Religious, Charitable, etc., Institutions and Community Chest

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Department of the Treasury
Rl
Internal Revenue Service
IRS
Tax Exempt and Government Entities
P.O. Box 2508
Cincinnati, OH 45201
Release Number: 202405013
Release Date: 2/2/2024
UIL Code: 501.03-00.
501 .03-30, 501.33-00
Date:
11/06/2023
Employer ID number:
Form you must file:
1120
Tax years:
All
Person to contact:
Dear :
This letter is our final determination that you don't qualify for exemption from federal inc-om, tax undc-r lntc-mal Revenue Code (lRC) Section 50 I (a) as an organization described in IRC Sectiou 50l(c)(J ). Receutly, we seul you a proposed adverse determination in response to your application. The proposed adverse determination explained the facts, law, and basis for our conclusion, and it gave you 30 days to 1ile a protest. Because we didn't receive a protest witʏin the required 30 days, the proposed determination is now final.
Because you don't qualify as a tax-exempt organization under !RC Section 501(c)(3), donors generally can't deduct contributions to you under !RC Section 170.
We may notify the appropriate state officials of our determination, as required by !RC Section 6104(c), by sending them a copy of this final letter along with the proposed determination letter.
You must file the federal income tax forms for the tax years shown above within 30 days from the date of this letter unless yon request an extension of time to file For further instruc.tiom, forms, and information, visit www.irs.gov.
We'll make this final adverse determination letter and the proposed adverse determination letter available for public mspecl10n alter deletmg cerlam 1dentilymg inltirmation, as required by lR(: Section 6110. Read the enclosed Letter 437. Notice oflntention to Disclose - Rulings, and review the two attached letters that show onr proposed deletions. If you disagree with our proposed deletions, follow the instructions in the Letter 437 on how to notify us. If you agree with our 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 tax status and responsibilities, 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

IRS
Department of the Treasury
Internal Revenue Service
PO Box2508
Cincinnati, OH 45201
Legend:
U = Operating System
V - Produot
W = Product
X = Date of Formation
Y = State of Formation
Z =Company
Dear :
Date: 09/13/2023
Employer ID number:
Person to contact:
Name:
ID number:
Telephone;
Fax:
UIL:
501.03-00
60 'I (l,l .lO
501.33-00
We c0nsidered yrnJr applicati0n for rec0gniti0n 0f exempti0n from foderal inc0me tax under Internal Revenue Code (!RC) Section 50l(a). We determined that you don't qualify for exemption under !RC Section 501(c)(3).
This letter explains the reasons for our conclusion. Please keep it for your records.

# Issues

Do you qualify for exemption under !RC Section 50 !( c)(3)? No, for the reasons stated below.
Farts
You submitted Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code.
You attest that you formed as an Unincorporated Association on X, in the state of Y. You attest that you have the necessary organizing document, that your organizing document limits your purposes to one or more exempt purposes within the meaning of the !RC Section 50l(c.)(3), that your organizing document does not expressly ompowor you to ongago in activities, othor than an insubstantial part, that are not in furtherance of one or more exempt purposes, and that your organizing document contains the dissolution provision required under Section 501(c)(3).
You attest that you are organized and operated exclusively to fmther charitable purposes. You attest that you have not conducted and will not conduct prohibited activities under !RC Section 501(c)(3). Specifically, you attest you will:
Letter 4034 (Rev. 01-2021)
Catalog Number 47628K