PLR 202226014
Homeowners Association
Department of the Treasury
Internal Revenue Service
Independent Office of Appeals
Number: 202226014
Release Date: 7/1/2022
Date:
APR O 6 2022
Pers on to contact:
Name:
Employee ID number:
Telephone:
Fax:
Hours:
Employer ID number:
Uniform issue list (UII}:
UIL: 501 .04-07, 501.04-06
Certified Mail
Dear
This is a final adverse determination that you do not qualify for exemption from federal income tax under Internal Revenue Code (the "Code") Section 50l(a) as an organization described in Section 50l(c)(4) of the Code.
We made the adverse determination for the following reasons:
Your organization does not promote the social welfare or provide a community benefit because it does not allow public access.
You're required to file federal income tax returns on Forms 1120, U.S. Corporation Income Tax Return and 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 or by calling 800-TAX-FORM (800-829-3676).
We'll make this letter and the proposed adverse determination letter available for public inspection under Section 6110 of the Code after deleting certain identifying information. We 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 can file an action for declaratory judgment under the provisions of Section 7428 of the Code in either:
• The United States Tax Court,
• The United States Court of Pederal Claims, or
• The United States District Court for the District of Columbia
Letter 1371 (Rev. 10 2021)
Catalog Number 40683R
Source: view the official PDF
The source document contains 12 figures (charts or worksheet graphics) not reproduced in this text version. See the official PDF above.
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