Food-bank charity loses exemption after failing to substantiate its operations

View official IRS release (PDF)

Plain-English summary

The IRS revoked the exemption of an organization formed to solicit and distribute surplus food and other items to people struggling to make ends meet. The organization reported cash and noncash contributions, but it did not provide the requested supporting records for donations, gross receipts, expenses, payments to volunteers and day labor, or the distribution of donated food. Third-party donor responses did not match amounts reported on the organization's return, and the organization did not reconcile the differences. Its own daily spreadsheet showed payments to individuals, but it supplied no substantiation and reported no compensation on Forms W-2 or 1099-MISC. The IRS concluded that the organization failed to prove that it operated for exempt purposes, that its funds and food did not benefit insiders, and that it met federal recordkeeping requirements. Exemption was revoked effective January 1 of the redacted year.

Ruling snapshot

• Question: Did the food-bank organization establish that it operated exclusively for charitable purposes, avoided private inurement, and maintained records supporting its returns and activities?
• Outcome: Revocation effective January 1 of the redacted year
• Key authorities: IRC §§ 170, 501, 6001, and 6033; Treas. Reg. §§ 1.501(c)(3)-1 and 1.6001-1; Rev. Rul. 59-95

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
TE/GE: EO Examinations
1100 Commerce Street, MC 4920DAL
Dallas, TX 75242

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

October 9, 2015

Release Number: 201603041 Taxpayer Identification Number:
Release Date: 1/15/2016
UIL Code: 501.03-00 Person to Contact:

                                               Identification Number:

                                               Contact Telephone Number:

CERTIFIED MAIL
Dear:

This is a final adverse determination regarding your exempt status under section
501(c)(3) of the Internal Revenue Code (the Code). Our favorable determination letter
to you dated January 6, 20XX is hereby revoked and you are no longer exempt under
section 501(a) of the Code effective January 1, 20XX.

You have failed to establish that you are operated exclusively for exempt purposes
within the meaning of Internal Revenue Code section 501(c)(3), and that no part of your
net earnings inure to the benefit of private shareholders or individuals. You failed to
respond to repeated reasonable requests to allow the Internal Revenue Service to
examine your records regarding your receipts, expenditures, or activities as required by
I.R.C. sections 6001, 6033(a)(1), Treasury Regulation 1.6033-2(i)(2) and Rev. Rul. 59-
95, 1959-1 C.B. 627.

Contributions to your organization are no longer deductible under IRC §170.

You are required to file income tax returns on Form 1120. These returns should be
filed with the appropriate Service Center for the tax year ended December 31, 20 and
for all tax years thereafter in accordance with the instructions of the return.

Processing of income tax returns and assessments of any taxes due will not be delayed
should a petition for declaratory judgment be filed under section 7428 of the Internal
Revenue Code.

If you decide to contest this determination under the declaratory judgment provisions of
section 7428 of the Code, a petition to the United States Tax Court, the United States
Claims Court, or the district court of the United States for the District of Columbia must
be filed before the 91st Day after the date this determination was mailed to you. Please
contact the clerk of the appropriate court for rules regarding filing petitions for
declaratory judgments by referring to the enclosed Publication 892. You may write to
these courts at the following addresses:

United States Tax Court United States Court of Federal Claims
400 Second Street, NW 717 Madison Place, NW
Washington, D.C. 20217 Washington, D.C. 20005

United States District Court for the District of Columbia
333 Constitution Avenue, NW
Washington, D.C. 20001

The Taxpayer Advocate Service (TAS) is an independent organization within the
IRS that can help protect your taxpayer rights. We 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 our assistance, which is always free,
we will do everything possible to help you. Visit taxpayeradvocate.irs.gov or call
1-877-777-4778.

If you have any questions, please contact the person whose name and telephone
number are shown in the heading of this letter.

Sincerely,

Margaret Von Lienen
Director, EO Examinations

Enclosure:
Publication 892

Letter 3607(04-2002)
Catalog Number: 34198J

Internal Revenue Service Department of the Treasury
Tax Exempt and Government Entities Division
Exempt Organizations: Examinations
1100 Commerce Street MS 4900 DAL
Dallas, TX 75242-1100

Date:
January 15, 2015
Taxpayer Identification Number:

Form:
990 Return
Tax Year(s) Ended:
Dec. 31, 20XX
Person to Contact/ID Number:

Contact Numbers:
Telephone:
Fax:

Manager’s name/ID number:

Manager’s contact number:

Response due date:

Certified Mail — Return Receipt Requested
Dear

Why you are receiving this letter

We propose to revoke your status as an organization described in section 501(c)(3) of the
Internal Revenue Code (Code). Enclosed is our report of examination explaining the proposed
action.

What you need to do if you agree

If you agree with our proposal, please sign the enclosed Form 6018, Consent to Proposed
Action — Section 7428, and return it to the contact person at the address listed above (unless
you have already provided us a signed Form 6018). We'll issue a final revocation letter
determining that you aren’t an organization described in section 501(c)(3).

After we issue the final revocation letter, we'll announce that your organization is no longer
eligible for contributions deductible under section 170 of the Code.

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 revocation letter. Failing to respond to this proposal will adversely impact your legal
standing to seek a declaratory judgment because you failed to exhaust your administrative
remedies.

Effect of revocation status

If you receive a final revocation letter, you'll be required to file federal income tax returns for the
tax year(s) shown above as well as for subsequent tax years.

What you need to do if you disagree with the proposed revocation

If you disagree with our proposed revocation, you may request a meeting or telephone
conference with the supervisor of the IRS contact identified in the heading of this letter. You also
may file a protest with the IRS Appeals office by submitting a written request to the contact
person at the address listed above within 30 calendar days from the date of this letter.

The Appeals office is independent of the Exempt Organizations division and resolves most
disputes informally.

For your protest to be valid, it must contain certain specific information including a statement of
the facts, the applicable law, and arguments in support of your position. For specific information
needed for a valid protest, please refer to page one of the enclosed Publication 892, How to
Appeal an IRS Decision on Tax-Exempt Status, and page six of the enclosed Publication 3498,
The Examination Process. Publication 3498 also includes information on your rights as a
taxpayer and the IRS collection process. Please note that Fast Track Mediation referred to in
Publication 3498 generally doesn’t apply after we issue this letter.

You also may request that we refer this matter for technical advice as explained in Publication

892. Please contact the individual identified on the first page of this letter if you are considering
     requesting technical advice. If we issue a determination letter to you based on a technical
     advice memorandum issued by the Exempt Organizations Rulings and Agreements office, no
     further IRS administrative appeal will be available to you.

Contacting the Taxpayer Advocate Office is a taxpayer right

You have the right to contact the office of the Taxpayer Advocate. Their assistance isn’t a
substitute for established IRS procedures, such as the formal appeals process. The Taxpayer
Advocate can't reverse a legally correct tax determination or extend the time you have (fixed by
law) to file a petition in a United States court. They can, however, see that a tax matter that
hasn't been resolved through normal channels gets prompt and proper handling. You may call
toll-free 1-877-777-4778 and ask for Taxpayer Advocate assistance. If you prefer, you may
contact your local Taxpayer Advocate at:

Internal Revenue Service
Office of the Taxpayer Advocate

For additional information

If you have any questions, please call the contact person at the telephone number shown in the
heading of this letter. If you write, please provide a telephone number and the most convenient
time to call if we need to contact you.

Thank you for your cooperation.

Enclosures:

Report of Examination
Form 6018
Publication 892
Publication 3498

Sincerely,

Margaret Von Lienen
Director, EO Examinations

Letter 3618 (Rev. 6-2012)
Catalog Number 34809F

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

ISSUE

Should the exempt status of ( ) under Section 501(a) of the Internal
Revenue Code (IRC) as an organization described in IRC Section 501(c)(3) be revoked
effective January 1, 20XX?

FACTS

Form 1023

Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the
International Revenue Code, was signed and filed on November 9, 20XX, stating that the
primary purpose and mission is to address the problem of hunger and “food insecurity” in our
communities by soliciting and distributing surplus food, and non-food items, the will be an
additional resource for families and individuals who are struggling to make ends meet.

Internal Revenue Service granted exempt status to on January 6, 20XX.

Article of Incorporation

The Articles of Incorporation of the were filed on August 31, 20XX in the State of
. In the Articles of Incorporation, it provided that the specific purpose of is to raise funds and
to collect provisions to distribute to indigent families.

Forms 990

The Form 990 for the year 20XX was filed electronically by the Corporate Executive Officer,
, on November 11, 20XX. The Part I of the Form 990 provided its exempt
activities are to solicit and distribute surplus food and non-food items to those who are
struggling to make ends meet.

The Form 990 provided that received a total contribution of $ . Among the total
contribution, cash and fair market value of the non-cash contributions received were $
, and $ , respectively.

The Schedule B of Form 990 listed donors that made food donations to . The donors
were , , , , and . Fair market value of the
food donations made to were $ , $ , $ , $ , and $
, respectively.

Interview with Officer

The Corporate Executive Officer (CEO) of , , was interviewed on June 26,
20XX at offices of located at .

Form 886-A (1-1994) Catalog Number 20810W Page 1 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

   was asked who is qualified to come to receive food. He indicated that everyone

can get help with a small donation of $ per cart of food. He further explained that regional
food bank charges $ per pond to distribute further, and charges about $ per pond to
distribute.

   was asked the payment methods that the        used. He indicated that        accepts

cash, check, and credit card. does not accept food stamps. He also indicated that
received approximately $ and provided food for 30 to 35 families a day.

   was asked how the cash in the cash register was handled. He indicated that the

store manager deposited cash, checks, and credits in the bank every few days. He further
explained that does not have a cash register because the volunteers did not know how to use
it. However, the store manager would count the money every hour.

   was asked who recorded the cash received from the food bank operation every

day. He indicated that the store manager ( ) or bookkeeper ( ) recorded
the cash received every day. He also indicated that or would deposit the checks
when the organization received them.

During the interview appointment, also explained how the daily cash was handled.
He explained has a manager in the store to take care the daily operation because he is not in
the food bank to monitor the activities every day. He further explained that sometimes, at the
end of the day, the volunteers did not have money to go home; the manager would take some
money from the cash register and gave money to the volunteers. Also, if someone took the
money from the cash register, he would not know because there was no tape in the cash
register and he was not there.

Information Document Request (IDR)

IDR 001

IDR 001 requested records such as cash donations, non-cash donations, information on
volunteers, and gross receipts. None of the records requested for information on cash
donations, non-cash donations, volunteers, and gross receipts was provided.

IDR 002

In order to determine whether operates its exempt activities according to the rules and
regulations of charitable organizations, IDR 002 asked for the following:

• Copies of supporting documents of the business expenses.

• Copies of supporting documents of non-cash donations and cash donations.

A response was received on January 22, 20XX, it provided the following:

Form 886-A (1-1994) Catalog Number 20810W Page 2 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

• The table contained donors’ names and information on the non-cash donations made to
during the year 20XX. Among the donors, of the donors’ names and the total fair market
values of the donations were the same as the non-cash donation listed in the Schedule B of
20XX Form 990. The donors were , , ,
and , and the total fair market values of the food donations were $ ,
$ , $ , $ , and $ , respectively. The other donors
were and , and the total fair market values of the food
donations made to were $ and $ , respectively.

No requested supporting documents of the noncash donation were provided.

IDR 003

IDR 003 asked to provide supporting documents to demonstrate the food bank operation.
IDR 003 also asked to provide copies of delivery confirmation and supporting documents to
demonstrate when the non-cash donation contribution were received and how the fair market
values of the non-cash donations were determination.

A narrative prepared by to explain the daily food bank operation was received on
July 22, 20XX via fax. It indicated that the donated food were weighted and loaded into the
truck. In addition, the weights were recorded and gave to the store manager.

The narrative further explained that on many occasions has tried to establish some sort of
inventory and accountability of how much food is being brought in, how much food is being
provided to participants, how much food is being bulk sold, and how much is being thrown out.
However, it is practically impossible to have the accountability because so much of the food is
being thrown out, other is being spoiled, and the food does not have a predetermined and
consistent quality.

A daily cash operation spreadsheet from was received on September 2, 20XX. The daily
cash operation spreadsheet provided the revenue, expenses, and descriptions of expenses.
Furthermore, the daily cash operation spreadsheet provided the amounts paid and the names of
individuals / volunteers who received the payments.

None of the requested supporting documents were provided to demonstrate whether the
expenditures were used for furthering its exempt purposes.

IDR 004

IDR 004 asked to provide all bank/financial records pertaining to , and/or
, and related business entities whether held jointly or severally or as trustee or fiduciary as well
as custodian, executor or guardian which includes any other entities in which these individuals
may have a financial interest.

None of the requested supporting documents were provided.

1 is part of .

Form 886-A (1-1994) Catalog Number 20810W Page 3 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

IDR 005

IDR 005 asked to provide written explanations and contemporaneous documentation to
substantiate the expenses that were recorded in the daily operation spreadsheet including, but
not limited to, copies of the receipts and logs for 12 selected periods. No explanations and
contemporaneous documentation were provided.

Also, was asked to provide copies of supporting documents to demonstrate that the fair
market values of the non-cash donations received were computed accurately. None of the
requested supporting documents were provided.

IDR 006

Information Document Request 006 asked to explain and provide supporting documents to
demonstrate that the fair market values of the non-cash donations received were computed
accurately.

Also, was asked to provide copies of all documents that were provided by to the donors
with the donations. The documents requested included, but were not limited to, monthly
reports, shipping confirmation, and acknowledgment letters.

None of the requested supporting documents were provided.

Non-cash Donors’ Confirmations

Third party contacts were made to the non-cash donors listed on the Schedule B of 20XX
Form 990. They are , , , , , and
.

• A third party information inquiry letter was sent to on November 19,
20XX at the address shown on the Schedule B of Form 990.

A response from dated December 2, 20XX indicated that
did not make any donations to any organization.

• A third party information inquiry letter was sent to on November 19, 20XX at the
address shown on the Schedule B of Form 990.

A response dated December 21, 20XX from provided a letter dated
December 17, 20XX from to . The letter indicated that reported
51,000lbs and found that the actual amount was 22,846 lbs.; the balance of 28,146 lbs. was
donated by and several smaller meat companies. The letter states to
that will amend its return.

Form 886-A (1-1994) Catalog Number 20810W Page 4 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

The letter further explained that due to a change of service in 20XX to computerized
recording they do not have detailed records of 20XX to date for each donation or weights.
They also changed their email which deleted most of the saved emails. However,
provided a detailed list of dates and weights that can submit for its tax purposes.
The list showed that there were a total of 13 donations made from to
between February and December, 20XX, and the total weight of the donations was 22,846
lbs.

• A third party information inquiry letter was sent to on November 19, 20XX at the
address shown on the Schedule B of Form 990.

A response from dated December 13, 20XX indicated that they cannot find
any documentation associated with the donation that they made to .

• A third party information inquiry letter was sent to on
November 19, 20XX at the address shown on the Schedule B of Form 990.

A letter response from indicated that they made 12
different non-cash donations to , and provided the 12 donation receipts from . The
receipts included date, description, quantity, and value of the donations. The total value of
the 12 donations was $ . See Exhibit 1 for the donation receipts from .

• A third party letter was sent to the on November 19, 20XX at the address shown
on the Schedule B of Form 990.

   responded the request by providing a spreadsheet showing that        received a

total of 210,980 lbs. donated food from their 22 stores in the year 20XX. also
provided a letter to IRS and indicated that the pounds shown on the spreadsheet were the
pounds reported by the through emails.

LAWS

IRC §501(a) provides, in part, that organizations described in IRC §501(c) are exempt from
federal income tax. Section 501(c)(3) of the Code describes, in part, an organization that is
organized and operated exclusively for religious, charitable, scientific, testing for public safety,
literary, or educational purposes, no part of the net earnings of which inures to the benefit of any
private shareholder or individual.

Form 886-A (1-1994) Catalog Number 20810W Page 5 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Treasury Regulations §1.501(c)(3)-1(a)(1) states that 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.

Treasury Regulations §1.501(c)(3)-1(c)(1) states that an organization will be regarded as
“operated exclusively” for one or more exempt purposes only if it engages primarily in activities
which accomplish one or more of such exempt purposes specified in section 501(c)(3). An
organization will not be so regarded if more than an insubstantial part of its activities is not in
furtherance of an exempt purpose.

Treasury Regulations §1.501(c)(3)-1(c)(2) states that an organization is not operated exclusively
for one or more exempt purposes if its net earnings inure in whole or in part to the benefit of
private shareholders or individuals.

Treasury Regulations §1.501(c)(3)-1(d)(1)(ii) states that an organization is not organized or
operated exclusively for one or more of the purposes specified in subdivision (i) of this
subparagraph unless it serves a public rather than a private interest. Thus, to meet the
requirement of this subdivision, it is necessary for an organization to establish that it is not
organized or operated for the benefit of private interests such as designated individuals, the
creator or his family, shareholders of the organization, or persons controlled, directly or
indirectly, by such private interests.

IRC §6001 states that every person liable for any tax imposed by this title, or for the collection
thereof, shall keep such records, render such statements, make such returns, and comply with
such rules and regulations as the Secretary may from time to time prescribe. Whenever in the
judgment of the Secretary it is necessary, he may require any person, by notice served upon
such person or by regulations, to make such returns, render such statements, or keep such
records, as the Secretary deems sufficient to show whether or not such person is liable for tax
under this title.

IRC §6033(a)(1) of the Code states that in general, every organization exempt from taxation
under section 501(a) shall file an annual return, stating specifically the items of gross income,
receipts, and disbursements, and such other information for the purpose of carrying out the
internal revenue laws as the Secretary may be forms or regulations prescribe, and shall keep
such records, render under oath such statements, make such other returns, and comply with
such rules and regulations as the Secretary may from time to time prescribe.

Treasury Regulations §1.6001-1(a) in conjunction with Treasury Regulations §1.6001-1(c)
provides that every organization exempt from tax under IRC section 501(a) and subject to the
tax imposed by IRC §511 on its unrelated business income must keep such permanent books or
accounts or records, including inventories, as are sufficient to establish the amount of gross
income, deduction, credits, or other matters required to be shown by such person in any return
of such tax. Such organization shall also keep such books and records as are required to
substantiate the information required by IRC §6033.

Form 886-A (1-1994) Catalog Number 20810W Page 6 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Treasury Regulations §1.6001-1(e) states that the books or records required by this section
shall be kept at all times available for inspection by authorized internal revenue officers or
employees, and shall be retained so long as the contents thereof may become material in the
administration of any internal revenue law.

GOVERNMENT’S POSITION

Continuous efforts have been made since May 29, 20XX to obtain information from in order to
verify that the organization operated exclusively for an exempt purpose, the operation of a food
bank. Upon initial contact, CEO, , agreed to submit all requested information for the
year under examination in order to show compliance.

In order to meet the operational test, must demonstrate it engages primarily in activities
which accomplish one or more exempt purposes specified in section 501(c)(3). See Treas.
Reg. Section 1.501(c)(3)-1(d)(ii). An organization is not organized or operated exclusively for
exempt purposes unless it serves a public rather than a private interest. Information submitted
is not sufficient to demonstrate that has operated exclusively for charitable purposes
because:

• provided a daily spreadsheet to demonstrate the cash operations of its food bank
services. However, failed to provide any supporting documents to demonstrate the funds
were used exclusively for one or more exempt purposes and no part of its net earnings inure
to the benefit of officers, managers, or any individuals.

• provided a daily spreadsheet to demonstrate the cash operations of its food bank
services. The spreadsheet provided by , showed that had paid individuals / volunteers.
During the year 20XX, paid a total of $ to individuals / volunteers and un-
named day labor. Some of the payments to the individuals / volunteers were noted as
business expenses such as gas, U-Haul, food, expenses, supply, and barbeque. The
amounts received by the individuals / volunteers were ranged from $ to $ . In
addition, had a total of $ paid to a day labor during the year 20XX. No supporting
documents were provided with the daily cash operation spreadsheet to substantiate any of
the expenses recorded including the payments to individuals / volunteers and day labor.
did not report any compensations paid to the individuals / volunteers on Forms 1099-Misc.
or Forms W-2.

• was asked to provide supporting documents such as donation acknowledgements,
receipts, or delivery confirmations to demonstrate the amounts of non-cash donations
received. was unwilling or unable to provide any of the supporting documents.

The information inquiry letters were sent to the non-cash donors. The information submitted
by the non-cash donors show much less fair market values of foods were donated to then
reported on its 20XX Form 990. The organization has been unable to reconcile this
discrepancy.

Form 886-A (1-1994) Catalog Number 20810W Page 7 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Thus, has failed to demonstrate the amounts of non-cash donations received were
accurately reported on its 20XX Form 990. In addition, failed to demonstrate the donated
foods were properly distributed to the needy individuals, and no part of the donated foods
were used to the benefit of the officers, managers, and volunteers that run the organization.

   was unwilling or unable to provide the records necessary to support and substantiate the

financial information reported on its annual return. The information provided to Internal
Revenue Service to explain the transactions did not match the records that were
contemporaneously prepared and provided to the non-cash donors. Accordingly, failed to
comply with requirements under the Code §§6001 and 6033 and the Regulations thereunder.

Therefore, revocation is proposed as of January 1, 20XX. Form 1120 returns should be filed for
tax periods after December 31, 20XX.

CONCLUSION

In order for the organization to be considered an exempt organization under IRC § 501(c)(3), it
is required to be organized and operated for exempt purposes. failed to meet the operational
test for a section 501(c)(3) organization because failed to demonstrate that the funds were
used for furthering its exempt purposes and no part of the funds were used to the benefit of the
officers, managers, and volunteers. In addition, failed to demonstrate the donated foods were
properly distributed to the needy individuals, and no part of the donated foods were used to the
benefit of the officers, managers, and volunteers that run the organization.

   paid a total of $        to        individuals / volunteers and        un-named day labor.        failed to report

any compensations paid to the individuals / volunteers on Forms 1099-Misc. or Forms W-2.

   failed to comply with requirements under the Code §§6001 and 6033 and the Regulation

because was unwilling or unable to provide the records necessary to support and
substantiate the financial information reported on its annual return.

Therefore, revocation is proposed as of January 1, 20XX. Form 1120 returns should be filed for
tax periods after December 31, 20XX.

Form 886-A (1-1994) Catalog Number 20810W Page 8 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from

DONATION RECEIPT
Receipt #00584
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 9 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00702
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 10 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00717
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 11 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00727
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 12 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00769
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 13 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00798
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 14 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00835
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 15 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00908
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 16 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00927
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 17 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #00940
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 18 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #01669
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 19 publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number Year/Period ended
Dec. 31, 20XX

Exhibit 1 — Donation Receipts from (Continued)

DONATION RECEIPT
Receipt #01671
Date: [illegible]
Donor name:
Address:
City:
Contribution entries: [illegible]
Special handling instructions: [illegible]
Released by:
Received by:

• Donor is responsible for listing and estimating the value of the contributions.

Form 886-A (1-1994) Catalog Number 20810W Page 20 publish.no.irs.gov Department of the Treasury-Internal Revenue Service