Exemption revoked for inurement and cessation of operations

View official IRS release (PDF)

Plain-English summary

A religious organization received donations to publish daily devotionals and produce a television program. The IRS examination found that organization funds paid its president's personal shopping, housing, medical, vehicle, credit card, and other expenses. The organization also made interest-free, unsecured loans and cash advances to a for-profit company controlled by the president, without adequate proof of repayment or board approval. It had stopped operating and filed a final Form 990. The IRS concluded that the private benefits and inurement violated section 501(c)(3), and it revoked the exemption retroactively to June 1, 2007. The organization agreed with revocation because it was no longer operating.

Ruling snapshot

• Question: Did the organization continue to qualify under section 501(c)(3) after its funds benefited its president and his for-profit company, and after the organization ceased operations?
• Outcome: Revocation
• Key authorities: IRC §§ 501, 4958, 6001, 6033, 7805; Treas. Reg. §§ 1.501(a)-1, 1.501(c)(3)-1, 1.6001-1, 1.6033-1

Full text (IRS public release)

Internal Revenue Service Department of the Treasury
Appeals Office

Royal Palm One, Suite 350
1000 South Pine Island Road
Plantation, FL 33324

Employer Identification Number:

Number
Release Number: 201533022
Release Date: 8/14/2015
Date: May 19, 2015 Employee ID Number:
NAME
ADDRESS Tel:
Fax:
UIL: 7428.02-00
Certified Mail
Dear

This is a final adverse determination regarding your exempt status under section
501(c)(3) of the Internal Revenue Code (the “Code”). It is determined that you do not
qualify as exempt from Federal income tax under section 501(c)(3) of the Code effective
June 1, 2007.

The revocation of your exempt status was made for the following reason(s):

Organizations exempt from Federal income tax under section 501(c)(3) of the Internal
Revenue Code are required to operate exclusively for charitable, education, or other
exempt purposes. Organizations are not operated exclusively for exempt purposes if the
net earnings of the organization inure in whole or in part to the benefit of private
shareholders or individuals of the organization. See Treas. Reg. § 1.501(c)(3)-1(c)(2).
We have determined that your net earnings inured to the benefit of private individuals
and a for-profit organization owned by private individuals through multiple and repeated
transactions. As such, you have not operated exclusively for exempt purposes and have
operated for the benefit of private interests of individuals in contravention of the
requirements of Treas. Reg. 1.501(c)(3)-1(d)(1)(ii).

You are required to file Federal income tax returns on Forms 1120. File your return with
the appropriate Internal Revenue Service Center per the instructions of the return. For
further instructions, forms, and information please visit www.irs.gov.

If you were a private foundation as of the effective date of revocation, you are
considered to be taxable private foundation until you terminate your private foundation
status under section 507 of the Code. In addition to your income tax return, you must

also continue to file Form 990-PF by the 15th Day of the fifth month after the end of your
annual accounting period.

We will make this letter and the proposed adverse determination letter available for
public inspection under Code section 6110, after deleting certain identifying information.
We have provided to you, in a separate mailing, Notice 437, Notice of Intention to
Disclose. Please review the Notice 437 and the documents attached that show our
proposed deletions. If you disagree with our proposed deletions, follow the instructions
in Notice 437.

You have agreed to waive your right to contest this determination under the declaratory
judgment provisions of Section 7428 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,

Timothy D. Jarvis
Appeals Team Manager

Enclosure: Publication 892 and/or 556

Internal Revenue Service

Department of the Treasury
IRS Tax Exempt and Government Entities Division

UIL: 501.03.00

ORG

Certified Mail - Return Receipt Requested
Dear

Why you are receiving this letter

Date:
April 10, 2014
Taxpayer Identification Number:

Form:
990
Tax year(s) ended:

5/31/20XX & 5/31/20XX & 5/31/20XX
Person to contact / ID number:

Contact numbers:
Phone Number:
Fax Number:
Manager's name / ID number:

ID
Manager's contact number:
Phone Number
Response due date:

May 9, 20XX

We propose to revoke your status as an organization described in section 501(c)(3) of the Internal Revenue
Code (Code). Enclosed is our report of examination explaining the proposed action.

What you need to do if you agree

If you agree with our proposal, please sign the enclosed Form 6018, Consent to Proposed Action — Section
7428, and return it to the contact person at the address listed above (unless you have already provided us a
signed Form 6018). We'll issue a final revocation letter determining that you aren't an organization described in

section 501(c)(3).

After we issue the final revocation letter, we’ll announce that your organization is no longer eligible for

contributions deductible under section 170 of the Code.

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
revocation letter. Failing to respond to this proposal will adversely impact your legal standing to seek a
declaratory judgment because you failed to exhaust your administrative remedies.

Effect of revocation status

If you receive a final revocation letter, you'll be required to file federal income tax returns for the tax year(s)

shown above as well as for subsequent tax years.

What you need to do if you disagree with the proposed revocation

If you disagree with our proposed revocation, you may request a meeting or telephone conference with the
supervisor of the IRS contact identified in the heading of this letter. You also may file a protest with the

Letter 3618 (Rev. 6-2012)

Catalog Number 34809F

IRS Appeals office by submitting a written request to the contact person at the address listed above within 30
calendar days from the date of this letter. The Appeals office is independent of the Exempt Organizations
division and resolves most disputes informally.

For your protest to be valid, it must contain certain specific information including a statement of the facts, the
applicable law, and arguments in support of your position. For specific information needed for a valid protest,
please refer to page one of the enclosed Publication 892, How to Appeal an IRS Decision on Tax-Exempt Status,
and page six of the enclosed Publication 3498, The Examination Process. Publication 3498 also includes
information on your rights as a taxpayer and the IRS collection process. Please note that Fast Track Mediation
referred to in Publication 3498 generally doesn’t apply after we issue this letter.

You also may request that we refer this matter for technical advice as explained in Publication 892. Please
contact the individual identified on the first page of this letter if you are considering requesting technical

advice. If we issue a determination letter to you based on a technical advice memorandum issued by the Exempt
Organizations Rulings and Agreements office, no further IRS administrative appeal will be available to you.

Contacting the Taxpayer Advocate Office is a taxpayer right

You have the right to contact the office of the Taxpayer Advocate. Their assistance isn’t a substitute for
established IRS procedures, such as the formal appeals process. The Taxpayer Advocate can't reverse a legally
correct tax determination or extend the time you have (fixed by law) to file a petition in a United States court.
They can, however, see that a tax matter that hasn't been resolved through normal channels gets prompt and
proper handling. You may call toll-free 1-877-777-4778 and ask for Taxpayer Advocate assistance. If you
prefer, you may contact your local Taxpayer Advocate at:

Internal Revenue Service
Office of the Taxpayer Advocate

For additional information

If you have any questions, please call the contact person at the telephone number shown in the heading of this
letter. If you write, please provide a telephone number and the most convenient time to call if we need to
contact you.

Thank you for your cooperation.

Sincerely,
Mary A. Epps

Mary A. Epps
Acting Director, EO Examinations

Enclosures:

Report of Examination
Form 6018

Publication 892
Publication 3498

Letter 3618 (Rev. 6-2012)
Catalog Number 34809F

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX
LEGEND
ORG - Organization name XX - Date State - state President - president
website - Website
Issue

Whether the IRS should revoke the tax exempt status of ORG (“ORG” or the “organization”)
pursuant to I.R.C. §§ 501(a) and 501(c)(3) effective June 1, 20XX where the organization is not
operated exclusively for tax exempt purposes, its net earnings inure to the benefit of its President,
and it is no longer operating.

Facts
ORG was incorporated under the Not-For-Profit Corporation Act of Illinois on June 23, 19XX.
ORG operates in State.

ORG was granted tax exempt status under section 501(a) as an organization described in section
501(c)(3) on January 28, 19XX. The exempt purpose of ORG was to educate people about the
Christian faith. Its activities consisted of creating and running: a website called Website

(www.Website.com), making available to the public via its website, and its e-mail postings its
Daily Devotionals, and operating a television show called Website. Daily Devotionals are daily
written articles that focus and comment on practices of the Christian faith.

ORG is run by its president, who is also its founder. The president is responsible for the overall
and day to day operations of ORG. He is authorized to sign corporate checks and other financial
instruments, execute contracts and leases, and otherwise perform all the daily duties and
functions ordinarily conducted by an officer of a corporation.

ORG derives its income from donations. In its website, www.Website.com ORG requests
donations and states that donations are tax deductible.

Evidence of Inurement

The IRS’s examination of ORG indicated that there was substantial inurement of ORG exempt
funds to the president of ORG.

A. Payments Made Directly to the President

The IRS’s examination of ORG’s bank statements, canceled checks, and related books and
records demonstrated that ORG’s exempt organization funds were used to make payments to, or
on behalf of the President of ORG in tax years ending May 31, 20XX, May 31, 20XX and May
31, 20XX. The president was a signer of ORG bank accounts who signed for ORG’s business

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -1-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or

Explanation of Items Exhibit

Name of Taxpayer Year/Period Ended

ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

expenses. In addition, the president approved expenses and endorsed checks for the payment of
his own personal expenses - including signed checks payable to “cash” which were endorsed by
the president; ORG funds were also used to pay for the president’s personal shopping expenses,

personal residence expenses, loans, personal credit card expenses, and car payments. Below is a
table showing the total expenses paid by ORG directly on the president’s behalf per calendar

year:

Tax Year Ending: 12/31/20XX 12/31/20XX 12/31/20XX 12/31/20XX
Total Direct Payments received by the president from ORG per year: $0 $0 $0 $0

(See Table 1 for a Description of These Payments)

• ORG did not maintain contemporaneous records documenting that the President had a
housing allowance.

• ORG did not maintain contemporaneous records documenting that the President had a
utilities allowance.

• ORG did not maintain contemporaneous records documenting that the President had a
clothing allowance.

• ORG did not maintain contemporaneous records documenting that the President had a
medical allowance.

• ORG did not maintain contemporaneous records documenting that the President was
reimbursed under an accountable plan. ORG did not maintain expense reports or
receipts. ORG payments of expenses incurred by the President were made under a “non-
accountable” plan.

• ORG did not maintain contemporaneous records demonstrating that expenses paid were
to support its exempt purpose.

• ORG issued a Form W-2 to the President in the following amounts:
Form W-2 for 12/31/20XX: $0
Form W-2 for 12/31/20XX: $0
Form W-2 for 12/31/20XX: $0
Form W-2 for 12/31/20XX: $0

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -2-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

The additional amounts received as indicated above were not included on Form W-2 or
1099-MISC issued to the President.

B. Payments Made Indirectly to the President

The IRS’s review of bank statements, canceled checks, and related books and records,
demonstrated that the funds of a for-profit company wholly owned by ORG’s president were
used to make payments to, or on behalf, of the president in each tax year. The president used
these funds for the payment of his personal expenses. Below is a table showing the expenses
paid by the for-profit company on behalf of the president:

Payments from the For-Profit Company for the President’s Personal Expenses
Tax Year Ending: 12/31/20XX 12/31/20XX 12/31/20XX 12/31/20XX
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Blank: $0.00 $0.00 $0.00 $0.00
Cash: $0.00 $0.00 $0.00 $0.00
Off ch #: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Total Payments per year: $0.00 $0.00 $0.00 $0.00

In connection with the above, the IRS’s examination of ORG’s bank statements, canceled
checks, and related books and records demonstrated that ORG’s exempt organization funds were
used to make payments in each tax year to the president’s for-profit company. The president was
the signer of ORG’s bank accounts. The president signed and approved payments for an alleged
loan and for cash advances from ORG to his for-profit company. The president was the signer of
his for-profit company’s bank accounts. Below is a table showing these payments from ORG to
his for-profit company:

Payments from ORG to the For-Profit Company
Tax Year Ending: 12/31/20XX 12/31/20XX 12/31/20XX 12/31/20XX
For-Profit Company: $0.00 (including $0.00 “loan” of 9/27/XX) $0.00 $0.00 $0.00
Total Payments from ORG to the For-Profit Company per year: $0.00 $0.00 $0.00 $0.00
Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service

Page: -3-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit

Name of Taxpayer Year/Period Ended

ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

• On 9/27/20XX, a Loan Agreement was entered into between ORG and the president’s for-
profit company. The agreement was executed by the president while acting as both the
president of ORG (the lender), and as the president of his for-profit corporation (the
borrower). The Loan Agreement provided that ORG would loan $0 to the for-profit
corporation. The loan was at 0% interest and the for-profit was required to repay the full
amount on December 27, 20XX. In correspondence dated February 19, 20XX, ORG
stated that $0 was repaid. In addition, no documentation was provided verifying this
partial repayment.

In correspondence dated February 19, 20XX, ORG stated the for-profit company received
more than one loan from ORG over the years, and in total, the for-profit did not repay
ORG $0 in borrowed funds. Also, in correspondence dated February 8, 20XX, ORG
stated that, “ORG funded [the for-profit company] with operational loans and as it was
able, [for-profit company] repaid what it could. ORG ended up being owed approximately
$0 million in unpaid loans when [the for-profit company] closed down.”

Evidence of a Failure to Operate

In tax year ending May 31, 20XX, ORG filed a Form 990 indicating that the organization had
terminated and that it was a final Form 990. ORG reported beginning year assets of $0 and
ending assets of $0.00. The IRS asked about this in Information Document Request (“IDR”) #5
dated January 12, 20XX. IDR #5 asked why the organization filed a “terminated” Form 990 for
tax year ending May 31, 20XX; asked who approved the distribution of assets; and requested
documents for proof of legal termination including Articles of Dissolution and proof of filing,
and a Board Resolution signed by the officers and board of directors indicating the date of
dissolution.

In correspondence dated March 18, 20XX ORG stated that, “ORG was involuntarily dissolved on
November 13, 20XX by the Illinois Secretary of State and had ceased all operations on March
30, 20XX.” With regard to the Articles of Dissolution and Board Resolution, ORG stated, “a.)
No articles of dissolution were filed. ORG was dissolved by operation of law for failure to file
the corporate annual report. b.) Not applicable.”

According to the State Department of State, ORG is listed as “inactive” and “Revoked for
Annual Report” dated 9/24/20XX.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -4-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

IDRs and ORG Responses as Evidence of the Above

In IDR #2 issued by the IRS dated July 28, 20XX, the IRS requested information on a loan and
cash advances that had been made from ORG to a for-profit corporation owned by the president
of ORG. The loans and cash advances were reported by ORG to be cash advances of $0 and $0
in uncollected ministry consulting income to the for-profit corporation. In the IDR the IRS
requested a copy of the loan contract, interest rates, repayment schedule including verification of
repayment such as canceled checks, copies of wire transfers, etc., if the loans/advances were
collateralized, how the loans furthered ORG’s exempt purpose, and if the loans and advances
were discussed or approved by the board of directors. The IDR also requested copies of bank
statements along with copies of canceled checks for tax years ending 5/31/20XX and 5/31/20XX.

In correspondence dated September 15, 20XX ORG stated the following:

“a. Attachment #2: Loan Agreement

b. The loan has no interest rate since the ministry benefits from the exposure it receives through
the efforts of [For-Profit Corporation].

c. The loan installment payments are being made by check. We do not get cancelled checks from
our bank.

d. The note is due on 12/27/XX.

e. The loan is not collateralized.

f. The purpose of the loan was to operate the [TV] program when it went national in 20XX in a
separate For-Profit entity since it will eventually receive advertising revenues. This was done to
ensure that those revenues would not generate a substantial amount of unrelated business income
for the 501(c)(3) organization.

g. The loan launched the television program that brings the Gospel of Jesus Christ to the lost and
hurting and ministering to people’s spiritual needs.

h. The president, [President] had the idea to make the loan. An initial loan was made on
9/27/XX, and additional amounts were loaned to [For-Profit Corporation] through December
20XX.

i. It was a decision made by the President and discussed with the Board at the December 20XX
Board Meeting of ORG, as well as at each subsequent Board Meeting, June 20XX, December
20XX, and June 20XX. (Attachment #3: December 20XX Board Meeting minutes)

j. [For-Profit Corporation] has repaid $0 to date.”

ORG included a copy of the December 22, 20XX minutes. The minutes did not document
discussion or approval of any loans or cash advances. Instead, the Minutes stated, “The Board
discussed the relationship between ORG and [For-Profit Corporation], a State for-profit
corporation.” (ORG Minutes dated December 22, 20XX) ORG did not provide copies of the
subsequent meeting Minutes that it referenced in its correspondence.

Form 886-A (Rev.4-68) , Department of the Treasury - Internal Revenue Service
Page: -5-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

ORG also included a copy of the Loan Agreement which was dated September 27, 20XX. The
Loan Agreement contained handwritten notes including what appear to be check marks, dates,
and numbers. The Loan Agreement states:
“This loan is between ORG and [For-Profit Corporation].
In consideration for a loan of $0, [For Profit Corporation] will repay the full amount plus
0% interest on December 27, 20XX. Agreed to this on the 27th day of September,
20XX.”

The Loan Agreement was signed by the president, as president of ORG and as president of the
for-profit corporation. The Loan Agreement was not signed by any other officers or board of
director members.

ORG did not provide copies of the bank statements or canceled checks in its reply to IDR #2.

On November 19, 20XX the IRS issued IDR #3. In IDR #3 the IRS requested copies of the bank

statements and canceled checks which had not been received with the previous correspondence.

The IDR also requested additional information on the loans and cash advances, and requested
documentation for the repayment of the loans and cash advances. IDR #3 asked:

“Also, in your response to Question #2, you indicated that to date, loan installment
payments totaling $0 have been paid by check(s). However you did not provide any
verification of any repayments made. You also stated that the loan was discussed during
a Board Meeting. You provided a copy of the Minutes of the Board of Directors Meeting
dated December 22, 20XX. Our review of the minutes shows that the Board did not in
fact discuss any loan to [For-Profit Corporation]. Rather the directors discussed, “the
relationship between ORG and [For-Profit Corporation] a State for-profit corporation.”
(December 22, 20XX Minutes, page 2)

Please answer the following questions with regard to the above-stated $0 loan:

a. Please explain what the handwritten notations indicate. Were these marks on the
Loan Agreement before it was signed? Please explain.

b. Did the Board of Directors discuss the $0 loan made to [For-Profit Corporation]?
Please provide documentation indicating the loan.

c. How was the loan made to [For-Profit Corporation]? (Wire transfer, checks, etc.)
Was the loan made in one transaction or several transactions/installments? Please
provide documentation such as copies of canceled checks (front & back) and/or copy
of wire transfer document.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -6-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

d. Please provide documentation to verify that [For-Profit Corporation] paid $0 to ORG,
such as copies of canceled checks (front & back), and/or copies of wire transfers. On
what date(s) did [For-Profit Corporation] repay the $0, and in what amount(s)?

e. Is [For-Profit Corporation] paying back the loan in installments? If so, what are the
installment amounts and how often are the installment payments made and when are
they due?

f. How does this loan further the exempt purposes of ORG? Why was the loan made at
0% interest? Who in your organization approved and authorized this loan?

g. Please explain what the following statement included in your response to Information
Document Request #2 question #2, means: “The loan has no interest rate since the
ministry benefits from the exposure it receives through the efforts of [For-Profit
Corporation.]”

ORG responded to IDR #3 in correspondence dated December 9, 20XX. It stated the following:

“a. The handwritten notations are loan disbursements made to [For-Profit Corporation. ]
b. The Board discussed the $0 loan to [For-Profit Corporation] at the December 22, 20XX
meeting. The minutes are the only documentation.
c. The transfers were made by check. The handwritten notation reflect the date and
amount of each installment. The bank does not provide canceled checks.
d. The bank does not provide canceled checks. [For-Profit Corporation] made the
payments as follows:
01/31/XX $0
02/15/ XX $0
04/15/ XX $0
04/22/ XX $0
05/12/ XX $0
05/23/ XX $0
06/30/ XX $0
07/10/ XX $0
10/30/ XX $0
e. There is no set repayment schedule.
f. [For-Profit Corporation] produces the religious television programs of
. See A2.f. above.
g. In light of the foregoing explanation of the ownership of [For-Profit Corporation] being
ORG, Inc. and not [President], this statement is self explanatory.” (ORG correspondence
dated December 9, 20XX)

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service

Page: -7-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 . 5/31/20XX,
5/31/20XX,
5/31/20XX

In the same correspondence dated December 9, 20XX, ORG stated that the for-profit corporation
was wholly owned by ORG, not the president personally. It indicated that the error was caused
by a typo in the audited financial statements.

On July 7, 20XX the IRS issued IDR #4. IDR #4 requested the copies of bank statements and
copies of the canceled checks. IDR #4 requested clarification on who is the legal owner of the
for-profit corporation. Legal documentation such as Stock Certificates were requested to
determine the legal owner of the for-profit corporation. IDR #4 asked what collection efforts
had been taken by ORG to date. Documentation and verification of the loans and payments were
requested such as copies of canceled checks, carbon copy of checks, wire transfer statements,
bank statements, etc.

In ORG correspondence dated February 19, 20XX, ORG stated that $0 of the loans had been

repaid, leaving $0 in unpaid loans that could not be repaid. ORG did not include verification of
the repayment of $0. It stated, “Although $0 of the nearly $0 loaned to [For-Profit Corporation]
was repaid to ORG, the rest is uncollectible.” (ORG correspondence dated February 19, 20XX)

The correspondence included a transfer document dated November 1, 20XX in which the
President transferred all his stock in the for-profit corporation to ORG. The document states:

“On this 1st day of November, 20XX, all stock in [For-Profit Corporation] is being
transferred to ORG, Inc. [President] will continue to act as President and has the
authority to make all decisions in the operation of [For-Profit Corporation.]”

On the Form 990 for tax year ending May 31, 20XX ORG filed a final Form 990 by checking the
“terminated” box and reporting end of the year assets of $0.00.

In correspondence dated February 25, 20XX ORG stated that from 1/31/20XX to 10/30/20XX,
$0 of loans were repaid, leaving $0 in unpaid loans that cannot be repaid. ORG stated that there
are no canceled checks.

As previously discussed, the IRS issued IDR #5 on January 12, 20XX. IDR #5 requested the
bank statements and canceled checks for tax years ending May 31, 20XX, May 31, 20XX and
May 31, 20XX. IDR #5 also requested detailed information on general ledger transactions which
appeared to be payments for the president’s personal expenses. This included payments to cash,
credit cards, banks, stores, and clothing stores.

The following questions are from IDR #5 dated January 12, 20XX:

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service

Page: -8-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

“These attachments have been taken from the general ledger and each one is a partial list
that does not include all of the payees from the general ledger. For the payments listed in
each of the above attachments, please answer the following questions:

a.) What were the payments for?

b.) Who authorized the check payments?

c.) Why are checks made payable to “cash?” What is the cash used for? By whom?

d.) It was noted that several checks made payable to “cash” were in the amount of zero.
Please explain.

e.) Please define and explain who/what each payee refers to.

f.) With respect to payments made to individuals, please advise whether any contracts
exist with respect to these payments, and if they exist, please provide them. If these
payments were for services, please advise what sort of reporting, e.g., Form 1099, ORG
made with respect to these payments.

g.) What consultation services did [redacted] One provide? Please explain what the
consultation fees were for.
h.) What consultation services did [redacted] provide? Please explain what the

consultation fees were for.
i.) What are payments to stores such as [redacted] and [redacted] for? How are they related to ORG’s tax
exempt purpose? Please provide documentation indicating such.
j.) With respect to the 20XX and 20XX Travel & Entertainment accounts, what are these
payments for? For each of these expenses listed, please explain how they are related to
ORG’s tax exempt purpose. In addition, what are the listed payments to banks
([redacted]) and credit card companies ([redacted]) for? Please provide all supporting documentation
that establish a connection between these expenses and ORG’s tax exempt purpose.
k.) Some payments were made to “Unknown Person.” To whom does this refer? What
was the purpose of these payments? How do they relate to ORG’s tax exempt purpose?”

In ORG correspondence dated March 18, 20XX ORG stated, “ORG used [Bank]. The ministry
has never received canceled checks. At present, the bank statements have not been located but
they will be provided if and when they are found.” ORG provided some bank statements for tax
year ending May 31, 20XX. It indicated that it did not have canceled checks. In the same
correspondence dated March 18, 20XX ORG provided its response to the above referenced
questions as follows:

“a.) To the best of [President’s] recollection, these payments related to the Internet
operational costs.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -9-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

b.) [President] authorized the check payments.

c.) [President] does not recollect why the payments are stated to be for cash. To the best
of his recollection the payments were made for operational needs.

d.) There is no explanation available for the printout did this.

e.) These are different companies that ORG used for its internet operations.

f.) There are no written contracts available. These were companies that provided
different internet operational services.

g.) These payments are not consulting fees. These payments to credit card companies. It
is unknown why this notation was used.

h.) These payments are not consulting fees. These payments to credit card companies. It
is unknown why this notation was used.

i.) To the best of [President’s] recollection, these payments relate to donor/fundraising
activities.

j.) To the best of [President’s] recollection, these payments relate to donor/fundraising
activities.

k.) [President] does not recollect what the payments refer to.”

The IRS summoned ORG’s bank statements and canceled checks for tax years ending May 31,
20XX, May 31, 20XX and May 31, 20XX from the bank. A review of the bank statements and
canceled checks indicated that there were several payments which appeared to be for the personal
expenses of the president. This included checks made payable to “cash” which were both signed
and endorsed by the president, clothing stores, jewelry stores, medical and dental payments, car
payments, credit card payments, bank payments, and payments for home services provided at the
president’s personal home address. The memo section in the checks had the president’s home
address printed on it.

On December 13, 20XX the IRS issued IDRs #6, #7, #8, and #9.

IDR #6 dated December 13, 20XX asked the following questions about the transactions which
appeared to be personal in nature:

"1.) For the transactions listed in Attachment A and Attachment B (enclosed) please provide
the following information for every transaction listed:

a.) What is the nature of the payment or expense? Provide a description of the expense.

b.) Provide an explanation as to how the expense is used for the organization’s operations.
c.) Provide supporting documentation such as receipts or invoices.

d.) Please explain why the amounts were not reported as compensation.”

In response to IDR #6 dated February 8, 20XX, ORG stated the following:

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service

Page: -10-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit

Name of Taxpayer Year/Period Ended

ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

“[President] has stated that he has no documents in response to your request, only written
responses.”

Also, in this same response, ORG stated that the expenses were for as follows:
“Car dealership- payment was made for the use of office space for the ministry.
[redacted]- the payment was for fundraising.
[redacted]- cash was taken for the operation of ministry shortfalls
BLANK- repayment of funds needed to operate ministry. The $0. And $0 went towards
TV times.
[redacted]- funds were used to operate the ministry.
Cash- used to pay for TV time and repay loans for operations.
[redacted]- used for operations.
Lender- loan payments
Doctor- medical expenses
[redacted]- used for operations.
[redacted]- satellite uplink costs
[redacted]- satellite uplink costs
Finance Company- operations.
[redacted]- car allowance
Tailor- clothing for TV show
[President]- repayment of funds loaned for operations and payment for State State Fair
expenses.
Lawn Care-1- housing expense.
[redacted]- fundraising.
[redacted]- used for operations
BLANK- operations
[redacted]- used for operations
Cash- payroll for [President]; petty cash; operational loans.
[redacted]- operations
Lawn Care-2- housing
Doctor- medical
[redacted]- fundraising expense
Individual- housing
Lake and Pond- housing
[redacted]- fundraising
Mayor’s- fundraising
[redacted]- clothing for TV
Professional termite: housing
[redacted]- TV studio
[redacted]- fundraising

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -11-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

Pool service- housing”

ORG did not provide documentation to show the exempt purpose for the expenses and payments.
ORG did not provide copies of a housing allowance, clothing allowance, medical allowance,
utilities allowance, or accountable plan information. ORG did not provide information on loans
or how the expenses were used for the organization’s operational needs.

IDR #8 dated December 13, 20XX asked about the loans ORG made to the for-profit
corporation. The questions included:

“Please answer the following questions in regard to payments to [For-Profit Corporation]

1.) Please explain the purpose of each of these payments. Indicate how these expenditures
are related to ORG operations between 20XX and 20XX.

2.) Provide documentation of any loan transactions relating to these payments.

3.) Provide board minutes indicating that the Board of Directors approved these

payments/loans.
4.) For any loans, provide proof of repayment if the amounts were repaid.”

In correspondence dated February 8, 20XX ORG stated:

“ORG funded [For-Profit Corporation] with operational loans and as it was able, [For-
Profit Corporation] repaid what it could. ORG ended up being owed approximately $0
million in unpaid loans when [For-Profit Corporation] closed down.”

IDR #9 dated December 13, 20XX asked about car payments. IDR #9 including the following
question:

“1.) With respect to Attachment A (enclosed) review of the accounts indicates that ORG
has made payments to various car dealerships including Car Dealership Inc. and
[redacted]. Who are the owner(s) of these vehicles? Provide proof of ownership.”

In correspondence dated February 8, 20XX ORG stated:

“Payments to Car Dealership were for office space. The owner of Car Dealership is on
the board of ORG. The [redacted] totaled in an accident in June 20XX.”

ORG did not provide proof of ownership for the vehicles or documents to verify that the vehicles
were used for official business of the exempt organization.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -12-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX
Law

Section 501 of the Code provides for the exemption from federal income tax of corporations
organized and operated exclusively for charitable or educational purposes, provided that no part
of the net earnings of such corporations inures to the benefit of any private shareholder or
individual. See § 501(c)(3).

Treas. Reg. § 1.501(c)(3)-1(a)(1) provides that in order for an organization to be exempt under
section 501(c)(3) it must be both organized and operated exclusively for one or more of the
purposes specified in such section. If an organization fails to meet either the organizational or
operational test, it is not exempt.

Treas. Reg. § 1.501(c)(3)-1(c)(1) provides that an organization operates exclusively for exempt
purposes only if it engages primarily in activities that accomplish exempt purposes specified in
section 501(c)(3). An organization must not engage in substantial activities that fail to further an
exempt purpose.

Treas. Reg. § 1.501(c)(3)-1(c)(2) provides that an organization is not operated exclusively for
one or more exempt purposes if its net earnings inure in whole or in part to the benefit of private
shareholders or individuals.

Treas. Reg. § 1.501(c)(3)-1(d)(1)(ii) provides that an organization is not organized or operated
exclusively for exempt purposes unless it serves a public rather than a private interest. To meet
this requirement, it is necessary for an organization to establish that it is not organized or
operated for the benefit of private interests.

Treas. Reg. § 1.501(c)(3)-1(d)(2) defines the term “charitable” for section 501(c)(3) purposes as
including the relief of the poor and distressed or of the underprivileged, and the promotion of
social welfare by organizations designed to lessen neighborhood tensions, to eliminate prejudice
and discrimination, or to combat community deterioration. The term “charitable” also includes
the advancement of education.

Treas. Reg. § 1.501(c)(3)-1(d)(3)(i) provides, in part, that the term “educational” for section
501(c)(3) purposes relates to the instruction of the public on subjects useful to the individual and
beneficial to the community.

Even if an organization's activities serve a charitable class or are otherwise charitable within the
meaning of section 501(c)(3), it must demonstrate that its activities serve a public rather than a
private interest within the meaning of section 1.501(c)(3)-1(d)(1).

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -13-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit

Name of Taxpayer Year/Period Ended

ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

An organization does not serve a public rather than a private interest within the meaning of
section 1.501(c)(3)-1(d)(1) if any of its assets or earnings inure to the benefit of any insiders (or
disqualified persons). Section 1.501(c)(3)-1(d)(1)(ii). Inurement is any transfer of charitable
assets to the organization's insiders for which the organization does not receive adequate
consideration. Inurement can take many forms.

Section 501(c)(3) specifies that an exempt organization described therein is one in which “no
part of the net of earnings inures to the benefit of any private shareholder or individual.” The
words “private shareholder or individual” in section 501 to refer to persons having a personal and
private interest in the activities of the organization. Treas. Reg. § 1.501 (a)-1(c).

Fact patterns suggesting inurement also frequently suggest excess benefit transactions between an
exempt organization and a disqualified person under § 4958. The regulations issued under
section 501(c)(3), at Treas. Reg. § 1.501(c)(3)-1(f)(ii), instruct the Service to consider a variety
of factors to determine whether revocation is appropriate when section 4958 excise taxes also
apply:
(A) The size and scope of the organization's regular and ongoing activities that further
exempt purpose before and after the excess benefit transaction or transactions occurred;
(B) The size and scope of the excess benefit transaction or transactions (collectively, if more
than one) in relation to the size and scope of the organization's regular and ongoing activities
that further exempt purposes;
(C) Whether the organization has been involved in multiple excess benefit transactions with
one or more persons;
(D) Whether the organization's implemented safeguards that are reasonably calculated to
prevent excess benefit transactions; and
(E) Whether the excess benefit transaction has been corrected (within the meaning of section
4958(f)(6) and § 53.4958-7), or the organization has made good faith efforts to seek
correction from the disqualified person(s); who benefited from the excess benefit transaction.

The Commissioner has discretion to weight the factors depending on the particular situation, but
the latter two factors are weighted heavier only when the Organization has taken preemptive
steps to correct the excess benefit transaction before they were brought to the Commissioner's
attention. Treas. Reg. § 1.501(c)(3)-1(f)(iii).

Treas. Reg. § 1.501(c)(3)-1(f)(iv) Example 3 supposes that an organization's founder diverts
significant portions of the organization to pay personal expenses, which reduces the funds
available to conduct exempt activity, over the course of multiple years. The board of trustees
never authorized the organization to pay the founder's personal expenses and takes no action to

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -14-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended

ORG Form: 990 5/31/20XX,
5/31/20XX,

5/31/20XX

seek repayment or terminate the founder's involvement with the organization. The founder
claims that the payments represent loans, but no contemporaneous documentation exists and no
payments of principal or interest were ever made to the organization. Based on the factors above,
the regulations contemplate that not only does the diversion of funds constitute an excess benefit
transaction under § 4958, but the prohibition against inurement has been violated and the
organization no longer qualified as an organization described in section 501(c)(3).

In Better Business Bureau of Washington D.C., Inc. v United States, 326 U.S. 279 (1945), the
Supreme Court held that the presence of a single non-exempt purpose, if substantial in nature,
will destroy the exemption regardless of the number or importance of truly exempt purposes.
The Court found that the trade association had an “underlying commercial motive” that
distinguished its educational program from that carried out by a university.

In Greg R. Vinikoor v. Commissioner. T.C. Memo. 1998-152, the United States Tax Court held
that whether a financial transaction constitutes a loan depends on all the facts and circumstances,
including whether (1) there was a promissory note or other evidence of indebtedness; (2) interest
was charged; (3) there was security or collateral; (4) there was a fixed maturity date; (5) a
demand for repayment was made; (6) any actual repayment was made; (7) the transferee had the
ability to repay; (8) any records maintained by the transferor and/or the transferee reflected the
transaction as a loan; and (9) the manner in which the transaction was reported for Federal tax
purposes. The Court stated, “A mere declaration by the taxpayers that they intended the transfer
to constitute a loan is insufficient if the transaction fails to exhibit more reliable indicia of debt.”

In Rameses School of San Antonio, Texas v. Commissioner, T.C. Memo 2007-85 the Tax Court
held that a private school failed to qualify for exemption under section 501(c)(3) because it
operated for the private benefit of its founder. Factors highlighting a prohibited relationship
included control by the founder over the entity's funds, assets, and disbursements; use of entity
moneys for personal expenses; payments of salary or rent to the founder without any
accompanying evidence or analysis of the reasonableness of the amounts; and purported loans to
the founder showing a ready private source of credit. -

Also in Rameses School of San Antonio, Texas v. Commissioner, the taxpayer failed the
operational test under Treas. Reg. § 1.501(c)(3)-1(c) on grounds that the taxpayer was operated to
benefit the private interests of an individual who served as the taxpayer's executive director,
president, chief executive officer, and administrator, and that part of its net earnings inured to her
benefit. The administrator made unexplained cash withdrawals on the taxpayer's account. There
were also questionable lease agreements, signed only by the administrator, that were never
approved by the board. The administrator contended that the taxpayer owned the property, but if
this were true, the taxpayer had leased the property from itself under the owner rental agreement.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -15-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer : Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

The court held that in application of the organizational and operational tests, "exclusively" does
not mean "'solely" or "absolutely without exception". Nonetheless, the presence of a single
nonexempt purpose, if substantial in nature, precludes exempt status, regardless of the number or
importance of truly exempt purposes.

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

I.R.C. § 6033(a)(1) provides, except as provided in I.R.C. § 6033(a)(2), every organization
exempt from tax under section 501(a) shall file an annual return, stating specifically the items of
gross income, receipts and disbursements, and such other information for the purposes of
carrying out the internal revenue laws as the Secretary may by forms or regulations prescribe, and
‘keep such records, render under oath such statements, make such other returns, and comply with
such rules and regulations as the Secretary may from time to time prescribe.

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 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) provides that every organization which has established its right to
exemption from tax, 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 the following), chapter 1 of the Code and section
6033.

I.R.C. § 7805(b)(8) provides that “[t]he Secretary [of the Treasury] may prescribe the extent, if
any, to which any ruling (including any judicial decision or any administrative determination
other than by regulation) relating to the internal revenue laws shall be applied without retroactive
effect.” Pursuant to this authority the Secretary has given the IRS discretion to retroactively
revoke exemption rulings or determination letters where “the organization omitted or misstated a
material fact, operated in‘a manner materially different from that originally represented, or
engaged in a prohibited transaction of the type described in subdivision (vii) of this
subparagraph.” 26 C.F.R. sec. 601.201(n)(6)(i), Statement of Procedural Rules. See also
Revenue Procedure 2013-9 '.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -16-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended

ORG Form: 990 5/31/20XX,
5/31/20XX,

5/31/20XX

Taxpayer’s Position

Taxpayer agrees with the revocation because they state they are no longer operating as of May
31, 20XX; at which time they filed a final Form 990 for tax year ending May 31, 20XX.
Taxpayer stated that ORG has been dissolved in 20XX and has not engaged in or received any
financial contributions since it was dissolved in 20XX.

Government’s Position

ORG’s exempt status should be revoked effective June 1, 20XX because the organization was
not operating exclusively for exempt purposes according to case law, the Code, and its
regulations as its net earnings inured to the benefit of its president, and because the organization
ceased operating.

During the examination, the IRS found that the organization’s exempt funds were being used for
the private benefit of the organization’s president. ORG’s exempt funds were used to pay for its
president’s clothing, jewelry, medical and dental expenses, credit card expenses, car payments,
loan payments, and personal house expenses. The IRS also determined that ORG’s funds were
used to make checks payable to “cash” and these checks were signed and endorsed by the
president.

In addition, ORG exempt funds were used to make loans and cash advances to a for-profit
corporation owned and controlled by the president of ORG. The loans and cash advances were
made at 0% interest and were not collateralized. ORG was unable to provide proof of repayment
for the loans and cash advances.

The payments of the president’s personal expenses were approved by the president. Other
officers and board of director members did not approve the transactions. ORG did not seek
correction of the transactions.

According to Treas. Reg. § 1.501(c)(3)-1(d)(1)(ii), an organization is not organized or operated
exclusively for one or more exempt purposes when its net earnings inure in whole or part to the
benefit of private shareholders or individuals. In addition, ORG stated that the organization is no
longer operating. ORG filed a final Form 990 for tax year ending May 31, 20XX.

On the issue of the retroactivity of the IRS's determination, ORG operated in a manner that was
different from what it represented to the IRS in its application, Articles of Incorporation, By-
Laws and Forms 990 wherein ORG asserts it operates for tax exempt purposes and in accordance
with section 501(c)(3). A section 501(c)(3) organization may not allow its net earnings to inure
to the benefit of any one individual or shareholder. Treas. Reg. § 1.501(c)(3)-1(d)(1)(i). Despite

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service

Page: -17-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX

these representations, ORG did not have any withdrawal or check-writing limitations imposed on
its president, or a method of review for the above-described payments such as an overseeing
board of directors, and regular board meetings. Without such procedures in place, inurement
occurred between ORG and its president. As such, the IRS’s determination to revoke

. retroactively is appropriate.

For these reasons, the exempt status of ORG should be revoked effective June 1, 20XX.

ORG is responsible for filing Forms 1120.

Conclusion

ORG’ 501(c)(3) tax exempt status should be revoked effective June 1, 20XX because the
organization was not operating exclusively for tax exempt purposes, its net earnings inured to the
benefit of its president, and the organization no longer operates, as demonstrated above.

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -18-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX
Table 1

Expenses paid by ORG directly on the president’s behalf per calendar year

Tax Year Ending: 12/31/20XX 12/31/20XX 12/31/20XX 12/31/20XX

Lawn Care (For service at president's personal residence): $0.00 $0.00 $315.00 $50.00
Car Dealership, Inc.: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Blank (Endorsed by president): $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Cash (Endorsed by president): $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Lawn Care-2 (For service at president's personal residence): $0.00 $0.00 $0.00 $0.00
Doctor (for president’s medical expenses): $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Doctor (For president’s medical expenses): $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Individual (For service at president's personal residence): $0.00 $0.00 $0.00 $0.00
Finance Company: $0.00 $0.00 $0.00 $0.00
Lake & Pond Maintenance (For service at president's personal residence): $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Mayors: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Professional Termite and Pest (for service at president's personal residence): $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00

Form 886-A (Rev.4-68)

Department of the Treasury - Internal Revenue Service

Page: -19-

Form 886A Department of the Treasury - Internal Revenue Service Schedule No. or
Explanation of Items Exhibit
Name of Taxpayer Year/Period Ended
ORG Form: 990 5/31/20XX,
5/31/20XX,
5/31/20XX
Tailors: $0.00 $0.00 $0.00 $0.00
[redacted]: $0.00 $0.00 $0.00 $0.00
Pool Service (for service at president's personal residence): $0.00 $0.00 $0.00 $0.00
[President]: $0.00 $0.00 $0.00 $0.00
Total Direct Payments received by the president from ORG per year: $0.00 $0.00 $0.00 $0.00

Form 886-A (Rev.4-68) Department of the Treasury - Internal Revenue Service
Page: -20-