Private v. Public Interest Served

Department of the Treasury
Internal Revenue Service
IRS
Tax Exempt and Government Entities
Box 2508
Cincinnati, OH 45201
Dear
Release Number: 202515015
Release Date: 4/11/2025
UIL Code: 501.03-00,
501.03-30. 501.33-00
Date:
01/14/2025
Employer ID number:
Form you must file:
1120
Tax years:
All
Person to contact:
This letter is our final determination 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 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 determination, 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 forms 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 www.1rs.gov.
We'll make this final adverse determination letter and the proposed adverse determination letter available for public inspection after deleting certain identifying information, as required by IRC Section 6110. Read the enclosed Letter 437, Notice oflntention to Disclose - Rulings, 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 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.
Enclosures:
Letter 437
Redacted Letter 4034
Sincerely,
Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements
Catalog Number 47632S fj))
IRS
Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities
CERTIFIED MAIL - Return Receipt Requested
\Vhy you're receh'ing this letter
Date:
January 31, 2024
Ta~ber:
Form:
Tax-ended:
Pe
ID nu
Telep
Fax:
Addres
Manager's con
Name:
ID num er:
Telephone:
Response due date:
March 1, 2024
We enclosed a copy of om- audit report Fonn 886-A. Explanation ofltems. explaining that we propose to revoke yom tax-exempt status as an organization described in Internal Revenue Code

(IRC) Section 50l(c)(3).
If you agree
If you haven't already. plem,e sign the enclosed Form 6018. Consent to Proposed Action. and return it to the contact person shown at the top of this letter. \Ye'll issue a final adverse letter determining: that you aren't an organization described in IRC Section 50l(c)(3) for the periods above.
After we issue the final adverse determination letter. we '11 announce that your organization is no longer eligible to receive tax deductible contributions nuder IRC Section 170.
If you disagree
1. Request a meeting or telephone confe1·ence with the manager shown at the top of this letter.
2. Send any infonnation you want us to consider.
3. File a protest with the IRS Appeals Office. If you request a meeting with the ma11age1· 01· send additional information as stated in 1 and 2. above. you'll still be able to file a protest with IRS Appeals Otlice after the meeting or after we consider the infonnation.
The IRS Appeals Office is independent of the Exempt Organizations division and resolves most disputes informally. If you file a protest, the auditing agent may ask you to sign a consent to extend the period of limitations for assessing tax. This is to allow the IRS Appeals Office enough time to consider your case. For your protest to be valid, it must contain certain specific information, including a statement of the facts, applicable law, and arguments in support of your position. For specific information needed for a valid protest, refer to Publication 892, How to Appeal an IRS Determination on Tax-Exempt Status.
Fast Track Mediation (FTM) referred to in Publication 3498, The Examination Process, generally doesn't apply now that we've issued this letter.
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 T AS assistance, which is always free, TAS will do everything possible to help you.
Visit www.taxpayeradvocate.irs.gov or call 877-777-4778.
For additional information
You can get any of the forms 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).
2 Letter 3618 (Rev. 8-2019)
If you have questions, you can contact the person shown at the top of this letter.
Enclosures:
Form 886-A
Form 6018
Form 4621-A
Publication 892
Publication 3498
Sincerely,
~u)~,for
Lynn A. Brinkley
Director, Exempt Organizations
Examinations
3