"Exclusively" Test

Internal Revenue Service
Appeals Office
Date: May 15, 2019
Number: 202053019
Release Date: 12/31/2020
Certified Mail
Dear
Department of the Treasury
Employer Identification Number:
Person to Contact:
Employee ID Number:
Tel:
Fax:
UIL Code: 0501.03-00, 501.35-00
This is a final adverse determination that you do not qualify for exemption from federal income ta)_( under Internal Revenue Code (the "Code") section 501(a) as an organization described in Section 501(c){ 3) of the-Code.
We made the adverse determination for the following reason(s):
Your organization's operations are not exempt under Section 501(c )(3) of the code because a substantial part of your planned operations violate public policy.
Contributions to your organization are not deductible under section 170 of the Code.
You're required to file Federal income tax returns on Forms {1120, U.S. Corporation Income Tax Return, OR 1041. U.S. Income Tax Return for Estates and Trusts]. Mail your form to the appropriate Internal Revenue Service Center per the form's Instructions. You can get forms and instructions by visiting our website at www.irs.gov/forms-pubs or by calling 800-TAX-FORM (800-829-3676}.
We'll mal<e this letter and the proposed adverse determination letter available for public inspection under Code section 611 0 after deleting certain Identifying information. We have provided to you, in a separate mailing, Notice 437, Notice of Intention to Disclose. Please review the Notice 437 and the documents attached that show our proposed deletions. If you disagree with our proposed deletions. follow the instructions in Notice 437.
If you decide to contest this determination, you may file an action for declaratory judgment under the provisions of section 7428 of the Code in either:
• United States Tax Court,
• The United States Court of Federal Claims,
• The United States District Court for the District of Columbia.
You must file a petition or complaint In one of these three courts within 90 days from the date we mailed this determination letter lo you. Contact the clerk of the appropriate court for rules and the appropriate forms for filing petitions for declaratory judgment. You can write to the courts at the following addresses: