Private v. Public Interest Served

Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities
IRS
Release Number: 202434014
Release Date: 8/23/2024
UIL Code: 501.00-00,
501.03-05, 501.33-00
Dear
Date:
05/29/2024
Employer ID number:
Person to contact:
11i.i8 letter is om fatal deterrn.i.uation that you don't qualify for exemption from federnl 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 detemrination in response to your application. The proposed adverse detemrination explained tire 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 detemrination is now final.
Because you don't qualify as a tax-exempt organization under IRC Section 50l(c)(3), donors generally can't deduct contributions to you under IRC Section 170.
We may notify the appropriate state officials of our detemrination, as required by IRC Section 6104(c), by sending them a copy of this final letter along witlr 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 mtless you request an extension of time to file. For fm1her instructions, forms, and information, visit www.rrs.gov.
\Ve'll make this final adverse detemrination letter and the proposed adverse detemrination 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 tlrat show our proposed deletions. If you disagree with our proposed deletions, follow the instmctions in the Letter 43 7 on how to notify us. If you agree witlr our deletions, you don't need to take any further· action.
If you have questions about this letter, you can call tire 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