PLR 202110031
Religious, Charitable, etc., Institutions and Community Chest
Number: 202110031
Release Date: 311212021
UIL: 501.03-00
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
1100 Commerce street. MC 4920DAL
Dallas, TX 75242
Date: September 18, 2020
Taxpayer ID Number:
Form:
Tax Period(s) ended:
Person to Contact:
Identification Number:
Telephone Number:
Fax Number:
CERTIFIED MAIL - Return Receipt Requested
LAST DAY FOR FILING A PETITION WITH THE TAX COURT:
Dear
This is a ftnal 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 January 1, 20XX. Your determination letter dated September 2, 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 under Section 501(a) must be both organized and operated exclusively for exempt purposes. You have not demonstrated that you are operated exclusively for charitable. educational, or other exempt purposes within the meaning of 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. You have not established that you have operated exclusively for an exempt purpose.
As such, you failed to meet the requirements of IRC Section 501(c)(3) and Treasury Regulation
Section 1.501(c)(3)-1(c). in that you have not established that you were operated exclusively for exempt purposes.
Contributions to your organization are no longer deductible under IRC Section 170.
Organizations that are not exempt under Section 501 generally are required to file federal income tax returns and pay tax, where ap licable. For further instructions. forms, and information please visitwww.irs.gov.
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