PLR 202434012
Private v. Public Interest Served
Department of the Treasury
Internal Revenue Service
IRS
Tax Exempt and Government Entities
Release Number: 202434012
Release Date: 8/23/2024
UIL CODE: 501.03-00 ,
501.33-00
Dear
Date:
05/29/2024
Employer ID number: rorm you muat flle:
Tax years:
Person to contact:
This letter is our final detennination that you don't qualify for exemption from federal income tax under Internal Revenue Code (IRC) Section 501 (a) as an organization described in IRC Section 501 ( c )(3 ). Recently, we sent 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 file a protest. Because we didn't receive a protest within the required 30 days, the proposed determination is now final.
Because you don't qualify as a tax-exempt organization m1der IRC Section 50l(c)(3), donors generally can't deduct contributions to you tmder IRC Section 170.
We may notify the appropriate state officials of our detennination. as required by IRC 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 fmms for the tax years shown above within 30 days from the date of this letter mtless you request an extension oftinle to file. For fiuther instmctions, forms, and information, visit www.rrs.gov.
\Ve'll make this final adverse determination letter and the proposed adverse determination letter available for public inspection after deleting certain identifying infmmation, as required by IRC Section 6110. Read the enclosed Letter 437, Notice of Intention to Disclose - Rttlings. and review the two attached letters that show our 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 om· deletions, you don't need to take any finther 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 nmnber 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
Source: view the official PDF
The source document contains 7 figures (charts or worksheet graphics) not reproduced in this text version. See the official PDF above.
Nearby sections (25 sections)
- plr-202435009 · Section 2010(c)(5)(A); Portability Election (as…
- plr-202435008 · Amount of Reversion
- plr-202435007 · Minimum Funding Waiver
- plr-202435006 · Restrictions on Certain Facilities
- plr-202435005 · Extension of Time for Making Certain Elections
- plr-202435004 · Accounting Methods
- plr-202435003 · Extension of Time for Making Certain Elections
- plr-202435002 · Extension of Time for Making Certain Elections
- plr-202435001 · Other
- tam-202434011 · Fines, Penalties and Other Amounts
- plr-202434014 · Private v. Public Interest Served
- plr-202434013 · Homeowners Association
- plr-202434012 · Private v. Public Interest Served
- plr-202434010 · Extension of Time for Making Certain Elections
- plr-202434009 · Extension of Time for Making Certain Elections
- plr-202434008 · Extension of Time for Making Certain Elections
- plr-202434007 · Reg. 301.7701-3 Classification of Certain Business…
- plr-202434006 · Cash or Deferred Arrangements
- plr-202434005 · Reg. 301.7701-3 Classification of Certain Business…
- plr-202434004 · Medical, Etc. Benefits
- plr-202434003 · Extension of Time for Making Certain Elections
- plr-202434002 · Extension of Time for Making Certain Elections
- plr-202434001 · Extension of Time for Making Certain Elections
- plr-202433008 · Inadvertent Terminations
- plr-202433007 · Reg. 301.7701-3 Classification of Certain Business…