Determination 200805025: Appeals office denies section 501(c)(13) exemption

Plain-English summary

An organization appealed an adverse exempt organization determination. The IRS Appeals office denied its claim to federal income tax exemption under section 501(c)(13). The letter directed the organization to file Form 1120 for the affected years within 30 days unless it obtained an extension. It did not state the facts or reasons behind the denial.

Ruling snapshot

• Question: Would Appeals grant the organization's claimed section 501(c)(13) exemption?
• Outcome: Denied.
• Key authorities: IRC § 501(c)(13).

Full text (IRS public release)

200805025

Internal Revenue Service
Department of the Treasury

Date: OCT 30 2007

Employer Identification Number:

Tax Year(s) Ending:

UIL Code: 501.03-10

Person to Contact:
Employee ID Number:
Contact Telephone Number:

Dear :

We have considered your appeal of the adverse action proposed by the Director, Exempt Organizations. The paragraph(s) checked below indicate(s) our decision.

X Your exemption from Federal income tax under section 501(c)(13) of the Internal Revenue Code is:

__ confirmed.

__ modified. A new determination letter is enclosed.

_X denied or __ revoked. You are required to file Federal income tax returns on Form 1120 for the above years. You should file these returns with the appropriate service center listed in the instructions for those returns, within 30 days from the date of this letter, unless a request for extension of time is granted.

__ You are not a private foundation because you are described in code section(s)
____.

__ You are an operating foundation as described in code section 4942(j)(3).

__ You have no liability for excise taxes under IRC __ for the above year(s).

__ Your liability for excise taxes under IRC __ for the above year(s) was properly reported on your return(s).

Baltimore Appeals Office
31 Hopkins Plaza, Room 1310
Baltimore, MD 21201
Letter 1370(RO) (Rev. 1-80)

200805025

__ There is no change to your unrelated business income tax liability as reported for the above years.

__ Your Form(s) 990-T for the above years are accepted as filed.

You may direct questions about the decision to the appeals officer whose name and telephone number are shown above.

Sincerely,

[signature]
Charles Fisher
Appeals Team Manager

Enclosure: Notice 437

Baltimore Appeals Office
31 Hopkins Plaza, Room 1310