Missing records and private inurement end charitable exemption

View official IRS release (PDF)

Plain-English summary

The IRS revoked a charitable organization's exemption effective January 1, 2012. The organization did not provide records needed to verify its activities, receipts, expenditures, or continued operation for exempt purposes. Bank records showed payments, transfers, cash withdrawals, and purchases that appeared to benefit the founder and other disqualified persons, while the organization supplied no adequate receipts or business-purpose documentation. The examination report also identified unreported compensation and personal purchases, including food, dining, vehicle costs, furniture, books, and a timeshare. The IRS concluded that the organization's earnings and assets inured to private individuals and that it failed both the operational test under IRC § 501(c)(3) and the recordkeeping duties under IRC §§ 6001 and 6033.

Ruling snapshot

• Question: Did the organization continue to qualify under section 501(c)(3) when it failed to substantiate its activities and used assets for private benefit?
• Outcome: Revoked effective January 1, 2012
• Key authorities: IRC §§ 501(c)(3), 4958, 6001, and 6033; Treas. Reg. §§ 1.501(c)(3)-1 and 1.6001-1; Rev. Rul. 59-95; Better Business Bureau of Washington, D.C., Inc. v. United States

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
TEGE:EO Examinations
1100 Commerce Street, MC 4920 DAL
Dallas, TX 75242

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

Date: April 6, 2016
Number: 201630017
Release Date: 7/22/2016

Person to Contact:
Identification Number:

Contact Telephone Number:

UIL Code: 501.03-00 EIN:

CERTIFIED MAIL — Return Receipt Requested

Dear

This is a final determination that your exempt status under section 501(c)(3) of the
Internal Revenue Code is revoked. Recognition of your exemption under Internal
Revenue Code section 501(c)(3) is revoked effective January 1, 2012 for the following
reasons:

You have failed to produce documents to establish that you are
operated exclusively for exempt purposes within the meaning of
Internal Revenue Code section 501(c)(3), and that no part of your

net earnings inure to the benefit of private shareholders or

individuals. You failed to respond to repeated reasonable requests

to allow the Internal Revenue Service to examine your records
regarding your receipts, expenditures, or activities as required by
I.R.C. sections 6001, 6033(a)(1) and Rev. Rul. 59-95, 1959-1 C.B. 627.

As such, you failed to meet the requirements of I.R.C. section 501(c)(3) and
Treasury Regulation Section 1.501(c)(3)-1(a)(1) in that you failed to establish
that you are operated exclusively for exempt purposes within the meaning of
Internal Revenue Code section 501(c)(3).

Contributions to your organization are no longer deductible under section 170 of the
Internal Revenue Code, effective January 1, 2012.

You are required to file Federal income tax returns on Form 1120. These returns
should be filed with the appropriate Service Center for the year ending December 31,
, and for all subsequent years.

Processing of income tax returns and assessment of any taxes due will not be delayed
should a petition for declaratory judgment be filed under section 7428 of the Internal

Revenue Code.

If you decide to contest this determination in court, you must initiate a suit for
declaratory judgment in the United States Tax Court, the United States Claim Court
or the District Court of the United States for the District of Columbia before the 91st
day after the date this determination was mailed to you. Contact the clerk of the
appropriate court for the rules for initiating suits for declaratory judgment. Please
contact the clerk of the respective court for rules and the appropriate forms
regarding filing petitions for declaratory judgment by referring to the enclosed
Publication 892. Please note that the United States Tax Court is the only one of
these courts where a declaratory judgment action can be pursued without the
services of a lawyer. You may write to the courts at the following addresses:

United States Tax Court
400 Second Street, NW
Washington, DC 20217

US Court of Federal Claims
717 Madison Place, NW
Washington, DC 20005

U.S. District Court for the District of Columbia
333 Constitution Ave., N.W.
Washington, DC 20001

The Taxpayer Advocate Service (TAS) is an independent organization within
the IRS that can help protect your taxpayer rights. We 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 our assistance, which is
always free, we will do everything possible to help you.

Visit taxpayeradvocate.irs.gov or call 1-877-777-4778.

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

Sincerely yours,

Enclosures: Paul A. Marmolejo
Publication 892 Acting Director, EO Examinations
Envelope

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

Exempt Organizations: Examinations

1555 Poydras Street, Stop 17 Date: January 13, 2016

New Orleans, LA 70112

Taxpayer Identification Number:
Form:

Tax Year(s) Ended:

Person to Contact/iD Number:

Contact Numbers:
Manager’s name/ID number:

Manager’s contact number:

Response due date:

Certified Mail — Return Receipt Requested
Dear

Why you are receiving this letter

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

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

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 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.

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

Thank you for your cooperation.

Sincerely,

/for/
Margaret Von Lienen
Director, EO Examinations

Enclosures:

Report of Examination
Form 6018
Publication 892
Publication 3498

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

Form 886-A Schedule number or exhibit

(Rev, January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number | Year/Period ended
December 31, 20XX
December 31, 20XX

Issue:

Whether qualifies for exemption under Section 501(c)(3) of the

Internal Revenue Code.

Whether direct payments to in the amount of $ for 20XX

and $ for 20XX were unreported compensation and constitutes

inurement within the meaning of I.R.C. section 501(c)(3).

Whether payments to in the amount of $ for
20XX and $ for 20XX were unreported compensation that constitutes

inurement within the meaning of i.R.C. section 501(c)(3).

Whether purchases by check or debit card in the amount of $ for 20XX and
$ for 20XX were personal in nature and constitutes inurement within the

meaning of I.R.C. section 501(c)(3).

Facts:

was duly incorporated under the laws of the State of
pursuant to the on August 4, 19XX.
On January 30, 20XX applied for exemption with the Internal

Revenue Service.

On May 1, 20XX was granted exemption by the Internal
Revenue Service.

According to the Articles of Incorporation, the name and address of the incorporator
is at

According to the State of ; owned
and is spouse of

According to the State of , owns

filed the Form 990 for 20XX but didn't file the 20XX return.
• Form 990 for year ending December 31, 20XX:
◦ Part IV Checklist of Required Schedules.
▪ Line 25a Section 501(c)(3) and 501(c)(4) organizations.
• Did the organization engage in an excess benefit transaction with a
disqualified person during the year?

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev, January 1994) EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number | Year/Period ended
December 31, 20XX
December 31, 20XX
fe) stated “No”.

▪ Line 25b (Is the organization aware that it engaged in an excess benefit

transaction.....).

▪ stated “No”.

▪ Line 26 (Was a loan to or by a current or former officer, director, trustee,

key employee, highly compensated employee, or disqualified person
outstanding as of the end of the organization’s tax year? If “Yes,” complete
Schedule L’ Part If).

▪ stated “No”.

" didn’t file a Schedule L.

◦ Part VI Section A (Governing Body and Management)

▪ Line 1A (Enter the number of voting members of the governing body at the

end of the tax year), stated .

◦ Part VII Section A (Officers, Directors, Trustees, Key Employees, and Highest

Compensated Employees.

▪ included as Founder an Officer

and Key Employee, with reported $ compensation.
▪ didn’t include compensation for related organizations.

◦ Part VIII Statement of Revenue.
▪ Line 1a — 1f (Contributions, gifts, grants, and similar amounts).

▪ reported $ in grants from two non-

related organizations.

◦ Part IX Statement of Functional Expenses.
▪ Line 2 (Grants and other assistance to individuals in the US) is blank.
▪ Line 5 (Compensation of current officers, directors, trustees, and key
employees) is blank.
◦ Schedule A Public Charity Status and Public Support.
▪ Part | Reason for Public Charity Status.

• Line 7 (An organization that normally receives a substantial part of its
support from a governmental unit or from the general public described
in Section 170(b)(1)(A)(vi) (Complete Part Il)) was checked.

▪ Part Il Support Schedule for Organizations Described in Sections

170(b)(1)(A)(iv) and 170(b)(1)(A)(vi).

• didn’t complete Part Il.

◦ Schedule D Supplemental Financial Statements.
▪ Part VI Investments — Land, Buildings, and Equipment.

• Line 1b (Building) was filled in.

According to the Form 1023 application is a program to provide
high quality, structured, innovative educational programs for inner city students in low
income housing. stemmed from an earlier community based
education initiative, the , which was developed and led by student activist

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev. January 1994) EXPLANATIONS OF ITEMS

Name of taxpayer Tax Identification Number | Year/Period ended
December 31, 20XX
December 31, 20XX

, a former resident of the and recent graduate of . This
grass-root, student run operation is centrally located in the in

and stands as a testament of true initiative by college students willing to give back to
a community. While serving, student volunteers receive training from experts in the
field and can grow personally and professionally from gaining knowledge and skills
via many community base workshops.

• However, has ceased operations.

According to the bank statements, made payments

to from January 9, 20XX through August 1, 20XX (see Schedule

A).

▪ issued the Form W-2 to in the amount of $

in 20XX and $ in 20XX.

▪ made payments of $ in 20XX and $ in

▪ hasn't provided receipts for the payments to

According to the bank statements, made

payments/transfers to from January 9, 20XX through April 29,

20XX (see Schedule B).

• made payment of $ in 20XX and $ in 20XX.

▪ hasn’t provided documentation show business purpose of these

payments.

According to the bank statements, made

payments to on December 10 and 11, 20XX (see Schedule C).

▪ made payments of $ in 20XX.

▪ hasn't provided documentation show business purpose of these

payments.

According to the bank statements, wrote checks,

made debit card purchases, and withdrew cash that appear personal in nature from
January 3, 20XX through October 16, 20XX (see Schedule D).

▪ made purchases of $ in 20XX and $ in

20XX.

• These purchases included food, dining out, parking while eating out, gas, vehicle
repair, furniture, books, and a timeshare (vacation) that appear personal in nature.

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev. January 1994) EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number | Year/Period ended

December 31, 20XX
December 31, 20XX

• These purchases weren't reported as income.
▪ hasn't provided receipts for the purchases made.

When asked for receipts, provided “Lost Receipt Affidavit”
statements for all receipt requested in Information Document Request # 3 stating that
the receipts were lost. These affidavits weren't signed or approved expenses.

LAW

Section 1.501(c)(3)-1(a) of the regulations states that an organization 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 test or the
operational test, it is not exempt.

Income Tax Regulation ("Regulation") section 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.

Regulation section 1.501(c)(3)-1(d)(1)(ii) provides that an organization is not
organized or operated exclusively for one or more of the purposes specified in
subdivision (i) of this subparagraph unless it serves a public rather than a private
interest. Thus, to meet the requirement of this subdivision, it is necessary for an
organization to establish that it is not organized or operated for the benefit of private
interests such as designated individuals, the creator or his family, shareholders of the
organization, or persons controlled, directly or indirectly, by such private interests.

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.

Section 3121(a) of the Code, states that for purposes of this chapter, the term “wages”
means all remuneration for employment, including the cash value of all remuneration
(including benefits) paid in any medium other than cash; except that such term shall not
include.

Section 4958(c)(1)(A) of the Code, states the term “excess benefit transaction” means
any transaction in which an economic benefit is provided by an applicable tax-exempt
organization directly or indirectly to or for the use of any disqualified person if the value
of the economic benefit provided exceeds the value of the consideration (including the

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev. January 1994) EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number | Year/Period ended

December 31, 20XX
December 31, 20XX

performance of services) received for providing such benefit. For purposes of the
preceding sentence, an economic benefit shall not be treated as consideration for the
performance of services unless such organization clearly indicated its intent to so treat
such benefit.

Section 4958(f)(1)(A) of the Code, states the term “disqualified person” means, with
respect to any transaction— any person who was, at any time during the 5-year period
ending on the date of such transaction, in a position to exercise substantial influence
over the affairs of the organization.

Section 4958(f)(1)(B) of the Code states the term “disqualified person” means, with respect
to any transaction— a member of the family of an individual described in subparagraph

(A).

Section 1.62-2(c)(1) of the Code states for purposes of sections 1.62-1, 1.62-1T, and
1.62-2, the phrase “reimbursement or other expense allowance arrangement” means an
arrangement that meets the requirements of paragraphs (d) (business connection, (e)
(substantiation), and (f) (returning amounts in excess of expenses) of this section. A
payor may have more than one arrangement with respect to a particular employee,
depending on the facts and circumstances. See paragraph (d)(2) of this section (payor
treated as having two arrangements under certain circumstances).

Section 1.62-2(d)(1) of the Code states in part, except as provided in paragraphs (d)(2)
and (d)(3) of this section, an arrangement meets the requirements of this paragraph (d)
if it provides advances, allowances (including per diem allowances, allowances only for
meals and incidental expenses, and mileage allowances), or reimbursements only for
business expenses that are allowable as deductions by part VI (section 161 and the
following), subchapter B, chapter 1 of the Code, and that are paid or incurred by the
employee in connection with the performance of services as an employee of the
employer. The payment may be actually received from the employer, its agent, or a third
party for whom the employee performs a service as an employee of the employer, and
may include amounts charged directly or indirectly to the payor through credit card
systems or otherwise.

Section 1.62-2(e)(1) of the Code states, an arrangement meets the requirements of this
paragraph (e) if it requires each business expense to be substantiated to the payor in
accordance with paragraph (e)(2) or (e)(3) of this section, whichever is applicable,
within a reasonable period of time. See section 1.274-5T or section 1.162-17.

Section 1.62-2(e)(2) of the Code states, an arrangement that reimburses travel,
entertainment, use of a passenger automobile or other listed property, or other business
expenses governed by section 274(d) meets the requirements of this paragraph (e)(2) if

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev. January 1994) EXPLANATIONS OF ITEMS
Name of taxpayer . Tax Identification Number | Year/Period ended

December 31, 20XX
December 31, 20XX

information sufficient to satisfy the substantiation requirements of section 274(d) and the
regulations thereunder is submitted to the payor. See section 1.274-5. Under section
274(d), information sufficient to substantiate the requisite elements of each expenditure
or use must be submitted to the payor. For example, with respect to travel away from
home, section 1.274-5(b)(2) requires that information sufficient to substantiate the
amount, time, place, and business purpose of the expense must be submitted to the
payor. Similarly, with respect to use of a passenger automobile or other listed property,
section 1.274-5(b)(6) requires that information sufficient to substantiate the amount,
time, use, and business purpose of the expense must be submitted to the payor. See
sections 1.274-5(g) and 1.275-(j), which grant the Commissioner the authority to
establish optional methods of substantiating certain expenses. Substantiation of the
amount of a business expense in accordance with rules prescribed pursuant to the
authority granted by sections 1.274-5(g) or 1.274-5(j) will be treated as substantiation of
the amount of such expense for purposes of this section.

Section 1.274-2(a)(2)(i) of the Code states, expenditures paid or incurred after December 31,
1978, and not with respect to a club. Except as provided in this section with respect to a club, no
deduction otherwise allowable under chapter 1 of the Code shall be allowed for any expenditure
paid or incurred after December 31, 1978, with respect to a facility used in connection with
entertainment.

Section 1.274-5(f)(4)(i) of the Code states, in general. For purposes of this paragraph (f)
an adequate accounting means the submission to the employer of an account book,
diary, log, statement of expense, trip sheet, or similar record maintained by the
employee in which the information as to each element of an expenditure or use
(described in paragraph (b) of this section) is recorded at or near the time of the
expenditure or use, together with supporting documentary evidence, in a manner that
conforms to all the adequate records requirements of paragraph (c)(2) of this section.
An adequate accounting requires that the employee account for all amounts received
from the employer during the taxable year as advances, reimbursements, or allowances
(including those charged directly or indirectly to the employer through credit cards or
otherwise) for travel, entertainment, gifts, and the use of listed property. The methods of
substantiation allowed under paragraph (c)(4) or (c)(5) of this section also will be
considered to be an adequate accounting if the employer accepts an employee's
substantiation and establishes that such substantiation meets the requirements of
paragraph (c)(4) or (c)(5). For purposes of an adequate accounting, the method of
substantiation allowed under paragraph (c)(3) of this section will not be permitted.

Section 6001 of the Code state that, every person liable for any tax imposed by this title, or for
the collection thereof, shall keep such records, render such statements, make such returns, and
comply with such rules and regulations as the Secretary may from time to time prescribe.
Whenever in the judgment of the Secretary it is necessary, he may require any person, by notice

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev. January 1994) EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number | Year/Period ended

December 31, 20XX
December 31, 20XX

served upon such person or by regulations, to make such returns, render such statements, or keep
such records, as the Secretary deems sufficient to show whether or not such person is liable for
tax under this title. The only records which an employer shall be required to keep under this
section in connection with charged tips shall be charge receipts, records necessary to comply
with section 6053(c), and copies of statements furnished by employees under section 6053(a).

Section 1.6001-1(a) of the Regulations state, except as provided in paragraph (b) of this
section, any person subject to tax under subtitle A of the Code (including a qualified
State individual income tax which is treated pursuant to section 6361(a) as if it were
imposed by chapter 1 of subtitle A), or any person required to file a return of information
with respect to income, shall keep such permanent books of account or records,
including inventories, as are sufficient to establish the amount of gross income,
deductions, credits, or other matters required to be shown by such person in any return
of such tax or information.

Section 1.6001-1(c) of the Regulations state, 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 sections 1.6033-1 through 1.6033-3.

Current Activities:

• was incorporated by .
◦ At the time of incorporation also owned and operated. other

for-profit businesses:

i“
a

: “ n

◦ The majority of the decisions made for were done by

During the initial interview stated that has
ceased operating, but in 20XX the organization conducted childcare and educational

activities. However, no activities could be verified.

Taxpayer’s Position:

has 30 days to respond to the examination determination if
they don’t agree.

Form 886-A (1-1994) Catalog Number 20810W Page ___ publish.no.irs.gov Department of the Treasury-Internal Revenue Service

Form 886-A Schedule number or exhibit
(Rev, January 1994) EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number | Year/Period ended

December 31, 20XX
December 31, 20XX

hasn't responded about inurement and has thirty (30)
days to respond.

Government’s Position:

isn’t operated exclusively for charitable, educational, or
religious purposes consistent with I.R.C. section 501(c)(3) of the Code nor section
1.501(c)(3)-1(a) of the Income Tax Regulations and therefore fails to meet the
operational test. Specifically, the facts above indicate that they didn’t operate
exclusively for exempt purposes but assets were used to inure to the benefit of

doesn’t meet the operational test due to their earnings inure in

whole or in part to the benefit of the founder of the organization.
That is a disqualified person under I.R.C. section 4958.

That the payments and purchases made to:

• direct payments to

▪ payments to

• payments to ;

▪ purchases by checks, debit cards, and cash.

are inurement and . was the recipients of the inurement.

That isn’t exempt from Federal Income Tax under I.R.C.

section 501(c)(3) due to inurement.

Form 1120 has to be filed by the organization for year ended December 31, 20XX
and all subsequent years.

Conclusion:

allowed the organization’s assets to be used by
a disqualified person.

personal use of assets constitutes inurement and is
grounds for revocation of exempt status under I.R.C. section 501(c)(3).

Form 886-A (1-1994) Catalog Number 20810W Page publish.no.irs.gov Department of the Treasury-Internal Revenue Service