IRS revoked an inactive charity's tax exemption

Plain-English summary

The IRS revoked an organization's Section 501(c)(3) exemption because it could not show that it still conducted charitable activities. The organization had originally supported the implementation of a government job-training program, but that program was later repealed. During the examination, the organization claimed that it worked jointly with a related organization, yet it provided no records describing its own activities or showing how it participated in the related organization's work. Its only income came from interest on a money market account, and it had no operating account, donations, grants, program-service revenue, or documented exempt operations. The IRS concluded that the organization failed the operational test under Section 501(c)(3) and no longer qualified as a publicly supported charity under Section 509(a)(2).

Ruling snapshot

• Question: Did an organization with no substantiated independent activities continue to qualify for Section 501(c)(3) exemption?
• Outcome: revocation
• Key authorities: IRC §§ 501(a), 501(c)(3), 509(a)(2); Treas. Reg. §§ 1.501(c)(3)-1(a)(1), 1.501(c)(3)-1(c)(1), 1.501(c)(3)-1(d)(1)(i); Rev. Rul. 58-617

Full text (IRS public release)

Department of the Treasury                         Date:
Internal Revenue Service                          01/31/2024
Tax Exempt and Government Entities                Taxpayer ID number (last 4 digits):
                                                   [redacted]
                                                   Form:
                                                   [redacted]

Release Number: 202419021                         Tax periods ended:
Release Date: 5/10/2024                           [redacted]
UIL Code: 501.03-00                               Person to contact:
                                                   Name:
                                                   [redacted]
                                                   ID number:
                                                   [redacted]
                                                   Telephone:
                                                   [redacted]
                                                   Fax:
                                                   [redacted]
                                                   Last day to file petition with United States
                                                   Tax Court:
                                                   [redacted]

CERTIFIED MAIL - Return Receipt Requested

Dear [redacted]:

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
January 1, 20[redacted]. Your determination letter dated July 25, 19[redacted], is revoked.

Our adverse determination as to your exempt status was made for the following reasons: Organization fails the
operational test because you could not demonstrate that you operated for one or more exempt purposes as
required by IRC Section 501(c)(3).

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.

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

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

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
Taxpayer Advocate Office
[redacted]

Telephone:
[redacted]
Fax:
[redacted]

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.

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.

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

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

Department of the Treasury                         Date:
Internal Revenue Service                          08/10/2023
Tax Exempt and Government Entities                Taxpayer ID number:
                                                   [redacted]
                                                   Form:
                                                   [redacted]
                                                   Tax periods ended:
                                                   [redacted]
                                                   Person to contact:
                                                   Name:
                                                   [redacted]
                                                   ID number:
                                                   [redacted]
                                                   Telephone:
                                                   [redacted]
                                                   Fax:
                                                   [redacted]
                                                   Address:
                                                   [redacted]
                                                   Manager's contact information:
                                                   Name:
                                                   [redacted]
                                                   ID number:
                                                   [redacted]
                                                   Telephone:
                                                   [redacted]
                                                   Response due date:
                                                   09/11/2023

CERTIFIED MAIL - Return Receipt Requested

Dear [redacted]:

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.

   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.

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

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).

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

                                                   Sincerely,

                                                   Denise Gonzalez, for
                                                   Lynn A. Brinkley
                                                   Director, Exempt Organizations
                                                   Examinations

Enclosures:
Form 886-A
Form 6018
Publication 892
Publication 3498

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/Period ended
[redacted]           [redacted]                                    [redacted]

ISSUE:

Whether [redacted] continues to qualify for exemption under
Internal Revenue Code (IRC) Section 501(a) as an organization described in IRC Section
501(c)(3) due to lack of operations or activities for a significant period, including the year under
examination.

FACTS:

[redacted] (hereinafter, [redacted]) was incorporated as a nonprofit corporation
on [redacted] pursuant to the [redacted], Title [redacted],
Sections [redacted]. The name of the corporation that appeared on the initial Certificate of Incorporation
was [redacted] (hereinafter, [redacted]). A Certificate of Amendment was
filed on [redacted] to change name to [redacted].

According to the Certificate of Incorporation, [redacted] (known then as [redacted]) was formed for the
following purposes:

A. establish and maintain [redacted] / [redacted] for the exchange of [redacted] and
   [redacted] among all of the [redacted] by the "[redacted]"
   and related [redacted] and [redacted], for the purpose of [redacted] and
   [redacted], [redacted] and [redacted];

B. reduce the [redacted] and [redacted] services currently being provided by
   [redacted] and interest groups;

C. allow for a governance structure for [redacted] efforts which reflects that
   interests of [redacted], [redacted] and [redacted];

D. provide [redacted] to [redacted] and [redacted] in the implementation of the "[redacted]",
   including:

    1. development and maintenance of a [redacted] of information on the
      implementation of the [redacted];
    2. development and maintenance of a [redacted] to assist
      [redacted] and [redacted] in their resolution of [redacted], [redacted] and [redacted]
      problems;
    3. provision of [redacted] in the interpretation and implementation of the "Job
      Training Partnership Act" and regulations promulgated thereunder;
    4. [redacted] in planning and conducting [redacted] on [redacted] and
      [redacted]; and
    5. analyses of [redacted] actions relative to the [redacted].

Catalog Number 20810W                  Page 1                  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/Period ended
[redacted]           [redacted]                                    [redacted]

[redacted] was recognized as a section 501(c)(3) organization pursuant to a ruling dated
[redacted] and was treated as a publicly supported organization described in section 509(a)(2) during the
advance ruling period. [redacted] later received another determination letter dated [redacted] after the
advance ruling period had ended. In this latest determination letter, [redacted] was given the foundation
status under section 509(a)(2).

According to the Tax Exempt Organization Search website (https://apps.irs.gov/app/eos/),
[redacted] filed Forms [redacted] in tax years [redacted] through [redacted], which includes the year under examination.
Form [redacted] ([redacted]) is an [redacted] filed by eligible small tax-exempt
organizations to satisfy their annual reporting requirements if their annual gross receipts are
normally $[redacted] or [redacted].

Determination Administrative File
[redacted] determination administrative file, which includes the exemption application Form 1023 and
supporting documents under former name [redacted], indicates that [redacted] was set up as a
[redacted] organization that consisted of [redacted] and [redacted] charged with implementation of the
[redacted]. Its activities described in the exemption application were to provide
[redacted] and [redacted] to the active [redacted] involved in
implementing the [redacted]. Such information exchange consists of notices
and documentations of the [redacted] and [redacted] programs being implemented at the [redacted] and
[redacted] levels under the [redacted].

According to the exemption application, "primary source of funds shall be [redacted] and
[redacted] assessed against [redacted] and [redacted] under the
[redacted]; [redacted]; secondary source of support will be
contributions from other [redacted] organizations; final source of support will be [redacted]
interested in [redacted] and [redacted] and [redacted] programs".

The [redacted]
The [redacted] was a [redacted] enacted by [redacted] on [redacted], to
establish [redacted] to prepare [redacted] for entry into the [redacted]
and to [redacted] to those [redacted] individuals and other
individuals facing serious barriers to [redacted], who are in [redacted] of such [redacted] to
obtain [redacted]. ([redacted])

The [redacted] of [redacted] was repealed by the [redacted].
([redacted])

Related Organization - [redacted]
Correspondence dated [redacted] from [redacted] (under former name [redacted]) stated that [redacted] had
begun operating under the trade name "[redacted]"
(hereinafter, "[redacted]"). The IRS then received an application for exemption, Form 1024, from

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/Period ended
[redacted]           [redacted]                                    [redacted]

[redacted] on [redacted]. [redacted] applied for tax-exempt status under section 501(c)([redacted]) as an unincorporated
association. Per its determination letter dated [redacted], [redacted] was recognized as a section
501(c)([redacted]) organization.

On [redacted], [redacted] formally incorporated, pursuant to the [redacted]
edition, Title [redacted], Chapter [redacted], for the following purposes:

A. improve the effectiveness of the [redacted] and [redacted];
B. enhance [redacted];
C. [redacted] among [redacted] and [redacted].

[redacted] filed a Certificate of Amendment on [redacted], changing its name to [redacted]
of [redacted]. (hereinafter, "[redacted]").

[redacted] has been filing Forms [redacted] since its inception. [redacted] now files Forms [redacted] and Forms [redacted] on
behalf of [redacted] as, according to [redacted], [redacted] and [redacted] share employees.

Operational
[redacted]'s Form [redacted] and [redacted] of Form [redacted] for the tax year ended [redacted] were under
examination. Based on interviews and responses provided in reply to information document
requests, [redacted] claims it shares board members, officers, employees, and office space with
[redacted]. The organizations do not enter into any agreements regarding the sharing of such
organizational resources. [redacted] is a [redacted] organization. [redacted] was initially set up as a
[redacted] organization as well; however, [redacted] does not have any [redacted] separate and apart
from [redacted] members.

The board meeting minutes provided by [redacted] were under the letterhead of [redacted], and the
matters discussed during the meeting pertained to [redacted] relating to
[redacted] conferences and [redacted]. [redacted] responded that there were no minutes solely for [redacted].

When asked to substantiate its [redacted], [redacted] responded with the
following sentence alone: "All activities conducted on behalf of the [redacted] and [redacted] are done in
[redacted]."

[redacted] failed to provide documents and/or information to substantiate that [redacted] was or is conducting
its own activities during the year under examination through the present. In fact, [redacted] failed to
provide any specific details or descriptions of activities it has conducted in furtherance of an
exempt purpose.

Financial
[redacted] maintained one money market account; it had no operating account, other assets or
liabilities; [redacted] did not receive any donations or grants; it had no [redacted] income or program

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/Period ended
[redacted]           [redacted]                                    [redacted]

service revenue; the only source of income was the [redacted] from that money market
account. When asked to provide the gross receipts for each tax year ended [redacted]
and the [redacted]-year gross receipt average for the purpose of determining
whether [redacted] was eligible to file the Form [redacted], the financial records showed that the
[redacted] income ranged from $[redacted] to $[redacted] for those [redacted] years. Besides the [redacted],
[redacted] had no deposit or disbursement transactions according to the [redacted] account's bank
statements. All [redacted] for those [redacted] that [redacted] filed [redacted] for were paid
directly by [redacted].

[redacted] applied [for] the [redacted] ([redacted]) loan and was approved $[redacted], during the
year under examination; all of the approved funds were subsequently transferred to the primary
checking account of [redacted].

Per inspection of [redacted] Form [redacted], [redacted] identified [redacted] as its related organization on the
Schedule [redacted]. The Schedule [redacted] indicated that [redacted] did not engage in any financial transactions
with the related organization [redacted], i.e., no gift, grant, or capital contribution to/from related
organization, no loans to to/from related organization, no reimbursement paid to/by related
organization, no sharing of facilities, paid employees with related organization.

LAWS:

Internal Revenue Code (IRC) Section 501(c)(3) provides exemption from Federal income tax on
corporations, and any community chest, fund, or foundation, organized and operated exclusively
for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or to
foster national or international amateur sports competition, or for the prevention of cruelty to
children or animals, no part of the net earnings of which inures to the benefit of any private
shareholder or individual, no substantial part of the activities of which is carrying on propaganda,
or otherwise attempting to influence legislation and which does not participate in, or intervene in
(including the publishing or distributing of statements), any political campaign on behalf of any
candidate for public office.

IRC Section 509(a)(2) describes an organization that receives no more than one-third of its
support from gross investment income and more than one-third of its support in each tax year from
a combination of the following:

i) gifts, grants, contributions, or membership fees from other than a disqualified person, and

ii) gross receipts from admissions, sales of merchandise, performance of services or furnishing
of facilities in an activity that is not an unrelated trade or business (to the extent that gross
receipts from any one individual does not exceed the greater of $5,000 or 1 percent of the
organization's total support on that tax year.

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/Period ended
[redacted]           [redacted]                                    [redacted]

Treasury Regulation 1.501(c)(3)-1(a)(1) provides 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 Regulation 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 exempt purposes specified in section 501(c)(3). An organization
will not be so regarded if more than in insubstantial part of its activities is not in furtherance of an
exempt purpose.

Treasury Regulation 1.501(c)(3)-1(d)(1)(i) states that an organization may be exempt as an
organization described in 501(c)(3) if it is organized and operated exclusively for one or more of
the following purposes: religious, charitable, scientific, testing for public safety, literary,
educational, or prevention of cruelty to children or animals.

Revenue Ruling 58-617, 1958-2 C.B. 260 states that, rulings and determinations letters granting
exemption from Federal income tax to an organization described in section 501(a) of the Internal
Revenue Code of 1954, to which contributions are deductible by donors in computing their taxable
income in the manner and to the extent provided by section 170 of the Code, are effective only so
long as there are no material changes in the character of the organization, the purposes for which
it was organized, or its methods of operation. Failure to comply with this requirement may result in
serious consequences to the organization for the reason that the ruling or determination letter
holding the organization exempt may be revoked retroactively to the date of the changes affecting
its exempt status, depending upon the circumstances involved, and subject to the limitations on
retroactivity of revocation found in section 503 of the Code.

In Community Education Foundation v. Commissioner T.C. Memo. 2016-223, revocation of
the petitioner's exemption was supported due to a long-extended period of inactivity. The
petitioner did not meet the operational test requirements for a section 501(c)(3) organization.

TAXPAYER'S POSITION:

When asked for a detailed description of activities conducted by [redacted] during the year under
examination and present, [redacted] stated that:

"[redacted] ([redacted]) serves an [redacted] mission to [redacted], [redacted], and
[redacted] the [redacted] field. The [redacted]
([redacted]) was formed for a complementary purpose: to offer
a [redacted] for [redacted], [redacted] and [redacted]. The

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/Period ended
[redacted]           [redacted]                                    [redacted]

organizations work closely together to [redacted] practices and [redacted]."

When asked to provide documents to support the types of activities specifically conducted by [redacted],
[redacted] stated that "all activities conducted on behalf of the [redacted] and [redacted] are done in [redacted]"
but materials such as newsletters and blogs are "published under the entity name [redacted]."

When asked to explain [redacted]'s relationship with [redacted], [redacted] stated that:

"[redacted] ([redacted]) serves an [redacted] to [redacted], [redacted], and
support the [redacted]. The [redacted]
([redacted]) was formed for a complementary purpose: to offer
a [redacted] for [redacted], [redacted] and [redacted]. The
organizations work closely together to [redacted] and [redacted]."

GOVERNMENT'S POSITION:

This report addresses the issue whether [redacted] continues to qualify for exemption as an
organization described under IRC 501(c)([redacted]) due to lack of operations or inactivity for a significant
period of time, including the year under examination. Any issues associated with the filing of
[redacted] (i.e., Form [redacted]) by [redacted] are not addressed in this report.

Information presented during the examination indicates that [redacted] has ceased to conduct the types
of activities described in its exemption application. [redacted] is no longer serving as an
[redacted] for parties involved in the implementation of the [redacted] of
[redacted] as the [redacted] was repealed in [redacted]. Moreover, although [redacted] claims it conducts activities jointly
with its related organization, [redacted], [redacted] has not provided any documentation to substantiate its
own activities, nor how it participates jointly in activities with [redacted].

[redacted] has failed to provide evidence to substantiate it has its own operations to accomplish one or
more exempt purposes specified in section 501(c)([redacted]). [redacted] does not have outside contributions or
grants; it does not have any [redacted] income or income from exempt operations. As such,
[redacted] has failed the operational requirements under section 501(c)([redacted]) and failed the public support
test under section 509(a)([redacted]).

As demonstrated in Rev. Rul. [redacted], an organization's exempt status will remain in effect only so
long as there are no material changes in the character of the organization, the purposes for which
it was organized, or its methods of operation. Information suggests that [redacted] has been inactive for
a long-extended period, including the year under examination, as (1) [redacted] clearly no longer serves

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/Period ended
[redacted]           [redacted]                                    [redacted]

the same purposes stated in its exemption application because the [redacted]
was repealed in [redacted]; (2) it has been filing the Form [redacted] at least since [redacted] to present;
(3) no income or expenses transactions except for [redacted] at least since [redacted] to present;
(4) no other assets or liabilities except for [redacted]; and (5) no
records to substantiate [redacted] has been actively engaged in its own exempt functions. The sole
function of [redacted] seems to be to file Forms [redacted] and [redacted] on behalf of [redacted], with whom
[redacted] claims to have [redacted]. In fact, [redacted] was not able to establish how many [redacted] the
allegedly "[redacted]" for [redacted] versus [redacted].

[redacted] is like the petitioner in the [redacted] v. [redacted] case where the
court concluded that revocation was appropriate due to a significant period of inactivity.

Accordingly, [redacted]'s tax-exempt status should be revoked because it fails to demonstrate it
continues to meet the operational requirements under section 501(c)([redacted]).

CONCLUSION:

[redacted] fails to meet the operational requirements for continued exemption under section 501(c)([redacted]) of
the Code due to lack of operations or activities that accomplish one or more of the exempt
purposes described in section 501(c)([redacted]). Moreover, [redacted] fails to satisfy section 509(a)([redacted])
foundation status or any public charity status because it has no public donations, grants,
membership fees, or any exempt function income. Therefore, [redacted] exempt status under section
501(c)([redacted]) should be revoked effective [redacted]. Form 1120, U.S. Corporation Income Tax,
should be filed for tax year ended [redacted], and thereafter.

If you agree to this conclusion, please sign and return the enclosed Form 6018.

If you disagree, please submit a written statement of your position.

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