PLR 202343038
Leases or Sales of Club Property
ii
IRS
Ltgend:
Department of the Treasury
Internal Revenue Service
PO Box.2508
Cincinnati, OH 45201
X=Date
Y=Date
Z=1anguage b percent mm1ber c percent = number
Dear :
JDato: 08/17/2021
Emp!oycrfD number:
Person to contact:
Name:
ID number:
Telephone:
Fan:
UlL:
501.07..00
501.07,-03
We considered your application for recognition of exeJ11ption from federal income tax under Inte..rnal Revenue Code (IRC) Section 501(a). We determined that you don'tquaUfy for exemption under IRC 501(c)(7). This letter explains the reasous for our conclusion. Please keep it for your records.
Do you qualify for exemption under IRC 50l(c)(7)? No, for the reasons stated below.
# Facts
Your tax-exempt status under lRC 50l(c)(7) was revoked for failure to file infmmational returns for fiscal years 011 X. You filed fm· reinstatement of your tax-exempt status 011 Y.
You are fotmerl as a social club. You provide clubhouse facilities for your membership. The clubhouse includes a bar that also serves food and various hall spaces. The clubhouse also l1ouses a Z radio program on the premises which airs weekly in Z language, so that eldedy Z persons can obtain news. You work with other charities to send donations to the Z homeland. Ycn.1 also subsidize housing for Z emigrants so they may fiӍd a safe place to live among their feHow Z people. The housing you subsidize includes various units located on the srune street, that you own.
You receive yom revenue from real estate rentals. rental of your facility, bar income, membership dues and donations, All donations and bar income comes from the membership. Real estate rental income is considered investment income. On nverage over the last four fiscal years, investment income was greater than b peree11t.
Letter 4034 (Rev. 01-2021}
Catalog Ntl!T,ber 476281<
Source: view the official PDF
The source document contains 6 figures (charts or worksheet graphics) not reproduced in this text version. See the official PDF above.
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