Organization received a final denial after it did not protest the proposed adverse determination

Plain-English summary

The IRS issued a final determination that an organization did not qualify for exemption under IRC § 501(c)(3). The final letter says the IRS had sent a proposed adverse determination explaining the facts, law, and basis for denial, but the organization did not protest within 30 days. The public PDF also includes a proposal letter referring to an enclosed Form 886-A audit report, but that report and its underlying facts do not appear in this release. The available text therefore does not disclose the factual reason for the adverse determination. The IRS directed the organization to file Form 1120 for all tax years and stated that donors generally could not deduct contributions under IRC § 170.

Ruling snapshot

• Question: Did the organization qualify for exemption under IRC § 501(c)(3)?
• Outcome: Denied
• Key authorities: IRC §§ 170, 501(a), 501(c)(3), 6104(c), 6110

Full text (IRS public release)

     Department of the Treasury                                           Date:
     Internal Revenue Service                                              01/14/2025
     Tax Exempt and Government Entities                                   Employer ID number:

IRS Box 2508
Cincinnati, OH 45201 Form you must file:
1120
Tax years:
Release Number: 202515015
All
Release Date: 4/11/2025 Person to contact:
UIL Code: 501.03-00,
501.03-30. 501.33-00

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.
Sincerely,

                                                     Stephen A. Martin
                                                     Director, Exempt Organizations
                                                     Rulings and Agreements

Enclosures:
Letter 437
Redacted Letter 4034
Letter 4038 (Rev. 11-2021)
Catalog Number 47632S
Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities
Exempt Organizations Examinations

[redacted]

[redacted]

Date:
January 31, 2024

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:
March 1, 2024

CERTIFIED MAIL - Return Receipt Requested

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.

                                                    Sincerely,

                                                    [signature], for

                                                    Lynn A. Brinkley
                                                    Director, Exempt Organizations
                                                    Examinations

Enclosures:
Form 886-A
Form 6018
Form 4621-A
Publication 892
Publication 3498

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