PLR 202110030
Religious, Charitable, etc., Institutions and Community Chest
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Number: 202110030
Release Date: 3/12/2021
UIL: 501.03-00
1100 Commerce Street, MC 4920DAL
Dallas, TX 75242
CERTIFIED MAIL- Return Receipt Requested
LAST DAY FOR FILING A PETITION WITH THE TAX COURT:
Dear
Date: October 30, 2020
Taxpayer ID Number:
Form:
Tax Period(s) Ending:
Person to Contact:
Identification Number:
Telephone Number:
Fax Number:
This is a final determination that you do not 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), effective August 29, 20XX. Your determination letter dated June 3, 20XX is revoked.
Our adverse determination as to your exempt status was made for the following reasons:
Organizations described in IRC Section 501(c)(3) and exempt from tax under
Section 501 (a) must be both organized and operated exclusively for exempt purposes. You have failed to produce documents or otherwise demonstrate that you are operated exclusively for exempt purposes and that no part of your net earnings inure to the benefit of private shareholders or individuals.
You failed to respond to repeated requests to allow the Internal Revenue
Service to examine your records regarding your receipts, expenditures, or activities as required by Sections 6001 and 6033(a)(1) and the regulations thereunder.
As such, you failed to meet the requirements of IRC Section 501 ( c)(3) and Treasury
Regulations Section 1.501 (c)(3)-1 (a), in that you have not established that you were organized and operated exclusively for exempt purposes.
Contributions to your organization are no longer deductible under IRC Section 170.
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