Charity status revoked for nonexempt purpose and private benefit

Number

201432027

Outcome

Revocation

Document type

Determination Letter

IRS subject

Not Able to Identify Under Present List

Topics

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This page covers one taxpayer's determination, issued in 2014, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

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

The IRS issued a final adverse determination revoking an organization's § 501(c)(3) status effective July 1, 2001. It found that the organization did not operate exclusively for exempt purposes or primarily conduct activities that accomplished exempt purposes. The organization instead had a substantial nonexempt purpose, operated for private interests, and produced substantial private benefit. Contributions were no longer deductible under § 170.

Ruling snapshot

Question: Did the organization continue to qualify for federal tax exemption under § 501(c)(3)?
Outcome: Revocation. Exempt status was revoked effective July 1, 2001.
Key authorities: IRC §§ 170, 501(c)(3); Treas. Reg. § 1.501(c)(3)-1(d)

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
TE/GE: EO Examination
1100 Commerce Street
Dallas, Texas 75242

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

JAN 31 2014

Employer Identification Number:

Number: 201432027
Release Date: 8/8/2014

Person to Contact/ID Number:

Contact Numbers:

UIL: 9999.98-00

CERTIFIED MAIL -- RETURN RECEIPT REQUESTED

Dear
:

This is a final adverse determination regarding your exempt status under section 501(c)(3) of the
Internal Revenue Code (the Code). We determined that you do not qualify as exempt from Federal
income tax under section 501(c)(3) of the Code effective July 1, 2001.

The revocation of your exempt status was made for the following reasons:

You have not demonstrated that you are operated exclusively for exempt purposes within the meaning of Internal Revenue Code section 501(c)(3) and Treasury Regulations section 1.501(c)(3)-1(d). You did not engage primarily in activities that accomplish one or more of the exempt purposes specified in section 501(c)(3). You are operated for a substantial non-exempt purpose. You are operated for the benefit of private rather than public interests and your activities resulted in substantial private benefit.

Contributions to your organization are not deductible under section 170 of the Code.

If you have any questions, please contact the person whose name and telephone number are shown
in the heading of this letter.

Sincerely yours,

Nanette M. Downing
Director, EO Examinations

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