Religious, Charitable, etc., Institutions and Community Chest

Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities
Release Number: 202437007
Release Date: 9/13/2024
UIL Code: 501.03-00
CERTIFIED l\tLi\IL - Return Receipt Requested Dear
\Vhy ,ve are sending you this letter
Date:
June i?, 2024
Taxpayer 10 number Hast 4 digits):
-
Form: -
Tax periods ended:
Person to contact:
Name:--
IDnumber:
Te!
Fax:
Last day to file petition wm, United States
Tax Court:
September 16, 2024
This is a final dete1minatio11 that you don't qualify for exemption fi:om fodernl income tax under Internal Revenue Code (IRC) Section 50I(a) as an organization described in IRC Section 50l(c)(3), effective Yom detenuim,tion letter dated is revoked.
Our adverse determina!ion as to your exempt status was made for the fi,ilowing reasons: Organizations described in IRC Section 50l(c)(3) and under IRC Section 509(a)(3) must be both organized and operated exclusively for exempt puq:mses. Your organization has not operated in furtherance of its exempt puq:mse for multiple years. Thus, you have not demonstrated that you are organized exdusively for charitable, educationaL or other exempt pmJ>Oses ivithin the meaning of IRC Section 50l(c)(3).
Organizations that axe not exempt under IRC Section 50 l generally are required to file federal income tax retmns and pay tax, where applicable. For further instmctions, forms and infomiation please visit IRS.gov.
Contributions to your organization are no longer deductible under IRC Section 170.
\Vhat you must do if you disagree ·with tbis deten11ination If you wani. to contest our final detennination, you have 90 days from the date this detennination letter was mailed to you to file a petition or complaint in one of the three federal courts listed below.
How to file your action for ded.uratory judgment
If you decide to contest this detennination, you can file an action for dedaratory judgment under the provisions pf Section 7428 of the Code in either:
• The United States Tax Court,
• TI1e United States Court of Federal Claims, or
• The United States District Court for the District of Columbia You must file a petition or complaint in one of these three courts ,vithin 90 days from the date we mailed this determination letter to vou. You can dmvnload a fillable petition or complaint fom1 and get infonnation about filing at each respectiv; court's v.rebsite listed belmv or by contacting the Office ofthe Clerk of the Court at one oftl;e addresses below. Be suR' to include a copy of this letter and any artacrunents and the applicable filing fee ,vith the petition or complaint.
Catalog Number 7 4808£
You can eFile your completed U.S. Tax Court petition by following the instructions and user guides available on the Tax Court website at ustaxcourt.gov/dawson.html. You will need to register for a DAWSON account to do so. You may also file your petition at the address below:
United States Tax Court
400 Second Street, NW
Washington, DC 2021 7 ustaxcourt.gov The websites of the U.S. Court of Federal Claims and the U.S. District Court for the District of Columbia contain instructions about how to file your completed complaint electronically. You may also file your complaint at one of the addresses below:
US Court of Federal Claims
717 Madison Place, NW
Washington, DC 20439 uscfc.uscourts.gov
US District Court for the District of Columbia
333 Constitution Avenue, NW
Washington, DC 20001 dcd.uscourts.gov Processing of income tax returns and assessments of any taxes due will not be delayed if you file a petition for declaratory judgment under IRC Section 7428.
The IRS office whose phone number appears at the top of the notice can best address and access your tax information and help get you answers. However, you may be eligible for free help from the Taxpayer Advocate Service (TAS) if you can't resolve your tax problem with the IRS or if you believe an IRS procedure just isn't working as it should. T AS is an independent organization within the IRS that helps taxpayers and protects taxpayer rights. Visit Taxpayer Advocate.IRS.gov/contact-us or call 877-777-4778 (TTY/TDD 800-829-4059) to find the location and phone number of your local advocate. Learn more about TAS and your rights under the Taxpayer Bill of Rights at Taxpayer Advocate.IRS.gov. Do not send your Tax Court petition to TAS. Use the Tax Court address provided earlier in the letter. Contacting TAS does not extend the time to file a petition.
Where you can find more information
Enclosed are Publication 1, Your Rights as a Taxpayer, and Publication 594, The IRS Collection Process, for more comprehensive information.
Find tax forms or publications by visiting IRS.gov/forms or calling 800-TAX-FORM (800-829-3676). If you have questions, you can call the person shown at the top of this letter.
If you prefer to write, use the address shown at the top of this letter. Include your telephone number, the best time to call, and a copy of this letter.
You may fax your documents to the fax number shown above, using either a fax machine or online fax service.
Protect yourself when sending digital data by understanding the fax service's privacy and security policies.
Catalog Number 74808E
Keep the original letter for yom records.
Euclm,ures:
Publication l
Publication 594
Publication 892
Sincerely, j.
(l-.~~ .. ·{ l);
UJii~'\. t.,;, i,•.t,r-t..:<\ 11,'~~,1 A. Brinklcv J ,,...
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Di1:ector, Ex~rnpt Organizations Examinations letter 6337 (Rev. 3-2024) Catalog Numbor MBOl!E ~ Department of the Treasury f_m
Internal Revenue Service
IRS Tax Exempt and Government Entitles CERTIFIED MAIL - Renrrn Receipt Requested Dear ,vny you're recei\"ing this letter Uyou agree
Date:
02/1212024
Taxpayer !D number:
-
Form: -
Tax periods ended:
Person to contact
Nam
ID n
Te
Fa
!Dnu
Response due date:
3/14/2024
If you haven't already, please sign the enclosed Fonn 6018, Consent to Proposed Action, and retw:n it to the contact person shown at the top of this letter. We'll issue a final ad,·erse letter deteanining that you aren't rm organization described in IRC Section 50l(c)(3) for the periods above.
If you disagl'ee
I. Request a meeting or telephone conference with the manager ~hown at the top of this h~tter.
2. Seud any iufr111nation you \Vnn! us lo consider.
3. File a protest with the IRS Appeals Otlice. Jfyou request a meeting with the manager or semi additional infonuatiou ns stated in l and~. above, y(1u 'U stlll be able lo file a protest \Vith IRS A.,ppeals Office afier the meeting or after ,1,;e consider the information.
The IRS Appeals Otlice is independent of the Exempt Organizatim1s division and resolves most disputes iufonually. If you file a protest the auditing agent may ask you to sign a consent to extend the period of limitations for assessing tax. TI1is is to allow the IRS Appeals Office enough time to consider your case.
For your protest to be valid, it nmst contain certain specific info1mation. including a statement of the facts. applicable law. and arguments in support of your position. For specific infomiation needed for a valid protest, refer to Publication 892. How to Appeal an IRS Detennination on Tax-Exempt Status.
Fast Trnck Mediation (FTM) referred to in Publication 3498. The Examination Process, generally doesn't apply no,v that we'w issued this letteL CBlalog Numrmr 34[l00F
4. Request technical advice from the Office of Associate Chief Counsel (Tax Exempt Government Entities) if you feel the issue hasn't been addressed in published precedent or has been treated inconsistently by the IRS.
If you're considering requesting technical advice, contact the person shown at the top of this letter. If you disagree with the technical advice decision, you will be able to appeal to the IRS Appeals Office, as explained above. A decision made in a technical advice memorandum, however, generally is final and binding on Appeals.
If we don't hear from you
If you don't respond to this proposal within 30 calendar days from the date of this letter, we'll issue a final adverse determination letter.
Contacting the Taxpayer Advocate Office is a taxpayer right
The Taxpayer Advocate Service (TAS) is an independent organization within the IRS that can help protect your taxpayer rights. TAS can offer you help if your tax problem is causing a hardship, or you've tried but haven't been able to resolve your problem with the IRS. If you qualify for TAS assistance, which is always free, TAS will do everything possible to help you. Visit www.taxpayeradvocate.irs.gov or call 877-777-4778.
Additional information
You can get any of the fonns and publications mentioned in this letter by visiting our website at www.irs.gov/forms-pubs or by calling 800-TAX-FORM (800-829-3676).
If you have questions, you can contact the person shown at the top of this letter. s· cerely, ~//.~ n A Matias, Supervisory, Internal Revenue Agent for Lynn A. Brinkley Enclosures:
Form 886-A
Form 6018
Director, Exempt Organizations Examinations Catalog Number 34809F Form 886-A (May 2017) Name of taxpayer

# ISSUE

Department of the Treasury - Internal Revenue Service
Explanations of Items
Tax Identification Number (last 4 digits) Schedule number or exhibit Year/Period ended
1. Whether qualifies for exemption under Sections 501 (c)(3) and public charity status under Section 509(a)(3) of the Internal Revenue Code as a Type Ill functionally integrated?
2. Whether the organization meets the requirements for operational test under Section 501(c)(3) of the Internal Revenue Code?
FACTS was formed in and is recognized as an IRC 509(a)(3) tax-exempt supporting organization with an effective date of The articles of incorporation dated , state the purpose of the organization.
The Form 990-EZ for shows that the Expenses had no exempt activity.
Statement of Program Service Accomplishments shows the organization's primary exempt purpose and shows no expenses incurred during the year.
On Schedule A attached to 990-EZ, Part IV Section D the organization answered question 1 "Yes" that the EO provided written notice to the describing the type or amount of support provided during the tax year.
On Schedule A attached to 990-EZ , , checked organization satisfied the Activities Test and completed responding with "Yes" to , that the , by On Information Document Request (IDR) response dated the organization responded" For calendar year no activities were undertaken to further the exempt activities Page _1 _ www.irs.gov Form 886-A (Rev. 5-2017) Form 886-A (May 2017) Department of the Treasury - Internal Revenue Service
Explanations of Items
Schedule number or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) Year/Period ended to directly further the exempt purposes of the supported organization. No requests were made in by ,, Section 501 (c)(3)-1 (a)(1) In order to be exempt as an organization described in section 501 (c)(3), an organization must be both organized and operated exclusively for one or more of the purposes specified in such section. If an organization fails to meet either the organizational test or the operational test, it is not exempt.
Section 509(a)-4(b)(1) Under subparagraph (A) of section 509(a)(3), in order to qualify as a supporting organization, an organization must be both organized and operated exclusively for the benefit of, to perform the functions of, or to carry out the purposes of (hereinafter referred to in this section as being organized and operated to support or benefit) one or more specified publicly supported organizations. If an organization fails to meet either the organizational or the operational test, it cannot qualify as a supporting organization.
Section 509(a)-4(e) Operational test-(1) Permissible beneficiaries, A supporting organization will be regarded as operated exclusively to support one or more specified publicly supported organizations (hereinafter referred to as the operational test) only if it engages solely in activities which support or benefit the specified publicly supported organizations. Such activities may include making payments to or for the use of, or providing services or facilities for, individual members of the charitable class benefited by the specified publicly supported organization.
GOVERNMENT'S POSITION
Section 509(a)-4(e) failed the operational test. In the organization did not engage in exempt activities nor provided support to supported organization. Based on all the facts and circumstances the supporting organization did not meet the operational test and exempt organization does not qualify for Section 501 (c)(3) tax exempt status Page _2_ www.irs.gov Form 886-A (Rev. 5-2017) Form 886-A (May 2017) Name of taxpayer
TAXPAYER'S POSITION
Department of the Treasury- Internal Revenue Service
Explanations of Items
Tax Identification Number (last 4 digits) The taxpayer's position is unknown at this time.

# Conclusion

Schedule number or exhibit
Year/Period ended
Exempt organization is not operated exclusively for exempt purpose because it was no exempt activities during tax year . It is recommended that Section 501 (c)(3) tax-exempt status be revoked effective Page _3_ www.irs.gov Form 886-A (Rev. 5-2017)