PLR 202110037
Social Clubs
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Number: 202110037
Release Date: 3/12/2021
UIL: 501.07-00
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
1100 Commerce Street, MC 4920DAL
Dallas, TX 75242
Date: September 22, 2020
Taxpayer ID Number:
Form:
For Tax Period(s) Ending:
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 final determination explaining why your organization doesn't qualify as an organization described in Internal Revenue Code (IRC) Section 501(c)(7) for the tax period listed above.
In the future, if you believe your organization qualifies for tax-exempt status and would like a determination letter from the Internal Revenue Service, you can request a determination by filing Form 1024, Application for Recognition of Exemption Under Section 501 (a), or Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code (as applicable) and paying the required user fee.
Our adverse determination as to your exempt status was made for the following reasons:
You have not established that you are operated substantially for pleasure and recreation of your members or other non-profitable purposes and no part of the earnings inures to the benefit of private shareholder within the meaning of IRC Section 501 (c)(7). You have made your recreational and social facilities available to the general public. You have exceeded the non-member income test for tax year ending December 31, 20XX.
Organizations that are not exempt under IRC Section 501 generally are required to file federal income tax returns and pay tax, where applicable. For further instructions, forms, and information please visit www.irs.gov.
1
Source: view the official PDF
The source document contains 9 figures (charts or worksheet graphics) not reproduced in this text version. See the official PDF above.
Nearby sections (25 sections)
- plr-202111008 · Revised Schedules
- plr-202111007 · Revised Schedules
- plr-202111006 · Revised Schedules
- plr-202111005 · Exceptions
- plr-202111004 · Exceptions
- plr-202111003 · Extension of Time for Making Certain Elections
- plr-202111002 · Retroactive Elections
- plr-202111001 · Retroactive Elections
- cca-202111012 · Wagering Losses
- tam-202110038 · Religious, Charitable, etc., Institutions and Community…
- plr-202110041 · Social Clubs
- plr-202110039 · Social Clubs
- plr-202110037 · Social Clubs
- plr-202110031 · Religious, Charitable, etc., Institutions and Community…
- plr-202110030 · Religious, Charitable, etc., Institutions and Community…
- plr-202110017 · Cost Sharing Arrangements: Stock Based Compensation…
- plr-202110016 · Passive Foreign Investment Company
- plr-202110015 · Dual Consolidated Loss
- plr-202110014 · Requirements of Gain Recognition Agreement
- plr-202110013 · Reg. 301.7701-3 Classification of Certain Business…
- plr-202110012 · Extension of Time for Making Certain Elections
- plr-202110011 · Cost Sharing Arrangements: Stock Based Compensation…
- plr-202110010 · Inadvertent Terminations
- plr-202110009 · Inadvertent Terminations
- plr-202110008 · Inadvertent Terminations