NIL collective was denied charitable exemption

Plain-English summary

A nonprofit proposed to pay student athletes from one university for personal appearances and social media posts promoting nearby charities. It argued that the arrangement would expand the charities' visibility, teach philanthropy, and benefit the community, while also compensating athletes for use of their names, images, and likenesses. The IRS found that the athletes were not selected based on financial need and that paying them would consume a substantial share of the organization's receipts. Because the program directly benefited a limited group of athletes and increasing their paid opportunities was a substantial purpose, the IRS concluded that the private benefit was not incidental to an exempt purpose. The organization failed the Section 501(c)(3) operational test and was denied charitable exemption.

Ruling snapshot

• Question: Did the NIL collective operate exclusively for charitable and educational purposes under Section 501(c)(3)?
• Outcome: denied
• Key authorities: IRC § 501(c)(3); Treas. Reg. § 1.501(c)(3)-1; Rev. Ruls. 61-170, 70-186, 75-286, 76-152, and 76-206

Full text (IRS public release)

Department of the Treasury Date:
Internal Revenue Service 01/10/2024

Tax Exempt and Government Entities Employer ID number:
IRS PO Box 2508
Cincinnati, OH 45201 Tax years:
All

Person to contact:

Release Number: 202414007
Release Date: 4/5/2024

UIL Code: 501.03-30,

501.32-01, 501.33-00,
503.00-00

Dear

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 501(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.irs.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 of Intention 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.

Letter 4038 (Rev. 11-2021)
Catalog Number 47632S

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:

Letter 437

Redacted Letter 4034
Redacted Letter 4038

Letter 4038 (Rev. 11-2021)
Catalog Number 47632S

Department of the Treasury
Internal Revenue Service
IRS PO Box 2508
Cincinnati, OH 45201
Date:
November 13, 2023

Employer ID number:

Person to contact:

Name:

ID number:

Telephone:

Fax:
Legend: UIL:
C = state 501.03-30
D = date 501.32-01
E = university 501.32-01
F = date range 1 501.33-00
G = date range 2 503.00-00

w percent = number 1
X percent = number 2
y percent = number 3

Dear

We considered your application for recognition of exemption from federal income tax under Internal Revenue
Code (IRC) Section 501(a). We determined that you don’t qualify for exemption under IRC Section 501(c)(3).
This letter explains the reasons for our conclusion. Please keep it for your records.

Issues
Do you qualify for exemption under IRC Section 501(c)(3)? No, for the reasons stated below.

Facts

You are a nonprofit organization incorporated in C on D. You were formed to engage student athletes at the
college level to lend their Name, Image and Likeness (NIL) to other charitable organizations in the vicinity.
This arrangement for student athletes is to monetize their NIL by matching the selected students with deals in
which they are paid by you to promote local charitable organizations. The student athletes selected will make
personal appearances and social media posts for the charity. Initially you will work with student athletes at the
E. Your revised budget indicates approximately w percent of your gross receipts will be paid to student athletes
for their services. You expect no more than x percent of your total gross receipts will be paid to student athletes
utilizing their NIL.

Your website states that you are a registered 501(c)(3) non-profit NIL collective that instills the importance of
humanitarian work and philanthropy into its student-athletes. Your website also states that donations are tax
deductible, and that you enable athletes to earn compensation for their NIL by partnering with other Section

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

2

501(c)(3) organizations who better your community. As more charitable opportunities are created you will
impact the future success and retention of E student athletes.

You assert that not only will student-athletes benefit monetarily from NIL opportunities by working with you,
but also, the community will benefit as well. The proposed NIL approach to philanthropy will create
relationships with charitable and educational organizations which will advance the economic interests of the
charities and benefit education as well. You will bring together private donors, local businesses and fans with
student athletes from the E. You will instill in student athletes the importance of humanitarian work and
philanthropy as a part of education. This exempt purpose may be accomplished by creating an NIL platform
with student athletes and other charities in the community. The student athletes will benefit monetarily from
the NIL opportunity, and the community will also thrive through this philanthropic and educational approach to

giving.

The student athletes who are engaged will sign an Independent Contractor (IC) agreement with you. The IC
agreement will spell out in detail the effective dates of the engagement and amount of compensation for the
student athlete.

The charity will sign a Letter of Understanding (LOU) with you which will contain the representations and
terms of the agreement. The representations in the LOU will include a scope of work statement which will
define the NIL services by the student athlete on behalf of the charity. Also, there will be some oversight by the
charity, and you will be notified promptly if the student athlete fails to complete the NIL services.

You submitted a financial data statement with Form 1023 which was later superseded by an updated financial
data statement. The initial financials with data from (F) showed that y percent of revenues were paid out to
student athletes as compensation. The revised financials for the period (G) forecast that about w percent of
revenues would be paid to student athletes as compensation. You expect that no more than x percent of your
total gross receipts will be paid to student athletes for the use of their NIL. The compensation to student athletes
will be for personal appearances and speaking engagements on behalf of the charities. You do not impose a cap
on payments to student athletes.

You expect that the efforts by the student athletes will lead to an increased level of public donations to the
charities with the overall result benefiting the charities and the community.

You plan to engage in direct contact with existing charitable and educational organizations, implementing
“sports clinics targeted to community youth.” You also stated that you plan on directly funding, in the future,
charitable and educational initiatives maintained by other tax-exempt organizations in the community.

Your funding will come from fans, alumni of the E and generous private donors. You anticipate direct
advertisement to the students and the public will also be used but that has not yet been developed.

Law
IRC Section 501(c)(3) provides exemption under section 501(a) for organizations organized and operated

exclusively for one or more of the exempt purposes set forth in section 501(c)(3).

Treasury Regulation Section 1.501(c)(3)-1(a)(1) states that, in order to be exempt as an organization described
in IRC Section 501(c)(3), an organization must be both organized and operated exclusively for one or more of

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

3

the purposes specified in such section. If an organization fails to meet either the organizational test or
operational test, it is not exempt.

Treas. Reg. Section 1.501(c)(3)-1(c)(1) provides 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.

Treas. Reg. Section 1.501(c)(3)-1(d)(1)(ii) provides that an organization is not organized or operated
exclusively for exempt purposes unless it serves a public rather than a private interest. To meet this
requirement, an organization must 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.

Rev. Rul. 61-170, 1961-2 C.B. 112 (1961), held that an association of professional nurses that operated a
nurses’ registry to provide greater employment opportunities to its members and to organize an adequate and
available nursing placement service for the community did not qualify for exemption under section 501(c)(3).
By operating an employment service principally for the benefit of its members, the organization served private
interests more than insubstantially and consequently was not organized and operated exclusively for charitable
or other exempt purposes.

Rev. Rul. 70-186, 1970-1 C.B. 128 held that an organization formed to preserve a lake as a public recreational
facility qualified for exemption under section 501(c)(3), even though the organization’s activities also benefited
lakefront property owners. The Service determined that the benefits of the organization’s activities flowed
principally to the general public and that it would have been impossible for the organization to accomplish its
exempt purposes without providing some benefit to the lakefront property owners.

Rev. Rul. 75-286, 1975-2 C.B. 210, held that an organization formed by the residents of a city block to beautify
and preserve that block did not qualify for exemption under section 501(c)(3). The restricted nature of the
organization’s membership and the limited area in which its improvements were made indicated that the
organization was organized and operated to serve private interests by enhancing the value of its members’

property rights.

Rev. Rul. 76-152, 1976-1 C.B. 151, held that an organization formed by art patrons to promote community
understanding of modern art trends did not qualify for exemption under section 501(c)(3). The organization
exhibited and sold the artwork of local artists, who received 90 percent of sales proceeds. This provision of
direct benefits served the private interests of the artists and could not be dismissed as being merely incidental to
its other purposes and activities, and therefore the organization was not operated exclusively for educational
purposes.

Rev. Rul. 76-206, 1976-1 C.B. 154, held that an organization formed to generate community interest in the
retention of classical music programs by a local for-profit radio station did not qualify for exemption under
section 501(c)(3). The organization’s activities enabled the radio station to increase its total revenue and, by
increasing its listening audience, would enhance the value and salability of the station’s airtime. The
organization’s activities benefited the station in a more than incidental way and served a private rather than a
public interest.

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

Better Business Bureau of Washington D.C. Inc. v. United States, 326 U.S. 279 (1945), held that the presence
of a single nonexempt purpose, if substantial in nature, will preclude exemption regardless of the number or
importance of truly exempt purposes.

B.S.W. Group, Inc. v. Commissioner, 70 T.C. 352 (1978), held that the purpose towards which an
organization’s activities are directed, and not the nature of the activities themselves, is ultimately dispositive of
the organization’s right to be classified as a section 501(c)(3) organization.

Christian Manner International, Inc. v. Commissioner, 71 T.C. 661 (1979), held that an organization whose
primary activity was the publication and sale of religious books written by its founder did not qualify for
exemption under section 501(c)(3). The Tax Court noted in this case that when an activity furthers both an
exempt and nonexempt purpose, qualification for exemption depends on whether the nonexempt purpose is so
incidental to the exempt purpose as not to disqualify the organization for exemption.

Est of Hawaii v. Commissioner, 71 T.C. 1067(1979), held that an organization created to disseminate
educational programs, the rights to which were owned by for-profit corporations, furthered the commercial,
private purposes of the for-profit entities and did not qualify for exemption under section 501(c)(3). The Tax
Court noted that the critical inquiry was not whether the payments to the for-profit corporations were
reasonable, but whether the for-profit entities benefited substantially from the organization’s operations.

In Goldsboro Art League, Inc. v. Commissioner of Internal Revenue, 75 T.C. 337, 344 (1980), the organization
exhibited in its two public galleries, “an artists more daring works in a part of the country where there were no
nearby art museums or galleries.” Due to the “difficulty attracting artists to exhibit their work,” the organization
offered the displayed works for sale. Moreover, the organization conducted numerous arts education activities
and displayed its own permanent collection of art throughout various public buildings. Under these specific
circumstances, the tax court found that the private benefit to the artists for the sale of their artwork was
secondary and incidental to the primary purpose of educating the public on art.

American Campaign Academy v. Commissioner, 92 T.C. 1053, 1076 (1989) held that a school that trained
individuals for careers as political campaign professionals was not described in section 501(c)(3) because its
operations benefited the private interests of entities and candidates associated with a single political party. The
Tax Court observed that an organization’s conferral of benefits on disinterested persons (i.e. unrelated third
parties) may cause the organization to serve private rather than public interests.

In City of Galveston, Texas v. United States, 33 Fed. Cl. 685, 707-08 (1995), the court indicated that “[a]
taxpayer cannot premise its right to an exemption by showing that others have been treated more generously,
leniently or even erroneously by the IRS.”

Application of law

IRC Section 501(c)(3) and Treas. Reg. Section 1.501(c)(3)-1(a)(1) set forth two main tests for an organization
to be recognized as exempt. An organization must be both organized and operated exclusively for purposes
described in Section 501(c)(3). Based on the information provided in your application and supporting
documentation, we conclude that you fail the operational test.

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

5

Qualification for exemption under IRC Section 501(c)(3) requires that an organization operate exclusively for
exempt purposes. Exclusivity with respect to Section 501(c)(3) does not mean “solely” or “without exception”
but rather contemplates that any non-exempt activities be only incidental and less than substantial. See Treas.
Reg. Section 1.501(c)(3)-1(c)(1).

Based on the facts presented in your application, you serve a private rather than a public interest, because you
confer benefits primarily on student athletes of a particular university’s sports teams for the use of their NIL.
You have not demonstrated that these student athletes belong to a charitable class. To qualify for exemption
under IRC Section 501(c)(3), you must serve a public, rather than private interest, as described in Treas. Reg.
Section 1.501(c)(3)-1(d)(1)(ii). Because you plan to spend between w percent and x percent of your funds to
acquire the NIL rights of student athletes, you operate substantially for a private interest rather than a public
interest.

Similar to Rev. Rul. 61-170, in which an organization operated to increase the employment opportunities
available to its members, your primary activity is to increase the number of paid NIL opportunities for the
student athletes of one particular university. You focus your efforts on arranging NIL deals between local
charities and student athletes to further the nonexempt purpose of providing student athletes with compensation.
Thus, a substantial and non-incidental part of your activities furthers private interests.

You are unlike the organization in Rev. Rul. 70-186, which was formed to preserve a lake as a public
recreational facility. The organization’s activities clearly benefited the public at large, but they also provided
some benefit to private individuals owning lakefront property. The benefit to private interests was qualitatively
incidental. The benefit to private interests was a necessary concomitant of the exempt activity because it would
have been impossible to accomplish the exempt purpose without benefiting the lakefront property owners. The
benefit to private interests was indirect and clearly incidental to the organization’s overriding purpose of
preserving the lake. In contrast, your activities result in a direct monetary benefit to E student athletes. In
addition, you have not established how exclusively benefiting the student athletes of one school is a necessary
concomitant of providing promotional/marketing services to local charities. There are alternative means by
which you could promote local charities without conferring a substantial private benefit on these student
athletes, such as by encouraging volunteerism. Therefore, the private benefit from your activities is not
qualitatively incidental to exempt purposes.

As in Rev. Rul. 75-286, your activities result in a direct benefit to a limited group of individuals; therefore, the
private benefit from your activities is not qualitatively incidental to the exempt purposes.

Just like the artists in Rev. Rul. 76-152, who directly benefited by the exhibition and sale of their works, the
student athletes who are engaged in your activities are directly benefited by the compensation they receive for
use of their NIL. Given that you plan on spending up to x percent of your gross receipts to acquire NIL rights of
student athletes, compensating student athletes for their NIL rights is one of your substantial activities and is
serving the private interests of those student athletes who participate. This direct monetary benefit to student
athletes is substantial and cannot be considered merely incidental. See Rev. Rul. 76-152, 1976-1 C.B.
151(1976) “[T]he artists in subject case are being directly benefited by the exhibition and sale of their works,
with the result that a major activity of the organization is serving private interests of those artists whose works
are displayed for sale. Since ninety percent of all sale proceeds are turned over to individual artists, such direct
benefits are substantial by any measure and the organization’s provision of them cannot be dismissed as being

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

6

merely incidental to its other purposes and activities.” Similarly, you provide a direct monetary benefit to
student athletes that is substantial and cannot be considered merely incidental.

Similar to the organization described in Rev. Rul. 76-206, whose activities were intentionally designed to
benefit the for-profit radio station so that it could continue broadcasting classical music, your activities are
designed to increase the number of paid NIL opportunities for the student athletes. The intentional private
benefit from your activities cannot be considered qualitatively incidental to the accomplishment of an exempt
purpose.

You plan on implementing “sports clinics targeted to community youth” and other charitable and educational
initiatives. However, under Better Business Bureau of Washington, D.C., Inc v. United States, even if these
activities further an exempt purpose (which they might not if these activities also substantially benefit the
private interests of the student athletes by providing them with more opportunities for monetary compensation),
the presence of a single non-exempt purpose, if substantial in nature, will destroy the exemption regardless of
the number or importance of truly exempt purposes.

As noted in American Campaign Academy v. Commissioner when an organization operates for the benefit of
private interests, the organization, by definition, does not operate exclusively for exempt purposes. In American
Campaign Academy, the organization operated a program to educate and/or train people to work for political
campaigns; however, the court decided that the organization was not exempt as an organization that furthers
educational purposes because the organization’s program was a feeder program for one specific political party,
and thus, the primary activity of the organization substantially furthered private interests. Like in American
Campaign Academy, your activities are aimed at benefiting a designated group, namely student athletes of one
university. Similarly, one of your substantial activities, providing promotional, marketing, and publicity
services to charities, does not make you exempt as charitable because this activity provides substantial private
benefit to the student athletes.

As described above, your activities are directed at benefiting student athletes. As described in B.S.W. Group Inc
v. Commissioner, 70 T.C. 352(1978), the purpose towards which an organization’s activities are directed, and
not the nature of the activities themselves, is ultimately dispositive of the organization’s right to be classified as
a section 501(c)(3) organization.

As in Christian Manner International, Inc. v. Commissioner you also further a non-exempt purpose that is not
incidental to an exempt purpose. Your payments to student-athletes in exchange for the use of their NIL does
not further an exempt purpose.

As in Est of Hawaii v. Commissioner of Internal Revenue, the critical inquiry is not whether the payments to
the student athletes are reasonable, but whether the student athletes benefited substantially from the
organization’s operations. You have stated that it is your purpose to develop financial opportunities for
members of the university’s sports teams, and that you intend to distribute at least w percent of your gross
receipts (and up to x percent) to these student athletes. Your entire enterprise, therefore, is carried on in such a
manner that the student athletes benefit substantially from your operations. This indicates that your activities
impermissibly serve private rather than public interests, and that you are not operated exclusively for exempt
purposes.

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

Your position
You stated that the students you were compensating were of a charitable class because, statistically, most

college students are considered to be poor and/or distressed.

You stated that you do not pay student athletes for providing services for charities. You engage the student
athletes to conduct activities which promote the mission of selected charities by utilizing the student athlete’s
NIL. These activities include social media posts and personal appearances on behalf of the charity. You state
such activities are not services to the charities by you or the student athlete but are actions on behalf of the
charity designed to expand the charity’s visibility in the community.

You indicated that you are similar to the organization described in Goldsboro Art League, Inc. v. Commissioner
of Internal Revenue, and therefore, the private benefit to the student athletes is incidental to your primary
charitable purpose.

You stated that various “peer institutions”, similar to your organization, have been recognized as tax exempt
under Section 501(c)(3) and therefore you should be granted such exempt status.

Our response to your position

You have not demonstrated that these student athletes belong to a charitable class. You have not indicated that
you will offer paid opportunities to student athletes based on a demonstrated need; rather, you plan on
compensating all the student athletes regardless of their financial need. Based on the facts presented in your
application, you serve a private, rather than a public interest, because you confer benefits primarily on student
athletes of a particular university’s sports teams for the use of their NIL.

No contract exists between the student athlete and the charity. However, you do have an independent contractor
agreement with each athlete and obtain a “Letter of Understanding” between you and the charity regarding
services you will provide to the charity using your independent contractor, the student athlete. This “Letter of
Understanding” is an agreement that indicates the services you will perform, using your independent contractor,
on behalf of the charity.

You are not like the organization in Goldsboro Art League v. Commissioner (1980). Unlike the organization in
Goldsboro Art League, you intend to spend between w and x percent of your gross receipts to compensate E
student athletes. You have not established that the private benefit from your activities is clearly secondary and
incidental to exempt purposes. Rather, the information you provided indicates that providing paid opportunities
for E student athletes is one of your primary purposes.

Even if the student athletes engaged in your activities are independent contractors and are not private
shareholders or organizational insiders, that fact is not determinative of whether you serve private interests. As
recognized by the Tax Court in American Campaign Academy, the conferral of benefits on disinterested
persons (i.e. unrelated third-parties) may cause an organization to serve private interests.

Since you distribute the majority of funds received to student athletes, and not for a charitable purpose, you
have a substantial non-exempt purpose. Therefore, you fail the operational test for IRC section 501(c)(3).

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

8

Regarding the tax-exempt status of other organizations, each application for exemption is evaluated based on its
own specific facts and circumstances. Furthermore, as indicated in City of Galveston, Texas v. United States, 33
Fed. Cl. 685, 707—08 (1995), “[a] taxpayer cannot premise its right to an exemption by showing that others have
been treated more generously, leniently or even erroneously by the IRS.”

Conclusion

Based on the above facts and analysis, you do not qualify for exemption under IRC Section 501(c)(3) because
you are operated for substantial non-exempt purposes and fail the operational test. Specifically, you are
operated for the private benefit of student athletes attending E. Accordingly, you do not qualify for exemption
under Section 501(c)(3).

If you agree

If you agree with our proposed adverse determination, you don’t need to do anything. If we don’t hear from
you within 30 days, we’ll issue a final adverse determination letter. That letter will provide information on
your income tax filing requirements.

If you don't agree
You have a right to protest if you don’t agree with our proposed adverse determination. To do so, send us a
protest within 30 days of the date of this letter. You must include:

* Your name, address, employer identification number (EIN), and a daytime phone number
- A statement of the facts, law, and arguments supporting your position
* A statement indicating whether you are requesting an Appeals Office conference

* The signature of an officer, director, trustee, or other official who is authorized to sign for the
organization or your authorized representative

+ The following declaration:

For an officer, director, trustee, or other official who is authorized to sign for the organization:
Under penalties of perjury, I declare that I have examined this request, or this modification to the
request, including accompanying documents, and to the best of my knowledge and belief; the request
or the modification contains all relevant facts relating to the request, and such facts are true, correct,
and complete.

Your representative (attorney, certified public accountant, or other individual enrolled to practice before the
IRS) must file a Form 2848, Power of Attorney and Declaration of Representative, with us if they haven’t
already done so. You can find more information about representation in Publication 947, Practice Before the
IRS and Power of Attorney.

We’ll review your protest statement and decide if you gave us a basis to reconsider our determination. If so,
we’ll continue to process your case considering the information you provided. If you haven’t given us a basis
for reconsideration, we’ll send your case to the Appeals Office and notify you. You can find more information
in Publication 892, How to Appeal an IRS Determination on Tax-Exempt Status.

If you don’t file a protest within 30 days, you can’t seek a declaratory judgment in court later because the
law requires that you use the IRC administrative process first (IRC Section 7428(b)(2)).

Where to send your protest

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K

9

Send your protest, Form 2848, if applicable, and any supporting documents to the applicable address:

U.S. mail: Street address for delivery service:
Internal Revenue Service Internal Revenue Service

EO Determinations Quality Assurance EO Determinations Quality Assurance
Mail Stop 6403 550 Main Street, Mail Stop 6403

PO Box 2508 Cincinnati, OH 45202

Cincinnati, OH 45201

You can also fax your protest and supporting documents to the fax number listed at the top of this letter. If you
fax your statement, please contact the person listed at the top of this letter to confirm that they received it.

You can get 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). If you have questions, you can contact the person listed at
the top of this letter.

Contacting the Taxpayer Advocate Service

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 if 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.

Sincerely,
Stephen A. Martin

Director, Exempt Organizations
Rulings and Agreements

Letter 4034 (Rev. 01-2021)
Catalog Number 47628K