IRS revokes a private school's 501(c)(3) exemption for failing the operational and recordkeeping tests

Plain-English summary

This is a final IRS revocation letter (Letter 6337) ending a private religious school's tax-exempt status under § 501(c)(3), along with the audit report (Form 886-A) that explains why. The school had stopped operating and could not show it was actually run for exempt purposes: it produced no admission records, no curriculum or academic calendar, and no financial records for the years under exam, saying documents were destroyed and that it never knew about recordkeeping rules. It also never publicized a racially nondiscriminatory policy in a newspaper or on its website, as private schools must under Rev. Proc. 75-50. Because the organization failed the operational test and the recordkeeping requirements of §§ 6001 and 6033, the IRS revoked the exemption. Donations to it are no longer deductible under § 170, and it must file corporate income tax returns going forward.

Ruling snapshot

• Question: Does the organization, a private school, still qualify for exemption under § 501(c)(3)?
• Outcome: Revocation; exempt status revoked and contributions no longer deductible
• Key authorities: IRC §§ 501(c)(3), 170, 6001, 6033; Treas. Reg. § 1.501(c)(3)-1; Rev. Rul. 71-447; Rev. Proc. 75-50; Rev. Proc. 2019-22

Full text (IRS public release)

Tax Exempt and Government Entities Taxpayer ID number (last 4 digits):

Exempt Organizations Examinations

Department of the Treasury Date:
Internal Revenue Service April 18, 2024
550 Main Street

[illegible]
Cincinnati, OH 45202-3222 [illegible]
Tax periods ended:
Release Number: 202428006
Release Date: 7/12/2024 Person to contact:
UIL Code: 501.03-00 Name:
ID number:
Telephone:
Fax:

Last day to file petition with United States
Tax Court: July 17, 2024

CERTIFIED MAIL - Return Receipt Requested
Dear :

Why we are sending you this letter
This is a final determination that you don’t qualify for exemption from federal income tax under Internal
Revenue Code (IRC) Section 501(a) as an organization described in IRC Section 501(c)(3), effective

. Your determination letter dated , is revoked.

Our adverse determination as to your exempt status was made for the following reasons: You have not
demonstrated that you are both organized and operated exclusively for charitable, educational, or other exempt

purposes within the meaning of IRC Section 501(c)(3). As such, you failed to meet the requirement of IRC
Section 501(c)(3) and Treasury Regulations Section 1.501(c)(3)-1(a).

Organizations that are not exempt under IRC Section 501 generally are required to file federal income tax returns
and pay tax, where applicable. For further instructions, forms and information please visit IRS.gov.

Contributions to your organization are no longer deductible under IRC Section 170.

What you must do if you disagree with this determination
If you want to contest our final determination, you have 90 days from the date this determination letter was

mailed to you to file a petition or complaint in one of the three federal courts listed below.

How to file your action for declaratory judgment
If you decide to contest this determination, you can file an action for declaratory judgment under the provisions

of Section 7428 of the Code in either:
• The United States Tax Court,
• The United States Court of Federal Claims, or
• The United States District Court for the District of Columbia

You must file a petition or complaint in one of these three courts within 90 days from the date we mailed this
determination letter to you. You can download a fillable petition or complaint form and get information about
filing at each respective court's website listed below or by contacting the Office of the Clerk of the Court at one
of the addresses below. Be sure to include a copy of this letter and any attachments and the applicable filing fee
with the petition or complaint.

Letter 6337 (Rev. 3-2024)

You can eFile your completed U.S. Tax Court petition by following the instructions and user guides available
on the Tax Court website at ustaxcourt.gov/dawson.html. You will need to register for a DAWSON account to
do so. You may also file your petition at the address below:

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

The websites of the U.S. Court of Federal Claims and the U.S. District Court for the District of Columbia contain
instructions about how to file your completed complaint electronically. You may also file your complaint at one of
the addresses below:

US Court of Federal Claims

717 Madison Place, NW

Washington, DC 20439

uscfc.uscourts.gov

US District Court for the District of Columbia
333 Constitution Avenue, NW

Washington, DC 20001

dcd.uscourts.gov

Processing of income tax returns and assessments of any taxes due will not be delayed if you file a petition for
declaratory judgment under IRC Section 7428.

We'll notify the appropriate state officials (as permitted by law) of our determination that you aren’t an
organization described in IRC Section 501(c)(3).

The IRS office whose phone number appears at the top of the notice can best address and access your tax
information and help get you answers. However, you may be eligible for free help from the Taxpayer Advocate
Service (TAS) if you can’t resolve your tax problem with the IRS or if you believe an IRS procedure just isn't
working as it should. TAS is an independent organization within the IRS that helps taxpayers and protects
taxpayer rights. Visit TaxpayerAdvocate.IRS.gov/contact-us or call 877-777-4778 (TTY/TDD 800-829-4059)
to find the location and phone number of your local advocate. Learn more about TAS and your rights under the
Taxpayer Bill of Rights at TaxpayerAdvocate.IRS.gov. Do not send your Tax Court petition to TAS. Use the
Tax Court address provided earlier in the letter. Contacting TAS does not extend the time to file a petition.

Where you can find more information
Enclosed are Publication 1, Your Rights as a Taxpayer, and Publication 594, The IRS Collection Process, for

more comprehensive information.

Find tax forms or publications by visiting IRS.gov/forms or calling 800-TAX-FORM (800-829-3676). If you
have questions, you can call the person shown at the top of this letter.

If you prefer to write, use the address shown at the top of this letter. Include your telephone number, the best
time to call, and a copy of this letter.

You may fax your documents to the fax number shown above, using either a fax machine or online fax service.
Protect yourself when sending digital data by understanding the fax service's privacy and security policies.

Letter 6337 (Rev. 3-2024)

Keep the original letter for your records.
Sincerely,
[illegible]
Lynn A. Brinkley
Director, Exempt Organizations Examinations

Enclosures:

Publication 1
Publication 594
Publication 892

Letter 6337 (Rev. 3-2024)

Department of the Treasury Date:
Internal Revenue Service 12/05/2023
Tax Exempt and Government Entities

IRS Taxpayer ID number:

Form:
Tax periods ended:

Person to contact:
Name:
ID number:
Telephone:

Fax:
Address:

Manager's contact information:
Name:

CERTIFIED MAIL — Return Receipt Requested [illegible]:
Telephone:

Response due date:

01/04/2024

Dear

Why you’re receiving this letter
We enclosed a copy of our audit report, Form 886-A, Explanation of Items, explaining that we propose to revoke
your tax-exempt status as an organization described in Internal Revenue Code (IRC) Section 501(c)(3).

If you agree

If you haven’t already, please sign the enclosed Form 6018, Consent to Proposed Action, and return it to the
contact person shown at the top of this letter. We'll issue a final adverse letter determining that you aren't an
organization described in IRC Section 501(c)(3) for the periods above.

After we issue the final adverse determination letter, we’ll announce that your organization is no longer eligible
to receive tax deductible contributions under IRC Section 170.

If you disagree

1. Request a meeting or telephone conference with the manager shown at the top of this letter.

2. Send any information you want us to consider.

3. File a protest with the IRS Appeals Office. If you request a meeting with the manager or send additional
   information as stated in 1 and 2, above, you’ll still be able to file a protest with IRS Appeals Office after
   the meeting or after we consider the information.

The IRS Appeals Office is independent of the Exempt Organizations division and resolves most disputes
informally. If you file a protest, the auditing agent may ask you to sign a consent to extend the period of
limitations for assessing tax. This is to allow the IRS Appeals Office enough time to consider your case.
For your protest to be valid, it must contain certain specific information, including a statement of the
facts, applicable law, and arguments in support of your position. For specific information needed for a
valid protest, refer to Publication 892, How to Appeal an IRS Determination on Tax-Exempt Status.

Fast Track Mediation (FTM) referred to in Publication 3498, The Examination Process, generally doesn’t
apply now that we’ve issued this letter.

Letter 3618 (Rev. 8-2019)

4. Request technical advice from the Office of Associate Chief Counsel (Tax Exempt Government Entities)
   if you feel the issue hasn’t been addressed in published precedent or has been treated inconsistently by the
   IRS.

If you’re considering requesting technical advice, contact the person shown at the top of this letter. If you
disagree with the technical advice decision, you will be able to appeal to the IRS Appeals Office, as
explained above. A decision made in a technical advice memorandum, however, generally is final and
binding on Appeals.

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

adverse determination letter.

Contacting the Taxpayer Advocate Office is a taxpayer right
The Taxpayer Advocate Service (TAS) is an independent organization within the IRS that can help protect your

taxpayer rights. TAS 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 TAS assistance, which is always free, TAS
will do everything possible to help you. Visit www.taxpayeradvocate.irs.gov or call 877-777-4778.

Additional information
You can get any of the forms and publications mentioned in this letter by visiting our website at

www.irs.gov/forms-pubs or by calling 800-TAX-FORM (800-829-3676).
If you have questions, you can contact the person shown at the top of this letter.

Sincerely,

[illegible] Navi Mishra, Acting Group Manager
(for) Lynn A. Brinkley
Director, Exempt Organizations Examinations

Enclosures:
Form 886-A
Form 6018

Letter 3618 (Rev. 8-2019)

Department of the Treasury - Internal Revenue Service Schedule number or exhibit
Form 886-A Explanation of Items
(Rev. May 2017)
Name of Taxpayer Tax Identification Number (last 4 digits) | Year/Period Ended
ISSUES:
1) Whether the primary activities of (“the organization”) accomplish its

exempt purposes so that the organization meets the operational test outlined in section 1.501(c)(3)-1(a)(1) of
the regulations?

2) Whether the organization continues to qualify for exemption under section 501(c)(3) of the Internal Revenue
Code (“the Code”)?

FACTS:

The organization was incorporated in the state of in . The organization states in its Articles of
Incorporation filed with that it is organized and operated exclusively for religious purposes
within the meaning of section 501(c)(3) of the Code. Ruling was issued in for the tax-exempt status under

section 501(c)(3) and public charity status under section 170(b)(1)(A)(ii) of the Code. To date, this determination has
not been changed.

is the founder of the organization. is shown as “Incorporator” in the organization’s Articles of
Incorporation and “President” on its application for recognition of exemption Form 1023.

The organization’s racially nondiscriminatory policy was included in its by-laws provided as an attachment to the Form
1023 application. Page 15 of Form 1023 states the organization will advertise its nondiscriminatory policy in the
newspapers.

The organization filed Forms 990-EZ for tax years under exam. , is the only individual
listed in Parts IV of the returns. The organization’s mission or most significant activities as stated on its most recently
filed Form 990 which is for the tax year ended , is “education.”

The organization checks Box 2 of Schedule A Part I, “A school described in section 170(b)(1)(A)(ii)” on all the Forms
990 and 990EZ filed.

All Schedules E of the organization’s recently filed Forms 990 and 990-EZ state that it did not publicize its racially
nondiscriminatory policy. Explanation to not publicizing the policy as stated in Part II Sch E on each year's return is,

The organization’s purpose posted on its website “ ” reads, “
” The following statement is also posted on the website, “

referred to him as the school during initial phone call on . Stated that
is and that both serve on the school’s board.
Part of Information Document Request #1 dated , requests copies of the following records and information

covering the tax year ended .
• Current brochures, catalogues, and any other written advertisements dealing with student admissions,
programs, and scholarships.
• Statistical data on the racial and ethnic composition of students and staff.

Catalog Number 20810W www.irs.gov Form 886-A (Rev. 5-2017)
Page 1 of 6

Department of the Treasury - Internal Revenue Service Schedule number or exhibit
Form 886-A Explanation of Items
(Rev. May 2017)
Name of Taxpayer Tax Identification Number (last 4 digits) | Year/Period Ended

• Correspondence files relating to fund solicitations, contributions received, acceptance and rejection of
students, and denial or approval of scholarships, loans, or other student aid.

responded to the above in his email dated , stating there was no information to provide
because there were no students due to
The examiner then requested the same information covering the period immediately before started.
response in the email dated , was as follows.

[illegible]

“ Current brochures, catalogues, and any other written advertisements dealing with student admissions,
programs, and scholarships.
a response — A copy of school catalog is attached.
“ Statistical data on the racial and ethnic composition of students and staff immediately before

a response - Students: ; Staff:
Correspondence files relating to fund solicitations, contributions received, acceptance and rejection of
students, and denial or approval of scholarships, loans, or other student aid immediately before

response - N/A - Files and paperwork got destroyed
The school catalog provided does not contain a date. The school committee listed indicates
During the interview conducted over the phone in as well as during follow-up conversations,

provided the following in response to the examiner’s inquiries.
• The school has been closed since the beginning of
• The school's activities are expected to resume likely in

• The occurred on a in . All documents and some furniture

• had the check writing authority.

• made all the bank deposits and was the only person who recorded all financial transactions in a
paper notebook. No one reviewed the bank reconciliations.

• At the end of the year, would hand the paper notebook or copy of note pages to the outside CPA
who would prepare the Form 990EZ return.

• did not know about the requirement to publicize the school’s racially nondiscriminatory
policy but would comply going forward by asking the person who’s in charge of the school’s website.

• response to the examiner’s inquiry on why tuition revenue and expenses were reported

on the Form 990EZ return during the time there were no students was, “

”

• The school is situated inside . The owns the building and lets the
school use a portion of the property for free. The was established a long time ago. Both the and
the school have the same purpose.

The exam was then expanded to include the tax year ended . Information Document Request #2
issued on , requests the standard books and records regarding the expanded tax year. Part of Information
Document Request #3 issued on , requests the following.

• Documentation that supports that the organization had a primary function of presenting formal instruction,
maintained a regular faculty of qualified teachers and a regularly scheduled curriculum including academic

Catalog Number 20810W www.irs.gov Form 886-A (Rev. 5-2017)
Page 2 of 6

Department of the Treasury - Internal Revenue Service Schedule number or exhibit
Form 886-A Explanation of Items
(Rev. May 2017)
Name of Taxpayer Tax Identification Number (last 4 digits) | Year/Period Ended
calendar, had a regularly enrolled body of students, and had an admission policy . This is
to determine whether the organization was operated exclusively for its exempt purposes
• Deposit records, check copies, and invoices related to tuition fees received in the amounts of $ and
$ for the tax years ended , and respectively.
• Invoices related to advertising and promotion expenses in the amounts of $ and $ for the tax
years ended , and respectively.
• Invoices related to professorship expenses incurred in the amounts of $ and $ for the tax years
ended , and respectively.
On : called and introduced who’s a member of
stated that is very knowledgeable about how the school operates

and that would be helping them to provide information to the examiner because

In response to Information Document Request #3, provided the following on behalf.

• 9 pages of what appear to be scanned images of a book. The document contains lists of certain Humanities,
Social and Behavioral Sciences, and Physical and Biological Sciences courses, a list of Prerequisite General
Studies Courses (in Biblical Studies) for All Concentrations, a list of resident faculties, and a list of visiting
faculties. It is stated on one of the pages, “

” The document does not provide any dates about the academic periods
the information covers.

• Explanations for not keeping any substantiating documents related to revenue and expenses: the organization
did not know the requirement to maintain records.

During the closing conference conducted on stated the following.
• They were not aware of the record keeping requirements because the CPA who prepared the returns never
told them.

• They need time to gather information to prove that the organization was operated as a school
and to show that the organization has a plan for future operations.

LAW:

Section 501(c)(3) of the Code provides for the recognition of exemption of organizations organized and operated
exclusively for religious, educational, or other charitable purposes, and no part of the net earnings of which inures to
the benefit of any private shareholder or individual.

Section 1.501(c)(3)-1(a)(1) of the Treasury regulations states that, to be exempt as an organization described in
Section 501(c)(3) of the Code, 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.

Section 1.501(c)(3)-1(c) of the regulations describes the operational test requirements for exemption under Section
501(c)(3) of the Code. The operational test focuses on how the organization is actually operated, regardless of
whether it is properly organized for tax-exempt purposes.

Section 1.501(c)(3)-1(c)(1) of the regulations provides that an organization will be regarded as operated exclusively for
one or more exempt purposes only if it engages primarily in activities which accomplish one or more of such exempt
purposes specified in Section 501(c)(3) of the Code. It further provides that an organization will not be so regarded if
more than an insubstantial part of its activities is not in furtherance of an exempt purpose.

Catalog Number 20810W www.irs.gov Form 886-A (Rev. 5-2017)
Page 3 of 6

Department of the Treasury - Internal Revenue Service Schedule number or exhibit
Form 886-A Explanation of Items
(Rev. May 2017)
Name of Taxpayer Tax Identification Number (last 4 digits) | Year/Period Ended

Section 1.501(c)(3)-1(d)(1)(ii) of the regulations provides that an organization is not organized or operated for one or
more exempt purposes unless it serves a public rather than a private interest. 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, shareholders, or persons controlled, directly or indirectly, by such private interests.

Section 511 of the Code imposes a tax at corporate rates under Section 11 of the Code on the unrelated business
taxable income of certain tax-exempt organizations including those described in Section 501(c) of the Code.

Section 6001 of the Code provides, in part, that every person liable for any tax imposed by the Code, 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.

Section 1.6001-1(e) of the regulations provides 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.

Section 6033(a)(1) of the Code provides, in general, that every organization exempt under Section 501(a) of the Code
shall file an annual return, stating specifically the items of gross income, receipts, and disbursements, and such other
information for the purpose of carrying out the Internal Revenue laws as the Secretary may by forms of regulations
prescribe, and shall 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.

Section 1.6033-2(i)(2) of the regulations provides that every organization which is exempt from tax, whether or not it is
required to file an annual information return, shall submit such additional information as may be required by the
Internal Revenue Service for the purpose of inquiring into its exempt status and administering the provisions of
subchapter F (section 501 and following), chapter 1 of subtitle A of the Code and section 6033.

Revenue Rulings 71-447 provides that a school that does not have a racially nondiscriminatory policy as to students
does not qualify as an organization exempt from federal income tax and that a school must show affirmatively both that
is has adopted a racially nondiscriminatory policy as to students that is made known to the general public and that
since the adoption of that policy it has operated in a bona fide manner in accordance therewith.

Revenue Procedure 75-50, 1975-2 C.B. 587 sets forth guidelines and recordkeeping requirements for determining
whether exempt private schools have racially nondiscriminatory policies as to students.
Section 2.02 provides that a school must show affirmatively both that it has adopted a racially nondiscriminatory policy
as to students that is made known to the general public and that since the adoption of that policy the school has
operated in accordance therewith.
Section 4.03 provides that a school must make its racially nondiscriminatory policy known to all segments of the
general community served by the school. A private school must use one of the two methods to satisfy the requirement:
(a) publishing a notice of the racially nondiscriminatory policy in a newspaper of general circulation serving all racial
segments of the community at least once annually, or (b) using broadcast media to publicize its racially
nondiscriminatory policy if this use makes such policy known to all segments of the general community the school
serves. If this method is chosen, the school must provide documentation that the means by which this policy was
communicated to all segments of the general community was reasonably expected to be effective.
Section 7.01 provides that a school must maintain for a minimum period of three years, beginning with the year after
the year of compilation or acquisition, the following records for the use of the Service on proper request:
1) Records indicating the racial composition of the student body, faculty, and administrative staff for each
academic year.
2) Records sufficient to document that scholarship and other financial assistance is awarded on a racially
nondiscriminatory basis.

Catalog Number 20810W www.irs.gov Form 886-A (Rev. 5-2017)
Page 4 of 6

Department of the Treasury - Internal Revenue Service Schedule number or exhibit
Form 886-A Explanation of Items
(Rev. May 2017)
Name of Taxpayer Tax Identification Number (last 4 digits) | Year/Period Ended

3) Copies of all brochures, catalogues, and advertising dealing with student admissions, programs, and
scholarships. Schools advertising nationally or in a large geographic segment or segments of the United
States need only maintain a record sufficient to indicate when and in what publications their advertisements
were placed.
4) Copies of all materials used by or on behalf of the school to solicit contributions.
Section 7.04 provides that failure to maintain or to produce upon the proper request the required records and
information will create a presumption that the organization has failed to comply with these guidelines.

Revenue Procedure 2019-22 modifies Revenue Procedure 75-50 to reflect technological advances since its
publication and provides a third method for a private school to satisfy the requirement by using its internet website to
publicize the school's racially nondiscriminatory policy as to students.

TAXPAYER’S POSITION:

Taxpayer contends that the organization was operating as a school and there is a plan to
resume activities in

GOVERNMENT’S POSITION:

Issue #1:

The organization does not meet the operational test under section 501(c)(3) of the Code and section 1.501(c)(3)-
1(a)(1) of the regulations because it is not operated exclusively for one or more exempt purposes as required under
section 1.501(c)(3)-1(c)(1) of the regulations. The organization is not operated exclusively for one or more exempt
purposes because it failed to demonstrate that it engages in activities which accomplish one or more of such exempt
purposes specified in section 501(c)(3) of the Code.

The organization contends that since there have been no school activities. But the organization
failed to provide any information that indicates that it was operated for its exempt purposes as a school
. The organization provided the racial and ethnic composition of students immediately before
but did not provide any documents relating to acceptance and rejection of students and denial or approval of
scholarships. The organization also did not provide documentation that supports that it had a primary function of
presenting formal instruction and a regularly scheduled curriculum, academic calendar, had a regularly enrolled body

of students, and had an admission policy . The organization’s statement about all documents
being destroyed should not apply to the tax years under exam and immediately
because the . We are not able to determine that the organization was operated for its exempt

purposes as a school by merely reviewing a list of courses and a list of faculties.

The organization contends that it had a plan to resume school activities in but failed to provide any information
that indicates a plan that has a primary function of presenting formal instruction and a regularly scheduled curriculum,
academic calendar, estimated regularly enrolled body of students, and an admission policy.

Additionally, the organization failed to meet the requirement described in Section 4.03 of Revenue Procedure 75-50,
1975-2 C.B. 587 because it did not publicize annually its racially nondiscriminatory policy in a newspaper or on its
website. The organization also failed to meet the recordkeeping requirements outlined in Section 7.01 for Revenue
Procedure 75-50 1975-2 C.B. 587 because it did not maintain any of the following: records indicating the racial
composition of the student body, faculty, and administrative staff for each academic year; records sufficient to
document that scholarship and other financial assistance is awarded on a racially nondiscriminatory basis; and copies
of all brochures, catalogues, and advertising dealing with student admissions, programs, and scholarships. Merely

Catalog Number 20810W www.irs.gov Form 886-A (Rev. 5-2017)
Page 5 of 6

Department of the Treasury - Internal Revenue Service Schedule number or exhibit
Form 886-A Explanation of Items
(Rev. May 2017)
Name of Taxpayer Tax Identification Number (last 4 digits) | Year/Period Ended

providing the racial composition of the student body and administrative staff without substantiating documentation does
not satisfy this requirement.

Furthermore, the organization failed to meet the record keeping requirements under section 6033 of the Code and
section 1.6033-1(i)(2) of the regulations by not providing the records such as invoices and receipts related to its
revenue and expenses. Such records are required to determine if the organization was in fact operated for exempt
purposes.

Issue #2:
The organization does not continue to qualify for exemption under Section 501(c)(3) of the Code because it does not
meet the operational test outlined in section 1.501(c)(3)-1(a)(1) of the regulations.

All the pertinent facts and circumstances above lead us to conclude that the organization has failed to meet the
conditions required for the continuation of exempt status as described in section 1.501(c)(3)-1(c)(1) of the regulations.

CONCLUSION:

It is the Internal Revenue Service's position that the organization ceases to qualify as an organization described in
section 501(c)(3) of the Code. The organization, a private school, has failed to provide pertinent information that it was
operated exclusively for one or more exempt purposes . It has failed to provide information that it
has a plan to resume the school activities that accomplish its exempt purposes in the future. Also, by not supplying
financial records required by sections 6001 and 6033 of the Code, we were unable to determine whether the
organization was operated for one or more of the exempt purposes. The organization has failed to meet the operating
requirements described in section 1.501(c)(3)-1(c)(1) of the regulations. Accordingly, revocation of the organization's
exempt status is proposed effective

Form 1120, U.S. Corporation Income Tax Return, should be filed for the tax periods ending , and all
the subsequent tax years.

If you agree to this conclusion, please sign the attached forms.

If you disagree, please submit a statement of your position.

Catalog Number 20810W www.irs.gov Form 886-A (Rev. 5-2017)
Page 6 of 6