501(c)(3) revoked, a dog-rescue charity whose operators were charged with animal cruelty and that stopped responding to the IRS

Plain-English summary

The IRS revoked the 501(c)(3) tax-exempt status of an animal-welfare organization that had been recognized as a dog rescue. During an examination, the revenue agent could not reach the organization: it did not answer letters or phone calls, had no valid address on file, and never provided any organizational or financial records. Web research showed the organization's operators had been charged with multiple counts of felony animal cruelty after dogs were found abandoned without food, water, or care, some so ill they had to be euthanized. The IRS concluded the organization does not prevent cruelty to animals (the opposite of its claimed exempt purpose), that its articles of incorporation lacked the required purpose and dissolution clauses, and that it failed its recordkeeping duties under Sections 6001 and 6033. Because it no longer qualifies under Section 501(c)(3), contributions to it are not deductible under Section 170, and it must file corporate income tax returns.

Ruling snapshot

• Question: Should the organization's 501(c)(3) exemption be revoked?
• Outcome: revocation
• Key authorities: IRC §§ 501(c)(3), 170, 6001, 6033; Treas. Reg. §§ 1.501(c)(3)-1(a)(1), (b)(1)(i), 1.6001-1, 1.6033-1(h)(2); Rev. Rul. 66-359, 1966-2 C.B. 219; Rev. Rul. 74-194, 1974-1 C.B. 130

Full text (IRS public release)

Department of the Treasury
Internal Revenue Service
IRS Tax Exempt and Government Entities

Date:
August 12, 2025

Taxpayer ID number (last 4 digits):

Form:

Tax periods ended:

Release Number: 202552031
Release Date: 12/26/2025
UIL Code: 501.03-00

Person to Contact:
Name:
ID number:
Telephone:
Fax:

Last day to file petition with United States Tax Court:
November 10, 2025

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 organized and operated exclusively for one or more exempt purposes and that no part
of your net earnings inures to the benefit of any private shareholder or individual. Your articles of organization
do not limit your purposes to one or more exempt purposes. Your articles of organization also expressly
empower you to engage in substantial activities which in themselves are not in furtherance of one or more
exempt purposes. The purposes for which you were created are broader than the purposes specified in section
501(c)(3). Your assets are also not dedicated to an exempt purpose. You have not demonstrated that, upon
dissolution, your assets will be distributed for one or more exempt purposes, or to the Federal Government, or
to a State or local government, for a public purpose, or that your assets would be distributed by a court to
another organization to be used in such manner as in the judgment of the court will best accomplish exempt
purposes. You have also not demonstrated that you are operated exclusively for exempt purposes and that no
part of your net earnings inures to the benefit of any private shareholder or individual. You also did not respond
to our repeated requests for information about your finances and activities.

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:

Letter 6337 (Rev. 3-2024)
Catalog Number 74808E

• 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

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).

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 if 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. Visit TaxpayerAdvocate.IRS.gov/contact-us or call 877-777-4778 (TTY/TDD 800-829-4059)
to find the location and phone number of your local advocate. Learn more about TAS and your rights under the
Taxpayer Bill of Rights at TaxpayerAdvocate.IRS.gov. Do not send your Tax Court petition to TAS. Use the
Tax Court address provided earlier in the letter. Contacting TAS does not extend the time to file a petition.

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. 3-2024)
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.

Director, Exempt Organizations Examinations

Enclosures:
Publication 1
Publication 594
Publication 892

Letter 6337 (Rev. 3-2024)
Catalog Number 74808E

Tax Exempt and Government Entities

Department of the Treasury
Internal Revenue Service
IRS

Date:
November 01, 2024

Taxpayer ID number:

Form:

Tax periods ended:

Person to contact:
Name:
ID number:
Telephone: [illegible]

Address: [illegible]

Manager's contact Information:
Name:
ID number: [illegible]
Telephone: [illegible]

CERTIFIED MAIL — Return Receipt Requested

Response due date:
December 2, 2024

Dear [illegible]:

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.

Fast Track Mediation (FTM) referred to in Publication 3498, The Examination Process, generally doesn't
apply now that we've issued this letter.

Letter 3616 (Rev. 3-2024)
Catalog Number 34809F

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.

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.

Enclosures:
Form 886-A
Form 6018

Letter 3618 (Rev. 3-2024)
Catalog Number 34809F

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

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

Issue:
Whether         meets the qualifications for exemption under section 501(c)(3) of the
Internal Revenue Code?

Facts:
(         ) is currently exempt under IRC Section 501(c)(3) as an Animal Protection
& Welfare organization.         was created to rescue and rehabilitate dogs.         was Incorporated
in         as a Non-Profit Corporation. The Revenue Agent conducted research on the
Secretary of State Website to obtain         's Articles of Incorporation. Articles were filed on         and
became effective on         . Per the Articles,         's initial planned non-profit activity is "
        " Per the Articles (         ) Code/Nature of Business
is as follows:

After a review of the Articles, the Revenue Agent determined they lack a purpose and dissolution clause.

The original Form 1023-EZ Streamlined Application for Recognition of Exemption Under Section 501(c)(3)
was obtained internally from Rulings and Agreements. After a review of the initial application for exemption,
the Revenue Agent noted that         claimed it doesn't and won't have annual gross receipts over $50,000 in
any of the past or next 3 years.         also claimed that it does not have total assets in which the fair market
value (FMV) exceeds $250,000.

The address provided on the 1023-EZ application is:

The officers listed on the 1023-EZ application are:

        , Director and Owner &         , Finance Officer
        , Welfare Advisor
The date of incorporation provided on the 1023-EZ application is         , and the state of incorporation
or other formation is listed as         . Revenue Agent noted that         is actually incorporated in
        and there is no corporate record for them in         . Additionally, the Revenue Agent noted that         filed
articles of incorporation months after their initial application for exemption was filed and processed.

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 or exhibit
(May 2017)         Explanations of Items

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

        checked boxes on the 1023-EZ application attesting to their organizing document meeting the organizational
test. No organizing document was submitted with the initial application for exemption.
        provided the following purpose on the application:

        attested that it is organized and operated exclusively to further charitable and prevention of cruelty to
animals purposes.         also attested that it has not and will not conduct activities that violate prohibitions
and restrictions to qualify for exemption as a Section 501(c)(3) organization. The foundation classification
requested is Section 509(a)(2). This classification is available to organizations that receive more than one-
third of their support from contributions, membership fees and gross receipts from activities related to their
exempt purposes.

The 1023-EZ application was electronically signed by         , Director and Owner on
        . A favorable determination letter was issued on         , and         was granted 501(c)(3)
status under section 509(a)(2) with an effective date of

        is required to file Form 990 series returns.         filed one Form 990-N, Electronic Notice (e-Postcard)
return for tax year         (filed on         ) and has not filed any other returns or notices.
The year under examination is         . The initial contact letter and information document request (IDR) were
mailed to         , address on         . The         address
is the current address the government has on file for         . A review of this address revealed a
failed to respond to this request. Revenue
Agent conducted research on the Secretary of State website to locate a correct mailing address for
        , but the state website says, "No principal office address found".

The Revenue Agent used internal sources to locate potential mailing addresses. The initial contact
letter and an IDR were sent via certified mail on         , to different addresses. The letters
were mailed to the         address again and to an address located in         . The status of
letters is undeliverable. If letters are not retrieved from the         , they will be returned to the
Internal Revenue Service (IRS).

Revenue Agent attempted contacting         for the initial contact phone call on         , dialing
the number provided on the 1023-EZ application. No one answered and a voicemail message was left for
        . The Revenue Agent never received a call back from that number. Since no other
phone number for         was on file, the Revenue Agent used external and internal sources to locate potential
phone numbers for officers.

        potential phone numbers were identified through internal sources. The potential phone number was
called, and someone answered, but the call dropped. The phone number was dialed again, and the same thing
happened. The potential phone number was dialed and is disconnected. The potential phone

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 or exhibit
(May 2017)         Explanations of Items

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

numbers were called on the following day and nothing changed.         and/or
have not responded to calls nor the letters.

Lastly, the Revenue Agent mailed Form 4759 — Address Information Request to the         located in
        . The form was returned, and the         selected "Moved, left no forwarding address".

Ultimately, several attempts by the Revenue Agent to contact         were unsuccessful.

The Revenue Agent conducted web research and located a         of "         "
by the         , in their mission to rescue         at
properties located in         .         law enforcement was contacted regarding
abandoned without care. After the         enforcement
contacted the         to deploy state licensed veterinarians, volunteers, and a skilled rescue
team consisting of organizations that specialize in rescue and cruelty documentation.

The Revenue agent also located an article written by the         at         ,
that includes         and         after allegedly being arrested and charged with
multiple counts of animal cruelty

In addition, the Revenue Agent found         name on         .         to the
        .         was arrested by the
at         , on         , for charges of animal cruelty, and aggravated cruelty of
a dog or cat with a $         bond.

Law:

Internal Revenue Code Section 501(c)(3) exempts from Federal income tax: 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
(but only if no part of its activities involve the provision of athletic facilities or equipment), 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

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 or exhibit
(May 2017)         Explanations of Items

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

otherwise attempting to influence legislation (except as otherwise provided in subsection (h)), and which does
not participate in, or intervene in (including the publishing or distributing of statements), any political
campaign on behalf of (or in opposition to) any candidate for public office.

Treasury Regulations Section 1.501(c)(3)-1(a)(1) states that in order to qualify under section 501(c)(3) of the
Code, an organization must be both organized and operated exclusively for one or more exempt purposes. If
an organization fails to meet either the organizational or operational test, it is not exempt.

Treas. Reg. Section 1.501(c)(3)-1(b)(1)(i) provides that an organization is organized exclusively for one or
more exempt purposes only if its articles of organization limit the purposes of such organization to one or
more exempt purposes and do not expressly empower the organization to engage, otherwise than as an
insubstantial part of its activities, in activities that in themselves are not in furtherance of one or more exempt
purposes.

Internal Revenue Code Section 6001 provides that every person liable for any tax imposed by the IRC, or for
the collection thereof, shall keep adequate records as the Secretary of the Treasury or his delegate may from
time to time prescribe.

Treas. Reg. § 1.6001-1(c) states that in addition to such permanent books and records as are required by
paragraph (a) of this section with respect to the tax imposed by section 511 on unrelated business income of
certain exempt organizations, 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. See section 6033 and §§ 1.6033-1
through -3.

Treas. Reg. § 1.6001-1(e) states that the books or records required by this section shall be kept at all times
available for inspection by authorized Internal Revenue Service officers or employees and shall be retained
as long as the contents thereof may be material in the administration of any Internal Revenue law.

Treas. Reg. § 1.6033-1(h)(2) states every organization which has established its right to exemption from tax,
whether or not it is required to file an annual return of information, shall submit such additional information
as may be required by the district director for the purpose of enabling him to inquire further into its exempt
status and to administer the provisions of subchapter F (section 501 and following), chapter 1 of the Code,
and of section 6033. See section 6001 and § 1.6001-1 with respect to the authority of the district director or
directors of service centers to require such additional information and with respect to the permanent books of
account or records to be kept by such organizations.

Rev. Rul. 66-359, 1966-2 C.B. 219, provides exemption to an organization that was organized and operated
to promote humane treatment of laboratory animals.

Rev. Rul. 74-194, 1974-1 C.B. 130, describes an organization formed to prevent cruelty to unwanted animals
by preventing the overbreeding of cats and dogs. The organization advocated the spaying or neutering of the

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 or exhibit
(May 2017)         Explanations of Items

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

mixed-breed dog and cat, and raised funds to aid pet-owners who desired to spay or neuter their pets but who
could not afford the rates charged by veterinarians to perform the operations. There is no relationship between
any member of the organization and the veterinarians who performed the operations. The organization was
found to be engaged in the prevention of cruelty to animals and accordingly, qualified for exemption from
federal income tax under section 501(c)(3) of the Code.

Government's Position:

Treasury Regulations Section 1.501(c)(3)-1(a)(1) states that in order to qualify under section 501(c)(3) of the
Code, an organization must be both organized and operated exclusively for one or more exempt purposes. If
an organization fails to meet either the organizational or operational test, it is not exempt.

        Articles of Incorporation lack a purpose clause and a dissolution clause. Without
adequate purpose and dissolution clauses,         does not pass the organizational test and is not organized
exclusively for one or more exempt purposes under section 501(c)(3) of the Code.

IRC 501(c)(3) provides exemption for organizations that prevent cruelty to animals. If such an organization
does not prevent and/or causes cruelty to animals, it should not be exempt. The operators/owners of
were charged with multiple counts of felony animal cruelty after abandoning dogs at different properties
in the heat without food, water, or care. Dogs were either running loose, tethered to trees, decomposed, or
housed in small hot cages. Some of the dogs' medical conditions were so far advanced that they had to be
euthanized onsite. Surviving dogs were suffering from bite wounds, worms, parasites, and dental damage.

Therefore,         is not an exempt organization described in Rev. Rul. 66-359 because         is not organized
and operated to promote humane treatment of animals. Additionally,         is not like the exempt organization
described in Rev. Rul. 74-194 which prevented the suffering of unwanted animals.         does not prevent
cruelty to animals and does not operate for 501(c)(3) purposes.

Finally,         has failed to provide records as is required in Code § 6033(a)(1) and Regulation § 1.6033-
1(h)(2).         failed to provide any organizational or financial information that the government requested
during the examination. The government attempted to obtain these records numerous times by mail and phone.
Without the records, the government cannot verify that         is operating according to their exempt purpose.
Government's position is that         , then, is not operating for exempt purposes and has not provided
anything to the contrary.

Taxpayer's Position:
The taxpayer did not respond to phone calls and requests for supporting documentation. Currently, the
taxpayer's position is unknown.

Conclusion:
IRC 501(c)(3) provides exemption for organizations that prevent cruelty to animals. The operators/owners of
        were charged with multiple counts of felony animal cruelty

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 or exhibit
(May 2017)         Explanations of Items

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

        . Therefore,         does not prevent cruelty to animals and does not operate for 501(c)(3)
purposes.

        has also failed to provide required documentation, thereby failing to comply with the Code, and failing
to show any evidence of their exempt activities. The government has no reason to believe that         is
operating for exempt purposes.

Accordingly, the government is proposing revocation of tax-exempt status effective         .
Contributions to         are not deductible under section 170 of the Code. Since         will no longer have
tax-exempt status, they are liable for filing Form 1120, U.S. Corporation Income Tax Return. If the proposed
revocation becomes final, appropriate state officials will be notified of such action in accordance with
§ 6104(c) of the Internal Revenue Code.

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