"Exclusively" Test

% Department of the Treasury tm
Internal Revenue Service
IRS
Tax Exempt and Government Entities
POBox2508
Dear
Cincinnati, OH 45201
Release Number: 202405006
Release Date: 212/2024
UIL Code: 501.03-30,
501.33-00, 501.35-00
Date:
11/06/2023
Employer ID number:
Person to contact:
This letter is om final detenuination that you don't qualify for exemption from federal income tax under Internal Revenue Code (TRC) Section 'i0l(a) as an organirntion desc1ihe<l in TRC Section Ն0l(c)(3). Recently, we sent you a 1-nopo;,e<l adveli>e <letem1111,1tw11 iu 1es1,ome lo yotll a1,plicalion. The JJ!OJJo:,ed adve1se detellninatio11 explained the facts, law, and basis for our conclusion, and it gave yon 30 days to file a protest. Because we clidu't 1eceive a p10tesl wilhiu the 1equi1ed 30 days, lhe p10pose<l dete1111i11ation is now final.
Bccmrno yon don't qualif\, ns a tnx exempt organization under !RC Section :>0 I ( c)(3), donors gcnernlly can't deduct contnbuhons to you under IRC Section 170.
\Ve may notify the appropriate state officials of our detenuination, as required by IRC Section 6l04(c). by sendmg them a copy of tlus final letter along with the proposed detenlllllat10n letter.
You must file the federal income tax fonus for the tax years shown above within 30 days from the date of this letter unless you request an extension of time to file. For further instructions, forms, and information, visit \VW\V.ll's.gov.
\Ve'll make this final adverse detennination letter and the proposed adverse detemunation letter available for public inspection after deleting certain identifying information, as required by IRC Section 6110. Read the enclosed Letter 437, Notice of Intention to Disclose - Rulings. and review the two attached letters that show om proposed deletions. If you disagree with om proposed deletions, follow the instrnctions in the Letter 43 7 on how to notify us. If you agree with om deletions, you don't need to take any further action.
If you have questions about this letter, you can call the contact person shown above. If you have questions about your federal income lax status and responsibililies, call our customer service number at 800-829-1040 (TTY 800-829-4933 for deaf or hard of hearing) or customer service for businesses at 800-829-4933.
Letter 4038 (Rev, 11-2021)
Catalog Number 47632S