Determination 200827040: Appeals revokes a business league's tax exemption

Number
200827040
Outcome
Revocation
Document type
Determination Letter
IRS subject
Not Able to Identify Under Present List
Topics
Code sections
§ 501
Ruling dated
April 9, 2008
Publicly released
July 4, 2008

Apply this to your situation

This page covers one taxpayer's determination, issued in 2008, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2008
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

An organization appealed a proposed adverse action concerning its exemption under section 501(c)(6). The IRS Appeals office checked the box for revocation. The letter requires the organization to file Form 1120 income tax returns for tax years beginning on or after January 1, 2008, generally within 30 days of the letter unless it receives an extension. This brief letter gives no explanation for the underlying revocation.

Ruling snapshot

  • Question: What was the Appeals decision on the organization's section 501(c)(6) exemption?
  • Outcome: Revocation.
  • Key authorities: IRC § 501(c)(6).

Full text (IRS public release)

200827040

Internal Revenue Service
Department of the Treasury
Appeals Office

Date: APR 09 2008
Employer Identification Number:
Release Date 7/4/2008
D
A
Person to Contact:
B
Employee ID Number:
C
Tel:
Fax:
In Re: EO Revocation
Tax Period(s) Ended:

LEGEND:
A = UIL: 9999.98-00
B =
C =
D =
E =

Dear
:

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

Your exemption from Federal income tax under section 501(c)(6) of the Internal Revenue Code is:

[ ] Confirmed.
[ ] Modified. A new determination letter is enclosed.

[ ] Denied or [X] Revoked. You are required to file Federal income tax returns on Form 1120 for tax years beginning on or after January 1, 2008. You should file these returns within 30 days from the date of this letter, unless a request for extension of time is granted. File the returns in accordance with their instructions and do not send them to this office.

[ ] 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 years.

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

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

200827040

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

[ ] (other)

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

Sincerely,

Appeals Team Manager

cc: E

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