profit, charitable organization; but, in fact, they planned to use to enrich themselves, while deceitfully marketing as a non-profit charitable organization to help senior citizens.
12. also came up with the idea to have elderly clients sign the separate one page
____ annuity agreements, which essentially stated that interest on the client's investment would accrue in the client's account until death when the balance and principal would revert to
____ and agreed they could get elderly clients to sign the agreements, without the clients realizing what they were signing, and they would not provide the clients with copies of the separate one page agreements. admitted his and Form 886-A Department of the Treasury-Internal Revenue Service Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX intention was to deceitfully keep the clients monies after the clients' deaths.
____ admitted he and agreed that if any client's heirs made a claim to
____ for the invested money after the client's death, and ____ _ would then simply claim the clients intended their investments to be donations to ____ _
____ admitted that he and never intended for the individual clients, or the clients' heirs, to get the annuity money back.
13. admitted that copied an Insurance Company Annuity booklet, almost word for word, to use as the Annuity contract booklet. --- was an authorized agent for and agreed they would modify the booklet to use for annuities and they would purposely not have
____ clients complete any application form, nor would they sign the booklet as--- representatives or officers. admitted they knew the annuities were not in compliance with the law and they hoped they would not get caught. had the modified Annuity booklet contracts printed at as they sold the alleged annuities. admitted there were no company and no persons standing behind
____ except himself and admitted had no financial backup reserves and the annuities were essentially fraudulent.
14. admitted he knew that was improperly incorporated and that
____ had no Board of Directors. admitted he and both knew the information provided to the IRS on the initial IRS application for 501(c)(3) tax exempt status was false. admitted that he and formulated
____ as a for-profit organization to enrich themselves and never intended to be a non- profit charitable organization. primary source of funds was to be from the sale of annuities to elderly people. admitted they filed for 501 (c)(3) status partly in an attempt to circumvent and cover themselves from regulation by the ____ _ Department of Insurance. said the supplemental IRS inquiries on the ____ _ 501 (c)(3) application were filed with the IRS by ____ _
15. stated that it was their plan for , and later , to initially sell the living trusts or living trust updates, and would notarize the alleged trust documents. , and later , would also sell the fraudulent ____ _ annuities, and was to manage and invest the incoming funds. ---:--- indicated that he erroneously thought that if and were the front men who sold the fraudulent trusts and annuities, then could remain in the background and be protected from legal action if clients made complaints.
16. continued that he did notarize documents of some of the trusts sold by --- but on many of the trusts, simply gave pre-signed pages bearing Form 886-A Service signature and Notary Public stamp and never met or notarized client Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX signatures for many of the trust sold by ____ _ _ ____ acknowledged he knew such false notarizations were illegal.
17. also admitted that he had purposely destroyed his Notary Public Journal because he expected the District Attorney's Office would be attempting to obtain it.
18. advised that and ____ were supposed to provide
____ with incoming funds from the sale of annuities and was to manage and invest some of the funds. related he did invest some of the funds into a account he opened at , and
____ also used the incoming funds for their respective living expenses.
19. admitted he did not open separate investment accounts in the names of the elderly
____ investors, nor did he keep detailed records under the names of the elderly investors, because they did not intend to pay the money back to the elderly investors or the investors' heirs after the investors' deaths.
20. stated he and began to have disagreements over some of the
____ annuities being sold and other matters. felt like things were spinning out of control, was out of control, and did not feel comfortable with the way things were going. Consequently, and agreed that
____ would withdraw from effective 06-11-20XX and sign a written agreement to that effect. and notified the accountants ____ _ and presented with a written "Transfer of Power Agreement" for alleged he signed the agreement without reading it closely and should not have signed the agreement. alleged that he was essentially out of after 06-11-20XX , but he still associated with ____ _ admitted that he did withdraw $ for himself from the account in the months prior to withdrawing from ____ _
____ and , accountants of ____ ,, of ____ , were interviewed by
____ District Attorney Investigator on 03-11-XX ( #XX- #XX). During that interview they stated that:
1. In approximately January 20XX, contacted to assist--- and in filing an IRS Form 1023 and related forms to apply for 501 (c)(3) non-profit tax exempt status for , an organization and were jointly staring.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX
2. had filed a few IRS 1023 applications in the past, but had never filed
3. such an application. took over the project of assisting and
____ with preparing the appropriate IRS and other forms and applications to get
____ approval with IRS.
____ and ____ advised they did not recall ever having a joint meeting with both
____ and regarding , it was always with , or later ____ , individually.
4. In preparing the IRS 1023, advised that he sat down with
____ and went through the form with question by question and line by line.
____ related that all answers to all questions on the initial IRS 1023 Application (signed by
____ on 08-03-20XX) were provided by ____ _
5. ____ made no attempts to verify answers or information provided by ____ or
____ , but simply drafted the answers and information as provided by and
____ without question.
6. and related that neither , nor , ever related anything to them about selling annuities of any type to seniors, or planning to sell annuities to seniors through ____ _
7. and related that in June 20XX , for reasons unknown to them,
____ withdrew from and took over all further---:-- control. They provided a copy of the Transfer of Power Agreement between and
____ indicated that most probably provided him with a copy of the transfer agreement. The agreement, signed by both and on 06-11-20XX .
8. In July and August 20XX , received letters from IRS requesting additional information for the pending IRS 1023 Application to grant tax exempt non-profit status to ____ _
____ ____ worked with on the IRS requests for additional information. Around this time frame, had reviewed --- web site " ,"and was concerned that the statements indicative of primary activities on the website were not in sync with those stated in the 1 023 Application submitted to IRS on 08-03-20XX. told that the 1023 Application and the website needed to be in sync.
9. also advised ____ that to comply with IRS requests, ____ would have to appoint a Board of Directors for ____ _ Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX
10. related that essentially, drafted responses to the IRS requests for additional information and emailed his draft responses to , who cleaned up the draft responses with some punctuation and organization changes and sent them back to --- for approval.
11. ____ related that ____ then submitted the additional information to the IRS.
12. ____ related that also needed to complete a personal tax return for 20XX and --- requested to provide with
____ financial records in order to complete a tax return for ____ _
13. did subsequently contract with for ____ bookkeeping services. provided and/or with bank records for 20XX. provided those records to ____ _ subsequently told· that was unable to obtain ____ _ records from and never provided any financial or activity records on to enable
____ to prepare a tax return.
14.1n the August 20XX IRS request for additional information, IRS specifically requested
____ to provide a complete list of the names, titles, and mailing addresses of all
____ officers, directors and/or trustees. was surprised to find in email to on 08-23-20XX , that was listed among the Board of Directors, as the Auditor; and ---CPA, was listed as the Bookkeeper. related that ____ _ had never asked him, or mentioned to him that would be on the Board of Directors for and related that he had no interest or desire to serve on the Board of Directors.
15. related he then told that he ( ) was not interested in serving on the Board of Directors for and told that
____ had to talk with all of the persons listed as members of the Board of Directors to confirm they were willing to serve on the board. deleted his name and the name of from list of members of the
____ Board of Directors, before sending his proposed draft back to for submission to IRS.
16. --- … did not contact the other persons ____ listed as members of the
____ Board of Directors. submitted the list to IRS without the names of ---and ____ _ Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Perio d ended 20XX, 2 OXX,20XX
17. On 04-07 -20XX, sent an email requesting to file an
- extension for 20XX personal income taxes, for , and
18. On 04-09-20XX, replied to that had deci ded to preparation he cease their tax preparation services to him and should make other tax arrangements. replied, "so, guilty b4 chance 2prove innocence? Not t American way is it?" , CPA, of , was interviewed by DAI of the District Attorney's Office On 04-20-20XX, at his office in
1. accounting practice is focused on business bookkeeping. _was contacted in late summer or early fall 20XX by , a CPA networking associ ate, about completing some bookkeeping work for one of tax clients, has never met in person, but has had email and possibly t elephone communications with in 20XX
2. It was understanding that and wanted to complete bookkeeping reports for business and non-profit organization, , for the year 20XX. related that he received all records on and through---~:---' but he never received any records on , because said he could not obtain the
____ records from his former business partner, ____ _
3. had told that large donation deposits into the account were actually donations intended for , but on checks written to ____ _
____ said he ) subsequently transferred the large deposits to a separate
____ account. was unable to verify statements because
____ never provided any bank statements or other records for ____ _
4. --- prepared no tax returns for ____ ---' or---
5. ____ was under the impression that he would be contracted to prepare bookkeeping reports for ____ and for 20XX , but he has been provided with no 20XX or ____ records by either or ____ _
6. ____ advised he has not been contacted further by ____ since about October
20XX. ____ related he has no further information about , or Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX
Failure to file Required Forms
The IRS's Information Data Retrieval System (I DRS}, lists the current status of as Exemption Revoked (Status Code 97) on March 11, 20XX, due to the failure to file Form 990 or Form 990N for 3consecutive years.
Form 990
The organization failed to file Forms 990 for the tax years ending 20XX and 20XX. If the organization does not meet any of the filing exceptions and its annual gross receipts are normally more than $ , it must file Form 990 or Form 990EZ. Third party records indicate the following:
Year
20XX
20XX
Income per Bank
____ received 1 00% of its income from the updating of fraudulent trusts and selling fraudulent private annuities to senior citizens.
The organization had a filing requirement for 20XX and 20XX because gross receipts exceeded $ ____ .
Forms 990 are due the 15th day of the 5th month following the end of the organization's tax year. Forms 990 for the tax years ending 20XX and 20XX have not been filed to date and are currently delinquent.

# Law

Internal Revenue Code ("Code") §501 (a) provides that an organization described in §501 (c) (3) is exempt from income tax. Code §501(c)(3) exempts from federal income tax corporations organized and operated exclusively for charitable, educational, and other purposes, provided that no part of the net earnings inure to the benefit of any private shareholder or individual. The term charitable includes relief of the poor and distressed. Federal Tax Regulations ("Regulations") §1.501 (c) (3)-1 (d) (2).
An IRC §170(b)(1)(A)(vi) organization is defined as an organization referred to in subsection (c)(2) which normally receives a substantial part of its support (exclusive of income received in the exercise or performance by such organization of its charitable, educational, or other purpose or function constituting the basis for its exemption under §501 (a)) from a governmental unit referred to in subsection (c)(1) or from direct or indirect contributions from the general public.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX IRC §170(c)(2)(B) defines a charitable organization as a corporation, trust, or community chest, fund, or foundation that is organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, or to foster national or international amateur sports competition (but only if no part of its activities involve the provision of athletic facilities or equipment), or for the prevention of cruelty to children or animals;
Regulations §1.501 (a)-1 (a)(3) states that an organization claiming exemption under section 501 (a) and described in any paragraph of section 501 (c) (other than section 501 (c)(1)) shall file the form of application prescribed by the Commissioner and shall include such information as required by such form and the instructions issued with respect thereto.
Regulations §1.501(a)-1(b)(1)(iii) states that an organization described in section 501(c)(3) shall submit with, and as a part of, an application filed after July 26, 1959, a detailed statement of its proposed activities.
Regulations §1.501 (a)-1 (b)(2) states that in addition to the information specifically called for by this section, the Commissioner may require any additional information deemed necessary for a proper determination of whether a particular organization is exempt under section 501 (a), and when deemed advisable in the interest of an efficient administration of the internal revenue laws, he may in the cases of particular types of organizations prescribe the form in which the proof of exemption shall be furnished.
Regulations §1.501(c)(3)-1(a)(1) provides that, in order to be exempt as an organization described in Code §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.
Regulations §1.501(c)(3)-1(c)(1) provides that an organization will be regarded as "operated exclusively" for one or more exempt purposes only if it engages primarily in activities that accomplish one or more of such exempt purposes specified in Code §501(c)(3). An organization will not be so regarded if more than an insubstantial part of its activities is not in furtherance of an exempt purpose. The existence of a substantial nonexempt purpose, regardless of the number or importance of exempt purposes, will cause failure of the operational test. Better Business Bureau of Washington. D.C. v. U.S., 326 U.S. 279 (1945).
Regulations §1.501 (c)(3)-1 (c)(2) provides that the operational test is not satisfied where any part of the organization's earnings inure to the benefit of private shareholders or individuals, and where the organization serves a private benefit rather than public interests.
Regulations §1.501 (c)(3)-1 (d)(ii) provides that an organization is not organized or operated exclusively for one or more exempt purposes unless it serves a public rather than private interest. Thus, it is necessary for an organization to establish that is not organized or operated for the benefit of private interests such as designated individuals, the creator or his family, shareholders of the organization, or persons controlled, directly or indirectly, by such private interests. Prohibited private interests include those of unrelated third parties as well as insiders. Christian Stewardship Assistance. Inc. v. Commissioner, 70 T.C. 1037 (1978);
American Campaign Academy v. Commissioner, 92 T.C. 1053 (1989). Private benefits include an Form 886-A Department of the Treasury-Internal Revenue Service Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX "advantage; profit; fruit; privilege; gain; [or] interest." Retired Teachers Legal Fund v. Commissioner. 78 T.C.
280, 286 (1982).
The presence of a single substantial nonexempt purpose can destroy the exemption regardless of the number or importance of exempt purposes. Better Bus. Bureau v. United States. 326 U.S. 279. 238, 90 L.
Ed. 67, 66 S. Ct. 112 (1945); Am. Campaign Acad. V. Commissioner. 92 T.C. 1053, 1065 (1989); see also Old Dominion Box Co .. Inc. v. United States. 477 F2d. 340 (41h Cir. 1973), cert. denied, 413 US 910 (1973) ("operating for the benefit of private parties who are not members of a charitable class constitutes a substantial nonexempt purpose".) When an organization operates for the benefit of private interests, such as designated individuals, the creator or his family, or persons directly or indirectly controlled by such private interests, the organization by definition does not operate exclusively for exempt purposes. Am. Campaign
Acad. V. Commissioner. supra at 1065-1066.
IRC §6001 provides that "Every person liable for any tax imposed by this title, or for the collection thereof, shall keep such records, render such statements, make such returns, and comply with such rules and regulations as the Secretary may from time to time prescribe. Whenever in the judgment of the Secretary it is necessary, he may require any person, by notice served upon such person or by regulations, to make such returns, render such statements, or keep such records, as the Secretary deems sufficient to show whether or not such person is liable for tax under this title"
IRC §6033(a)(1) provides that "Except as provided in paragraph (2), every organization exempt from taxation under §501 (a) shall file an annual return, stating specifically the items of gross income, receipts, and disbursements, and such other information for the purpose of carrying out the internal revenue laws as the Secretary may by forms or regulations prescribe, and shall keep such records, render under oath such statements, make such other returns, and comply with such rules and regulations as the Secretary may from time to time prescribe; except that, in the discretion of the Secretary, any organization described in §401 (a) may be relieved from stating in its return any information which is reported in returns filed by the employer which established such organization.
Paragraph 6033(a)(2) lists mandatory exceptions to paragraph (1) as (i) churches, their integrated auxiliaries, and conventions or associations of churches, (ii) any organization (other than a private foundation, as defined in §509(a)) described in subparagraph (C), the gross receipts of which in each taxable year are normally not more than $5,000, or (iii) the exclusively religious activities of any religious order.
Revenue Ruling 80-278. 1980-2 CB 175. (Jan. 01. 1980) establishes that in making the determination of whether an organization's activities are consistent with exemption under section 501 (c)(3) of the Code, the Service will rely on a three-part test. The organization's activities will be considered permissible under section 501 (c)(3) if:

(1) The purpose of the organization is charitable;

(2) The activities are not illegal, contrary to a clearly defined and established public policy, or in conflict with express statutory restrictions; and Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX

(3) The activities are in furtherance of the organization's exempt purpose and are reasonably related to the accomplishment of that purpose.
Revenue Ruling 75-3841 1975-2 CB 2041 (Jan. 01 I 1975) states that as a matter of trust law, one of the main sources of the general law of charity, no trust can be created for a purpose which is illegal. The purpose is illegal if the trust property is to be used for an object which is in violation of the criminal law, or if the trust tends to induce the commission of crime, or if the accomplishment of the purpose is otherwise against public policy. IV Scott on Trusts Sec. 377 (3d ed. 1967). Thus, all charitable trusts (and by implication all charitable organizations, regardless of their form) are subject to the requirement that their purposes may not be illegal or contrary to public policy. See Rev. Rul. 71-447, 1971-2 C. B. 230; Restatement (Second), Trusts (1959)
Sec. 377, Comment (c).
Rev. Proc. 2008-91 I.R.S. 2008-2 (January 141 2008) I Section 121 states that a determination letter or ruling recognizing exemption may be revoked or modified by a notice to the taxpayer to whom the determination letter or ruling was issued. It went on to say that the revocation or modification of a determination letter or ruling recognizing exemption may be retroactive if the organization omitted or misstated a material fact, operated in a manner materially different from that originally represented, or engaged in a prohibited transaction and where there is a material change, inconsistent with exemption, in the character, the purpose, or the method of operation of an organization, revocation or modification will ordinarily take effect as of the date of such material change.
Government's Position:

# Issue 1

It is the Government's Position that the Form 1 023, Application for Recognition of Exemption Under Section 501 (c)(3) of the Internal Revenue Code, for was knowingly filed with material misstatements, was never Intended to be operated 1n a manner that would qualify for exemption under §501 (c)(3) of the Internal Revenue Code, and has failed to operate exclusively for charitable, educational, and other purposes.
In its Form 1023 application, described itself as an organization that shall assist seniors with their independent living, charitable giving, and ability to live their own lives with respect and dignity. The organization stated that its primary sources of financial support were to be "contributions, benefits".
The Form 1023 application stated that the organization planned to do this by: (1) providing counseling, planning, transportation, and funding to seniors on a case by case basis. (2) building wheelchair access ramps leading into the home, (3) installation of safety railings within bathtub or shower areas, and (4) Making adjustments to kitchen and bathroom countertops to make them more easily accessible to seniors.
On 01-31-20XX, 07-19-20XX, and 03-28-20XX, Deputy District Attorney (DDA) and District Attorney Investigator (DIA) of the Office of the , conducted free talk interviews Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX with in the presence of ____ _ defense attorney---· A review of the records of these interviews revealed that:
1. , , and ____ met in approximately 20XX or 20XX, when they were all employed as salesmen by at in ____ _
____ characterized as essentially a "trust mill" operation.
2. In approximately 20XX/20XX, established ____ in ____ , as a business to sell living trusts and living trust updates. lived in at that time.
3. In approximately 20XX, ---terminated his association with --- and
____ and ____ continued to work with until it went out of business in about 20XX.
4. ____ moved to , near the border with ____ , and started working with ____ selling living trusts and trust updates with ____ _
5. In about 20XX/20XX, and ____ formed a partnership and--- gave the business to to own and operate.
6. and continued to work together primarily in , with
____ selling living trusts and living trust updates to elderly clients and ____ _ notarizing the trusts and trust updates for , while also soliciting the elderly clients to purchase insurance annuities from through various insurance companies.
____ was a commissioned Notary Public and a licensed insurance agent in ____ _
7. In late 20XX and early 20XX, the stated officers of , ____ ,President, and,
____ , Vice President, formulated an agreement to establish --- as a 501 (c)(3) tax exempt organization and identify and market as a non-profit charitable organization to help senior citizens remain living independently.
8. He and agreed and planned to operate ____ as a "trust mill scam," which they both knew to be an illegal operation.
9. admitted they filed for 501 (c)(3) status partly in an attempt to circumvent and cover themselves from regulation by the Department of Insurance.
10. ____ admitted he knew that ____ was improperly incorporated and that
____ had no Board of Directors.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX
____ and , accountants of ____ , of , were interviewed by
____ District Attorney Investigator on 03-11-XX. During that interview they stated that:
1. In approximately January 20XX, contacted to assist~---::--- and in filing an IRS Form 1023 and related forms to apply for 501 (c)(3) non-profit tax exempt status for , an organization and were jointly staring.
2. had filed a few IRS 1023 applications in the past, but had never filed
3. such an application. took over the project of assisting and
____ with preparing the appropriate IRS and other forms and applications to get
____ approval with IRS.
____ and ____ advised they did not recall ever having a joint meeting with both
____ and regarding , it was always with , or later ____ ,, individually.
4. In preparing the IRS 1023, advised that he sat down with
____ and went through the form with question by question and line by line.
____ related that all answers to all questions on the initial IRS 1023 Application (signed by
____ on 08-03-20XX) were provided by ____ ,
5. made no attempts to verify answers or information provided by ____ or
____ ,, but simply drafted the answers and information as provided by and ____ _ without question.
6. and related that neither , nor , ever related anything to them about selling annuities of any type to seniors, or planning to sell annuities to seniors through ____ _
7. and related that in June 20XX , for reasons unknown to them,
____ withdrew from and took over all further ____ _ control. They provided a copy of the Transfer of Power Agreement between and
____ indicated that most probably provided him with a copy of the transfer agreement. The agreement, signed by both and on 06-11-20XX.
Additional questions were sent in letters to by , an Exempt Organization Specialist with the IRS. --- ---Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX The interview with , and ____ , accountants of , of , by --- … ,_--District Attorney Investigator on 03-11-XX. also provided information on these letters. They stated that:
1. In July and August 20XX , received letters from IRS requesting additional information for the pending IRS 1023 Application to grant tax exempt non-profit status to ____ _
____ ____ worked with on the IRS requests for additional information. Around this time frame, had reviewed --- web site " , " and was concerned that the statements indicative of primary activities on the website were not in sync with those stated in the 1023 Application submitted to IRS on 08-03-20XX. told that the 1023 Application and the website needed to be in sync.
2. also advised ____ that to comply with IRS requests, ____ would have to appoint a Board of Directors for ____ _
3. related that essentially, drafted responses to the IRS requests for additional information and emailed his draft responses to , who cleaned up the draft responses with some punctuation and organization changes and sent them back to ____ _ for approval.
4. ____ related that ____ then submitted the additional information to the IRS.
5. In the August 20XX IRS request for additional information, IRS specifically requested
____ to provide a complete list of the names, titles, and mailing addresses of all
____ officers, directors and/or trustees. was surprised to find in email to on 08-23-20XX that was listed among the Board of Directors, as the Auditor; and , CPA, was listed as the Bookkeeper. related that had never asked him, or mentioned to him that would be on the Board of Directors for
____ and related that he had no interest or desire to serve on the
____ Board of Directors.
6. related he then told that he ( ) was not interested in serving on the Board of Directors for and told that
____ had to talk with all of the persons listed as members of the Board of Directors to confirm they were willing to serve on the board. deleted his name and the name of from list of members of the
____ Board of Directors, before sending his proposed draft back to for submission to IRS.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX
7. ____ did not contact the other persons ____ listed as members of the
____ Board of Directors. submitted the list to IRS without the names of
____ and ____ _
In a response to additional questions sent in a letter to by , an Exempt Organization Specialist with the IRS, listed , Attorney and ____ _ Attorney, as Board Members and , Attorney, as Legal Counsel.
The letter's instructions said that any response to the questions in the letter should be accompanied by the following declaration:
Underpenaltiesofperjury, I declare that/ have examined this information, including accompanying documents, and, to the best of my knowledge and belief, the information contains all the relevant facts relating to the request forthe information, and such facts are true, correct, and complete.
The declaration was signed by at the end of the response.
Deputy District Attorney (DDA) of the contacted attorneys , and
____ by phone; both advised that they were not then, nor had they ever been board members for
____ and expressed surprise that had listed them as board members on documents submitted to the IRS. Both and advised that they had never attended any meetings for the board members, officers, directors, or trustees of ____ _ DDA contacted attorney by phone; he advised that he was not then, nor has he ever been, associated with said that he was retained to represent
____ only in the criminal charges. related that he was unaware that ____ _ had identified him on any document as a legal counsel for . He related that he has never attended any meetings for the board members, officers, directors, or trustees of ____ _ The admissions made during the interviews by and the statements made during the interviews of , and , accountants of , show that the officers of the organization, and , have a history going back to approximately 20XX or 20XX, when they were all employed as salesmen by at in . , of running what characterized as essentially a "trust mill" operation. The two continued the operation of selling trusts through after they left at and came up with the idea to start ____ _ Both and intentionally made false and misleading statements when filing Form 1023, Application for Recognition of Exemption Under Section 501 (c)(3) of the Internal Revenue Code, in order to obtain exempt status under IRC §501 (c)(3). They did this in an attempt to hide Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX the fact that they were involved in an illegal "trust mill" scam to sell worthless trusts and "personal annuities" to senior citizens Their conduct of criminal activities is contrary to Revenue Ruling 80-2781 1980-2 CB 1751 (Jan. 01 I 1980) and Revenue Ruling 75-3841 1975-2 CB 2041 (Jan. 01 I 1975) that states that as a matter of trust law, one of the main sources of the general law of charity, no trust can be created for a purpose which is illegal. The purpose is illegal if the trust property is to be used for an object which is in violation of the criminal law.
Rev. Proc. 2008-91 I.R.S. 2008-2 (January 1412008) I Section 121 states that a determination letter or ruling recognizing exemption may be revoked or modified by a notice to the taxpayer to whom the determination letter or ruling was issued.
The Rev. Proc. went on to say that the revocation or modification of a determination letter or ruling recognizing exemption may be retroactive if the organization omitted or misstated a material fact, operated in a manner materially different from that originally represented, or engaged in a prohibited transaction and where there is a material change, inconsistent with exemption, in the character, the purpose, or the method of operation of an organization, revocation or modification will ordinarily take effect as of the date of such material change.
Operating as a not-for-profit
The Form 1023 stated that the organizations sources of financial support would be "Contributions, benefits".
The officers of , and , along with another individual
____ , identified as a member of the Board of Directors and in charge of marketing for
____ , have been arrested by the Sheriff's Office for selling elderly victims worthless living trusts and fraudulent annuities through their companies and . All the defendants have been arrested, but are currently out of custody. Two preliminary hearings have been held on the cases and all defendants have been bound over for felony trial.
On 01-31-20XX, 07-19-20XX, and 03-28-20XX, Deputy District Attorney (DDA) and District Attorney Investigator (DIA) of the Office of the , conducted free talk interviews with in the presence of defense attorney . In the course of these interviews admitted that:
1. , , and ____ met in approximately 20XX or 20XX, when they were all employed as salesmen by at in ------characterized as essentially a "trust mill" operation.
2. In approximately 20XX/20XX, established ____ in ____ , as a business to sell living trusts and living trust updates. lived in at that time.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended · 20XX,20XX,20XX
3. In approximately 20XX, ____ terminated his association with ____ and ---and--- continued to work with until it went out of business in about 20XX.
4. ____ moved to , near the border with ____ ,, and started working with ____ selling living trusts and trust updates with ____ _
5. In about 20XX/20XX, and ____ formed a partnership and ____ _ gave the business to to own and operate.
6. came up with the idea to have elderly clients sign the separate one page
____ annuity agreements, which essentially stated that interest on the client's investment would accrue in the client's account until death when the balance and principal would revert to
____ and agreed they could get elderly clients to sign the agreements, without the clients realizing what they were signing, and they would not provide the clients with copies of the separate one page agreements. admitted his and intention was to deceitfully keep the clients monies after the clients' deaths.
--- admitted he and agreed that if any client's heirs made a claim to
____ for the invested money after the client's death, and ____ _ would then simply claim the clients intended their investments to be donations to ____ _
____ admitted that he and never intended for the individual clients, or the clients' heirs, to get the annuity money back.
7. admitted that copied an Insurance Company Annuity booklet, almost word for word, to use as the Annuity contract booklet. was an authorized agent for and agreed they would modify the booklet to use for annuities and they would purposely not have
____ clients complete any application form, nor would they sign the booklet as ____ _ representatives or officers. admitted they knew the annuities were not in compliance with the law and they hoped they would not get caught. had the modified Annuity booklet contracts printed at as they sold the alleged annuities. admitted there were no company and no persons standing behind
____ except himself and admitted had no financial backup reserves and the annuities were essentially fraudulent.
8. admitted they filed for 501(c)(3) status partly in an attempt to circumvent and cover themselves from regulation by the Department of Insurance.
9. stated that it was their plan for ____ , and later , to initially sell the living trusts or living trust updates, and would notarize the alleged trust documents. , and later , would also sell the fraudulent ____ _ Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX annuities, and was to manage and invest the incoming funds. ---:--- indicated that he erroneously thought that if and ____ were the front men who sold the fraudulent trusts and annuities, then could remain in the background and be protected from legal action if clients made complaints.
10. continued that he did notarize documents of some of the trusts sold by--:---:--- but on many of the trusts, simply gave pre-signed pages bearing signature and Notary Public stamp and never met or notarized client signatures for many of the trust sold by acknowledged he knew such false notarizations were illegal.
11. also admitted that he had purposely destroyed his Notary Public Journal because he expected the District Attorney's Office would be attempting to obtain it.
12. advised that and --- were supposed to provide ---with incoming funds from the sale of annuities and was to manage and invest some of the funds. related he did invest some of the funds into a account he opened at , and
____ also used the incoming funds for their respective living expenses.
13. admitted he did not open separate investment accounts in the names of the elderly
____ investors, nor did he keep detailed records under the names of the elderly investors, because they did not intend to pay the money back to the elderly investors or the investors' heirs after the investors' deaths.
14. stated he and began to have disagreements over some of the
____ annuities being sold and other matters. felt like things were spinning out of control, was out of control, and did not feel comfortable with the way things were going. Consequently, and agreed that
____ would withdraw from effective 06-11-20XX and sign a written agreement to that effect. and notified the accountants -:-=--- and presented with a written "Transfer of Power Agreement" for alleged he signed the agreement without reading it closely and should not have signed the agreement. alleged that he was essentially out of after 06-11-20XX , but he still associated with ____ _ admitted that he did withdraw $ for himself from the ____ --- account in the months prior to withdrawing from ____ _ Examination of bank and brokerage statements provided by the District Attorney's Office indicates that received % of its income from client fees associated with the updating of trusts and from the sale of the "private annuities" and from the , and later Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX -:---· There is no indication of any ____ public support. There is no indication of grants from government agencies or donations from the public.
There is no indication that --- was involved in any charitable activities.
Treas. Reg. 1.501 (c)(3)-1 (c) (1) states that an organization will be regarded as "operated exclusively" for one or more exempt purposes only if it engages primarily in activities which accomplish one or more of such exempt purposes specified in section 501 (c)(3). An organization will not be so regarded if more than an insubstantial part of its activities is not in furtherance of an exempt purpose. Furthermore, In Better Bus.
Bureau v. United States. 326 U.S. 279. 238. 90 L. Ed. 67. 66 S. Ct. 112 (1945) the court stated that a single non-educational purpose, if substantial in nature, will destroy the exemption regardless of the number or importance of truly educational purposes.
The admissions by as to the operation of the "trust mill" and the examination of the account information supplied by the District Attorney's Office convincingly show that ____ _
____ , and later , had no intention of running as an exempt organization. This lack of intent and the fact that , and also used the incoming funds for their respective living expenses, are substantial enough to destroy the exemption.
____ has Failed to File Required Forms Form 990 The organization failed to file Forms 990 for the tax years ending 20XX and 20XX . If the organization does not meet any of the exceptions and its annual gross receipts are normally more than $25,000, it must file Form 990 or Form 990EZ. Third party records indicate the following:
Year
20XX
20XX
Income per Bank
____ knew that ____ had a filing requirement for ____ . The interview with
____ , and , accountants of , of , by---District Attorney Investigator on 03-11-XX provided information that:
1. ____ related that also needed to complete a personal tax return for 20XX and ____ requested to provide with
____ financial records in order to complete a tax return for ____ _ Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX
2. did subsequently contract with for bookkeeping services. provided and/or with bank records for 20XX. provided those records to ____ , subsequently told that was unable to obtain ____ _ records from and never provided any financial or activity records on ____ _ to enable to prepare a tax return.
3. On 04-07-20XX, ____ sent an email requesting---:--- to file an extension for 20XX personal income taxes, for ____ , and
____ , CPA, of , was interviewed by DAI ____ of the ____ _ District Attorney's Office On 04-20-20XX, at his office in ____ _
1. accounting practice is focused on business bookkeeping. was contacted in late summer or early fall 20XX by , a CPA networking associate, about completing some bookkeeping work for one of tax clients, ____ ,
____ has never met in person, but has had email and possibly telephone communications with in 20XX
2. It was understanding that and ---wanted ____ _ to complete bookkeeping reports for business and --- non-profit organization, , for the year 20XX. related that he received all records on and through , but he never received any records on , because said he could not obtain the
____ records from his former business partner, ____ _
3. had told that large donation deposits into the account were actually donations intended for , but on checks written to ____ _
____ said he subsequently transferred the large deposits to a separate
____ account. was unable to verify statements because
____ never provided any bank statements or other records for ____ _
4. ____ prepared no tax returns for ____ , or---
5. was under the impression that he would be contracted to prepare bookkeeping reports for and for 20XX , but he has been provided with no 20XX or
____ records by either or---:--:------ never followed through with the filing requirements despite the requests from the CPAs that he contacted.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX The organization had a filing requirement for 20XX and 20XX because gross receipts exceeded $25,000.
The organization had a filing requirement under IRC §6033, as it is an IRC §501 (a) organization. Third party records indicate that the organization does not qualify for the filing requirement exemption under IRC §6033(a)(2)(ii) that exempts any organization (other than a private foundation, as defined in §509(a)) the gross receipts of which in each taxable year are normally not more than $5,000.
Forms 990 are due the 151h day of the 51h month following the end of the organization's tax year. Forms 990 for the tax years ending 20XX and 20XX have not been filed to date and are currently delinquent.
The IRS's Information Data Retrieval System (I DRS), lists the current status of as Exemption Revoked (Status Code 97) on March 11, 20XX, due to the failure to file Form 990 or Form 990N for 3consecutive years.
Organization's Position:
The organization has no response at this time.
Summary:
On the basis of the examination of the books, records, and activities of , and the interviews conducted by the , the organization fails to qualify for exempt status under IRC §501(c)(3).
Admissions made during the interviews by and the statements made during the interviews of
____ , and , accountants of , show that the officers of the organization, and , and later , have a history going back to approximately 20XX or 20XX, when they were all employed as salesmen by at
____ in . , of running what characterized as essentially a "trust mill" operation. ____ and continued the operation of selling trusts through ____ _ after they left at and came up with the idea to start ____ _ Both and intentionally made false and misleading statements when filing Form 1023, Application for Recognition of Exemption Under Section 501 (c)(3) of the Internal Revenue Code, in order to obtain exempt status under IRC §501 (c)(3).
The officers of , and , knowingly and willfully made false or misleading statements when filing the original Form 1023, Application for Recognition of Exemption Under Section 501 (c)(3) of the Internal Revenue Code, for . Admissions by indicate that the false and misleading statements made on the Form 1 023 were a deliberate and pre-planned to enable to qualify for exempt status as a 501 ( c)(3) organization.
Form 886-A
Service
Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX, 20XX, 20XX Statements made by , and , accountants of , who
____ and hired to file the Form 1023 indicate that answered all the questions on the original application. They also stated that after additional inquiries came in ____ _ would send the replies for editing and then send them back to . When inquiries about the members of the Board of Directors were received, told that he needed to ask the listed members if they were willing to be members of the Board. knowingly made material misrepresentations by giving names of attorneys that ____ _ knew were not members of the Board and signed those misrepresentations under a "penalties of perjury" declaration.
Exemption was granted under Section 501 (c)(3) and Section 170(b)(1 )(A)(vi) of the Internal Revenue Code, on September 02, 20XX , as a publicly supported organization after these inquiries were answered ..
____ failed to operate exclusively for charitable or educational purposes. and
____ knowingly made material misrepresentations in the filing of the organization's Form 1023 to hide the fact that they, and later , did this in an attempt to hide the fact that they were involved in an illegal "trust mill" scam to sell worthless.trusts and "personal annuities" to senior citizens to enrich themselves and never return the proceeds to the senior citizens that had invested in the "trusts".
This failure to operate exclusively for charitable or educational purposes in contrary to Revenue Ruling 80-2781 1980-2 CB 1751 (Jan. 01 I 1980 and Revenue Ruling 75-3841 1975-2 CB 2041 (Jan. 01 I 1975).
-=--- receives no public support. has received % of its financial support from client fees from the sale of trust updates and "private annuities". Since income was shown to be % from the sale of illegal trust updates and "private annuities" to senior Citizens,
____ fails the public support test of Treas. Reg. § 1.170A-9( e) that allows classification of
____ as a public charity under IRC §509(a)(1) & 170(b)(1)(A)(vi).
--:--- has failed to file Forms 990 for the calendar years 20XX and 20XX . CPAs ____ _ and both requested records from in order to file ____ _ Forms 990. failed to provide any records to the CPAs. The Form 990 for the tax year ending 20XX was due May 15, 20XX and the Form 990 for the tax year ending 20XX was due May 15, 20XX.
These returns have not been filed to date and are currently delinquent. The IRS's Information Data Retrieval System (I DRS), lists the current status of as Exemption Revoked (Status Code 97) on March 11, 20XX, due to the failure to file Form 990 or Form 990N for 3-consecutive years.
Based on the examination of the record supplied by the District Attorney's Office and activities of , as detailed in the interviews of and , and , accountants of , revocation of exempt status is being proposed back to the date that the original Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, was filed, February 4, 20XX. This is the date of the original false and misleading statements made by and that resulted in the granting of ____ _ Form 886-A Service Department of the Treasury-Internal Revenue Form 886-A Schedule number or exhibit
Explanations of Items
Name of Taxpayer Tax Identification Number Year/Period ended 20XX,20XX,20XX exempt status under IRC §509(a)(1) & 170(b)(1)(A)(vi). (Rev. Proc. 2008-9. I.R.S. 2008-2 (January 14.
2008). Section 12.)
SA should file Forms 1120, U.S. Corporation Income Tax Return, for each year under examination and each subsequent year.
Form 886-A
Service
Department of the Treasury-Internal Revenue

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