Organizational and Operational Tests

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IRS
Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities
PO Box 2508
Cincim1ati, OH 45201
Number: 202102013
Release Date: 1/15/2021
UIL Number: 501.00-00, 501.03-00, 501.03-30
Dear
Date:
October 20, 2020
Employer ID number:
Form you must file:
Tax years:
Person to contact:
Name:
ID number:
Telephone:
This letter is our final determination that you don't qualify for exemption from federal income tax under Internal Revenue Code (IRC) Section 501(a) as an organization described in IRC Section 501(c)(3). Recently, we sent you a proposed adverse determination in response to your application. The proposed adverse determination explained the facts, law, and basis for our conclusion, and it gave you 30 days to file a protest. Because we didn't receive a protest within the required 30 days, the proposed determination is now final.
Because you don't qualify as a tax-exempt organization under IRC Section 501(c)(3), donors generally can't deduct contributions to you under IRC Section 170.
We may notify the appropriate state officials of our determination, as required by IRC Section 6104( c ), by sending them a copy of this final letter along with the proposed determination letter.
You must file the federal income tax forms for the tax years shown above within 30 days from the date of this letter unless you request an extension of time to file. For further instructions, forms, and information, visit www.irs.gov.
We'll make this final adverse determination letter and the proposed adverse determination letter available for public inspection after deleting certain identifying information, as required by IRC Section 6110. Read the enclosed Notice 437, Notice of Intention to Disclose, and review the two attached letters that show our proposed deletions. If you disagree with our proposed deletions, follow the instructions in the Notice 437 on how to notify us. If you agree with our deletions, you don't need to take any further action.
If you have questions about this letter, you can call the contact person shown above. If you have questions about your federal income tax status and responsibilities, call our customer service number at 800-829-1040 (TTY 800-829-493 3 for deaf or hard of hearing) or customer service for businesses at 800-829-4933.
Letter 4038 (Rev. 5-2020)
Catalog Number 47632S

IRS
Legend:
E = Date
F = State
Department of the Treasury
Internal Revenue Service
P.O. Box 2508
Cincim1ati, OH 45201
G = Region
H = Vehicle
Dear
Date:
August 18, 2020
Employer ID number:
Contact person/ID number:
Contact telephone number:
Contact fax number:
UIL:
501.00-00
501.03-00
501.03-30
We considered your application for recognition of exemption from federal income tax under Internal Revenue Code (IRC) Section 501(a). We determined that you don't qualify for exemption under IRC Section 501(c)(3).
This letter explains the reasons for our conclusion. Please keep it for your records.

# Issues

Do you qualify for exemption under IRC Section 501(c)(3)? No, for the reasons stated below.

# Facts

You submitted Form 1023-EZ, Streamline Application for Recognition of Exemption Under Section 501 (c)(3) of the Internal Revenue Code. You attested on Form 1023-EZ that you are organized and operated exclusively to further charitable and educational purposes. You also attested that you have not conducted and will not conduct prohibited activities under IRC Section 501(c)(3).
During review of your Form 1023-EZ, detailed information was requested supplemental to your attestations.
You were formed as a nonprofit corporation on E in the State of F. Your Articles state that you were established to promote recreation in the G area of F and to preserve/restore older H. Your Articles further state that notwithstanding any other provision, you shall not carry on any other activities not permitted to be carried on by a corporation exempt under IRC Section 50l(c)(3).
Your specific activities include an H show, an H and quarterly meetings. Participants in your activities include your members and the general public. The show includes displays of H which are judged by your members. Trophies are given for winners of various categories. You assert that you are a family friendly club and are open to all in the community. The H involves members, along with the general public, meeting up to go on a together.
Letter4034 (Rev.11-2018)
Catalog Number 47628K