Exemption revoked over tax-preparation business and private benefit

Plain-English summary

A section 501(c)(3) organization shared bank accounts and operations with a for-profit tax-return preparation business owned and operated by insiders. Bank records showed individual tax refunds and economic impact payments flowing through the accounts, along with substantial cash withdrawals and transfers that the organization did not substantiate as charitable expenses. The organization also referred people to named for-profit businesses, including one owned by a director, and did not provide requested books and financial records needed to verify its continued qualification. The IRS concluded that the organization served private interests, allowed net earnings to benefit insiders, and had a substantial nonexempt commercial purpose. It revoked the organization’s exemption under section 501(c)(3), and contributions were no longer deductible under section 170.

Ruling snapshot

• Question: Did the organization remain qualified under section 501(c)(3) while operating with an insider-owned tax-preparation business and failing to substantiate its finances?
• Outcome: revocation
• Key authorities: IRC §§ 501(c)(3), 6001, 6033; Treas. Reg. §§ 1.501(c)(3)-1, 1.6001-1, 1.6033-2(i)(2); Rev. Rul. 59-95

Full text (IRS public release)

Department of the Treasury Date:
Internal Revenue Service
Tax Exempt and Government Entities Taxpayer ID number (last 4 digits):

Release Number: 202404006
Release Date: 1/26/2024
UIL Code: 501.03-00

Form:

Tax periods ended:

Person to contact:
Name:

ID number:
Telephone:
Fax:

Last day to file petition with United States
Tax Court:

CERTIFIED MAIL - Return Receipt Requested
Dear

Why we are sending you this letter
This is a 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), effective
Your determination letter dated , is revoked.

Our adverse determination as to your exempt status was made for the following reasons: You have not
demonstrated 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 insiders. More than an
insubstantial part of your activities was not in furtherance of an exempt purpose. You operated for the primary
purpose of carrying on the unrelated trade or business of providing tax return preparation services.

Organizations that are not exempt under IRC Section 501 generally are required to file federal income tax returns
and pay tax, where applicable. For further instructions, forms and information please visit IRS.gov.

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

What you must do if you disagree with this determination

If you want to contest our final determination, you have 90 days from the date this determination 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 declaratory judgment
If you decide to contest this determination, you can file an action for declaratory judgment under the provisions

of Section 7428 of the Code in either:
• The United States Tax Court,
• The 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 within 90 days from the date we mailed this
determination letter to you. You can download a fillable petition or complaint form and get information about
filing at each respective court's website listed below or by contacting the Office of the Clerk of the Court at one
of the addresses below. Be sure to include a copy of this letter and any attachments and the applicable filing fee
with the petition or complaint.

Letter 6337 (Rev. 8-2022)
Catalog Number 74808E

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 20217

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.

We'll notify the appropriate state officials (as permitted by law) of our determination that you aren’t an
organization described in IRC Section 501(c)(3).

Information about the IRS Taxpayer Advocate Service

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 you believe an IRS procedure just isn't
working as it should. TAS is an independent organization within the IRS that helps taxpayers and protects
taxpayer rights. Contact your local Taxpayer Advocate Office at:

Internal Revenue Service

Or call TAS at 877-777-4778. For more information about TAS and your rights under the Taxpayer Bill of Rights,
go to taxpayeradvocate.IRS.gov. Do not send your federal court pleading to the TAS address listed above.
Use the applicable federal court address provided earlier in the letter. Contacting TAS does not extend the time

to file an action for declaratory judgment.

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.

Letter 6337 (Rev. 8-2022)

Catalog Number 74808E

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.

Keep the original letter for your records.

Sincerely,

Lynn A. Brinkley
Director, Exempt Organizations Examinations

Enclosures:
Publication 1
Publication 594
Publication 892

Letter 6337 (Rev. 8-2022)
Catalog Number 74808E

Date:

Department of the Treasury July 11, 2023
Internal Revenue Service Taxpayer ID number:

IRS Tax Exempt and Government Entities

Form:

Tax periods ended:

Person to contact:
Name:
ID number:
Telephone:
Fax:
Address:

Manager's contact information:
Name:
ID number:

Telephone:
Response due date:
August 10, 2023

CERTIFIED MAIL — Return Receipt Requested
Dear

Why you’re receiving this letter
We enclosed a copy of our audit report, Form 886-A, Explanation of Items, explaining that we
propose to revoke your tax-exempt status as an organization described in Internal Revenue Code

(IRC) Section 501(c)(3).

If you agree
If you haven’t already, please sign the enclosed Form 6018, Consent to Proposed Action, and

return it to the contact person shown at the top of this letter. We'll issue a final adverse letter
determining that you aren't an organization described in IRC Section 501 (c)(3) for the periods

above.

After we issue the final adverse determination letter, we’ll announce that your organization is no
longer eligible to receive tax deductible contributions under IRC Section 170.

If you disagree

1. Request a meeting or telephone conference with the manager shown at the top of this

letter.

2. Send any information you want us to consider.

3. File a protest with the IRS Appeals Office. If you request a meeting with the manager or
send additional information as stated in 1 and 2, above, you’ll still be able to file a protest
with IRS Appeals Office after the meeting or after we consider the information.

Letter 3618 (Rev. 8-2019)
Catalog Number 34809F

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 TAS 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)
Catalog Number 34809F

If you have questions, you can contact the person shown at the top of this letter.

Enclosures:
Form 6018
Form 4621-A
Form 886-A
Pub 892

Pub 3498

Sincerely,

Digitally signed by Jason E.
Brasch
Date: 2023.07.11 10:30:03 -07'00'

For Lynn Brinkley
Director, Exempt Organizations

Examinations

Letter 3618 (Rev. 8-2019)
Catalog Number 34809F

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended
ISSUES

1. Whether (the Organization) provided information verifying its continued

qualification for exempt status under Section 501(c)(3) of the Internal Revenue Code (IRC), as
required by IRC Section 6033(a)(1).

2. Whether the Organization engaged in nonexempt activities prohibited by IRC Section 501(c)(3).
3. Whether the Organization’s exempt status should be revoked for engaging in nonexempt activities
and failing to provide information verifying its continued qualification for exempt status for the tax
period ending

FACTS
The Organization was incorporated in the State of on , as a non-profit public
benefit corporation. Article of its Articles of Incorporation state its purpose is to “

” The Organization is currently in active good standing

with the Secretary of State.

On , the Internal Revenue Service (IRS) received Form 1023, Application for
Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, from the Organization
requesting exemption from income tax under IRC Section 501(c)(3). The Organization provided the
following narrative description of its activities:

On , the IRS granted tax-exemption to the Organization under IRC Section 501(c)(3), and
further classified it as a public charity described in IRC Sections 509(a)(1) and 170(b)(1)(A)(vi), effective

On , the Organization filed Form 990-EZ, Short Form Return of Organization Exempt
from Income Tax, for tax year ended

In , the assigned agent began an examination of the Organization’s Form 990-EZ for tax years
ended , and

On , the assigned agent issued the initial contact letter and Information Document Request

(IDR) to the Organization. No response was received by the assigned agent.

On , the assigned agent issued notice of third-party contact, IDR delinquency notice, and
IDR to the Organization. No response was received by the assigned agent.

Catalog Number 20810W 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/Periods ended

The assigned agent obtained bank statements for the Organization’s checking and savings accounts with
as the signatory on the accounts,

. The signature cards show

The bank statements show the following deposits and withdrawals for tax year

amounts reported on the Form 990-EZ:

, compared to the

Per Form 990-EZ

Per Bank Statements

Difference

Total Revenue/Deposits

$

$

$

Total Expenses/Withdrawals

On , the assigned agent issued IDR to the Organization requesting supporting
documentation for the transactions listed in the bank statements. See the enclosed Attachment for the list of

transactions.

On , the assigned agent received a fax from Mr.

, Director, with a written

response to IDR . The response included the following explanation of its sources of income:

On , the assigned agent issued IDR

On , the assigned agent conducted an interview and tour of facilities with
, where he provided the

Organization’s property, located at
following information:

to the Organization with scheduled site visit for ,

at the

Catalog Number 20810W

Page 2

www.irs.gov

Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended
The Organization has board members:

1. , Executive Director

2. , Treasurer and Secretary

3. , Director.

4. , Director.

5. , Director and Controller
On , the assigned agent issued IDR to the Organization with scheduled in-person appointment
for
On , the assigned agent received a fax from with confirmation of e-filing Forms
990-N postcard for tax years , , and
On , the Organization filed Form 990-N, Electronic Notice (e-postcard) for Tax-Exempt
Organizations Not Required to File Form 990 or Form 990-EZ, for tax year ended
originally due . The Organization indicated on its Form 990-N that it received not more than

$50,000 in gross receipts during the accounting period, without subtracting any costs or expenses.

The bank statements show the following deposits and withdrawals for tax year , compared to the Form
990-N:

Per Form 990-N Per Bank Statements Difference
Total Revenue/Deposits Not more than $ $ $
Total Expenses/Withdrawals -

On , the Organization filed Form 990-N for tax year ended , originally due
. The Organization indicated on its Form 990-N that it received not more than $ in

gross receipts during the accounting period, without subtracting any costs or expenses.

On , the Organization filed Form 990-N for tax year ended . The
Organization indicated on its Form 990-N that it received not more than $50,000 in gross receipts during the
accounting period, without subtracting any costs or expenses.

On , the assigned agent received a phone call from cancelling the in-person
appointment scheduled

On , the assigned agent issued a delinquency notice for IDR with response due
No response has been received by the assigned agent.

Catalog Number 20810W Page 3 www.irs.gov Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended
On , the assigned agent expanded the examination to include tax years ended ,
, and . The assigned agent issued IDR _ to the Organization requesting the relevant
accounting records and financial statements with response due . No response has been received

by the assigned agent.

LAW

IRC Section 501(c)(3) provides in part tax-exemption to corporations organized and operated exclusively
for religious, charitable, or similar purposes, no part of the net earnings of which inures to the benefit of any
private shareholder or individual.

IRC Section 6033(a)(1) provides in part that 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 by
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 Section (Treas. Reg.) 1.501(a)-1(c) defines “private shareholder or individual” as
referring to persons having a personal and private interest in the activities of the organization.

Treas. Reg. 1.501(c)(3)-1(c)(2) states that an organization is not operated exclusively for charitable purposes
if its net earnings inure in whole or in part to the benefit of private shareholders or individuals.

Treas. Reg. 1.501(c)(3)-1(d)(1)(ii) states in part that an organization is not organization exclusively for
exempt purposes unless it serves public, rather than private, interests. Thus, it is necessary for the
organization to establish that it is not organization or operated for the benefit of private interests such as
designated individuals, the creator or their family, shareholders of the organization, or persons controlled,
directly or indirectly, by such interests.

Treas. Reg. 1.6001-1(a) provides in part that any person subject to tax under Subtitle A of the Code, or any
person required to file a return of information with respect to income, shall keep such permanent books of
account or records, including inventories, as are sufficient to establish the amount of gross income,
deductions, credits or other matters required to be shown by such person in any return of such tax or
information.

Treas. Reg. 1.6001-1(c) provides in part that every organization exempt from tax under section 501(a) shall
keep such permanent books of account or records, including inventories, as are sufficient to show
specifically the items of gross income, receipts and disbursements. Such organizations shall also keep such

books and records as are required to substantiate the information required by section 6033.

Treas. Reg. 1.6001-1(d) provides in part that the district director may require any person, by notice served
upon him, to make such returns, render such statements, or keep such specific records as will enable the
district director to determine whether or not such person is liable for tax under Subtitle A of the Code.

Catalog Number 20810W Page 4 www.irs.gov Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended

Treas. Reg. 1.6001-1(e) provides in part 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.

Treas. Reg. 1.6033-2(i)(2) provides in part that every organization which is exempt from tax shall submit
such additional information as may be required by the Internal Revenue Service for the purpose of inquiring
into its exempt status and administering the provisions of Subchapter F, Chapter 1 of Subtitle A of the Code,
section 6033, and Chapter 42 of Subtitle D of the Code.

Revenue Ruling 59-95, 1959-1 C.B. 627 held that failure or inability to file the required information return
or otherwise to comply with the provision of section 6033 of the Code and the regulations which implement
it, may result in the termination of the exempt status of an organization previously held exempt, on the
grounds that the organization has not established that it is observing the conditions required for the
continuation of an exempt status.

In Airlie Foundation, Inc. v. Commissioner of Internal Revenue (CIR), 70 T.C. 352 (1978) the Court held
that in cases where an organization’s activities could be carried out for either exempt or nonexempt
purposes, courts must examine the manner in which those activities are carried out in order to determine
their true purpose.

In American Campaign Academy v. CIR, 92 T.C. 1053 (1989), the Court held in part that operating for the
benefit of private interests is a nonexempt purpose.

In Northwestern Municipal Ass’n v. United States, 99 F.2d 460, 463 the Court found that the phrase “net
earnings”, as used in Section 501(c)(3), may include “more than the term net profits as shown by the books
of the organization or the difference between the gross receipts and disbursements in dollars.”

In United Missionary Aviation, Inc. v. CIR, 60 T.C.M 1152, (CCH) 1990-566 the Court held in part that an
organization does not qualify for tax exemption if it has a substantial nonexempt commercial purpose.

ORGANIZATION’S POSITION
The Organization has not provided a position.

GOVERNMENT’S POSITION

Issue #1: Whether the Organization provided information verifying its continued qualification for exempt
status under Section 501(c)(3) of the Internal Revenue Code (IRC), as required by IRC Section

6033 (a)(1).

IRC Section 6033(a)(1) requires exempt organizations to file annual information returns (Form 990, Form
990-EZ, or Form 990-PF) with an exception for organizations with annual gross receipts not normally more
than $5,000. Treas. Regs. 1.6001-1 and 1.6033-2(i)(2) require exempt organizations to keep permanent
books of account or records to substantiate the information report on the annual information returns, and to

Catalog Number 20810W Page 5 www.irs.gov Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended

provide such records as may be required by the Internal Revenue Service for the purpose of inquiring into its
exempt status.

The activity and ending balances shown in the bank records do not match amounts reported on the
Organization’s Form 990-EZ for tax year . The bank records also show approximately $

deposited into the Organization’s bank accounts during , which far exceeds the $50,000 filing threshold
for the Form 990-N e-Postcard, indicating the Organization filed the wrong type of return.

The assigned agent requested explanation and supporting documentation to support the exempt nature of the
expenditures listed in the bank records, including substantiation to justify the following cash and equivalent
transactions made in and :

Amount Description
$ ATM withdrawals
transfers to
Transfers to unknown accounts
Debits to unknown destinations

The Organization has not provided a response to IDRs and _ requesting it provide its books of account and
financial statements to the assigned agent to evaluate its qualification for exemption.

In response to IDR, the Organization stated in writing it makes retail purchases on behalf of
’s clients but provided no supporting documentation or substantiation for its expenditures during
the examination years.

During the in-person field visitation, the Organization stated the ATM withdrawals were also for these
clients of . The Organization did not fully respond to IDR __ by failing to provide the
financial records to the assigned agent. The assigned agent informed the Organization that their response
was incomplete and that they must provide the financial records.

The Organization has not provided a response to IDR requesting supporting documentation for the
transactions claimed to be made on behalf of ’s clients to the assigned agent.

The assigned agent made multiple attempts to request the necessary information from the Organization to
properly evaluate its qualification or exempt status, and the Organization has not fully responded to the
requests. The Organization did not request an extension of time to provide such information or provide a
reason for its failure to respond. The assigned agent cannot properly determine the Organization is qualified
for its tax-exempt status because of the Organization’s failure to provide the necessary information.

The Organization has not provided information or records to assert its qualification for tax exemption under
IRC Section 501(c)(3) as required by IRC Section 6033(a)(1).

Issue #2: Whether the Organization engaged in nonexempt activities prohibited by IRC Section 501(c)(3).

Catalog Number 20810W Page 6 www.irs.gov Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended

Treas. Reg. 1.501(c)(3)-1(c)(2) provides that an organization is not operated exclusively for exempt
purposes if its net earnings inure in whole or in part to the benefit of private shareholders or individuals.
Treas. Reg. 1.501(c)(3)-1(d)(1)(ii) states in part that an organization is not organization exclusively for
exempt purposes unless it serves public, rather than private, interests. An organization must establish it is
not organized or operated for the benefit of private interests such as the creator or their family.

Executive Director stated the Organization shares its bank accounts with
, a for-profit income tax preparation organization owned and operated by and Director,
. The Organization’s bank accounts show the following sources of income received during
tax years and

Amount Source

$ State of Franchise Tax Board income tax refunds
IRS Dept of Treasury income tax refunds
IRS Dept of Treasury COVID Economic Impact Payments (EIP)
ATM Cash deposits

transfers in

e-deposits
Varo transfers in

The deposits from the State of and IRS Department of the Treasury are addressed to specific
individual taxpayers for either tax refunds or COVID-related relief payments. The Organization and
comingle assets and activities, making the for-profit business part-and-parcel to the
operation of the exempt organization. The Organization could not distinguish the income, expenses and
operations from that of the for-profit tax corporation. Similar to United Missionary Aviation Inc, v. CIR, the
Organization has a substantial nonexempt commercial purpose, barring qualification from tax exemption.

As stated previously, the bank statements also reveal substantial dealings in cash and cash equivalents,
including $ in ATM cash withdrawals and $ in transfers to via during
tax years and . There is no evidence in the record to support how these transactions furthered the
Organization’s exempt purpose, and the Organization has not provided documentation nor sufficient
explanation to show as much. These withdrawals served ’ private interests by benefitting him
personally, which is a nonexempt purpose under IRC Section 501(c)(3). As held in American Campaign
Academy v. CIR, operating for the benefit of private interests is a nonexempt purpose.

Additionally, the activities described by —job referrals, childcare referrals, and income tax
preparation referrals—serve the private interests of the referred businesses rather than those of the public.
The referrals are made based on verbal agreements to specifically-named for-profit businesses, one of which
is owned by a Director of the Organization. As the Court held in Northwestern Municipal Ass’n v. United
States, the phrase ‘net earnings’ as used when defining inurement includes more than the term net profits as
shown by the books of the organization or the difference between the gross receipts and disbursements in

Catalog Number 20810W Page 7 www.irs.gov Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number
(May 2017) Explanations of Items or exhibit
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Periods ended

dollars. As such, the Organization is not operated exclusively for exempt purposes because its net earnings
inure to the benefit of private shareholders and individuals.

The Organization has provided no evidence to establish it is not organized and operated for the benefit of the
board members and their families as required by Treas. Reg. 1.501(c)(3)-1(d)(1)(ii). Thus, it is concluded
that the Organization’s expenditures and activities served private interests and allowed its net earnings to
inurement the benefit of private individuals. As such, the Organization has engaged in nonexempt activities
barring continued qualification for tax exemption under IRC Section 501(c)(3).

Issue #3: Whether the Organization’s exempt status should be revoked for engaging in nonexempt
activities and failing to provide information verifying its continued qualification for exempt status for the
tax period ending

The Organization has engaged in nonexempt activities and failed to provide documentation or testimony to
support its exempt status and therefore does not qualify for exempt status under IRC Section 501(c)(3). The
Organization fails to qualify for tax exemption effective the of the tax year in which it failed to
qualify for exempt status, or

CONCLUSION
The Organization has engaged in nonexempt activities and failed to provide information verifying its
continued qualification for exempt status under IRC Section 501(c)(3) and should have its status revoked for

the tax period ending , effective

Catalog Number 20810W Page 8 www.irs.gov Form 886-A (Rev. 5-2017)