IRS revoked exemption after a founder used organization funds for personal expenses

Plain-English summary

The IRS revoked an organization's section 501(c)(3) status after finding that its founder and chief executive received substantial private benefits. Bank and mortgage records showed unsubstantiated payments for a personal home loan, personal property taxes, debit-card purchases, checks, groceries, meals, and travel. The organization did not provide records showing that the transactions furthered its exempt purposes, despite information requests, follow-up calls, and summonses. The IRS also found no safeguards against excess benefit transactions and no effort to correct them. It concluded that the organization's net earnings inured to an insider and that revocation was warranted under section 501(c)(3), even after considering the section 4958 factors.

Ruling snapshot

• Question: Did unsubstantiated payments benefiting the founder cause prohibited private inurement and loss of section 501(c)(3) status?
• Outcome: Revocation
• Key authorities: IRC §§ 501, 4958, 6001, and 6033; Treas. Reg. §§ 1.501(c)(3)-1 and 1.6033-2

Full text (IRS public release)

Department of the Treasury Internal Revenue Service Date:

April 11, 2025
Tax Exempt and Government Entities Taxpayer ID number (last 4 digits):
Form:

Tax periods ended:

Person to contact:

ID number:
Release Number: 202527015 Telephone:

Release Date: 7/3/2025 Last day to file petition with United States
UIL Code: 501.03-00 Tax Court:

July 10, 2025

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: Organizations
described in IRC Section 501(c)(3) and exempt from tax under Section 501(a) must be both organized and
operated exclusively for exempt purposes and no part of the net earnings may inure to the benefit of any private
shareholder or individual. See Treas. Reg. § 1.501 (c)(3)-1(c)(2). An organization will not be so regarded if
more than an insubstantial part of its activities is not in furtherance of an exempt purpose. You have not
demonstrated that you are organized and operated exclusively for an exempt purpose or that you have been
engaged primarily in activities that accomplish one or more exempt purposes as required by Treas. Reg. section
1.501(c)(3)-1(c)(1). Moreover, your organization was operated for the private interests of its President/CEO/
founder rather than the public. Your income or assets have inured to the benefit of private shareholders or
individuals which is contrary to IRC Section 501(c)(3) and Treasury Reg. section 1.501(c)(3)-1(c)(2). As such,
you have failed to meet the requirements of IRC Section 501(c)(3) and Treasury Reg. section 1.501(c)(3)-1 (a).
Under IRC Section 6001, every person liable shall keep and render such records and comply with the Secretary;
similarly, IRC Section 6033 also refers to keeping and rendering records upon the Secretary’s request. Treas.
Reg. § 1.6033-2(i)(2) provides that every organization exempt from tax shall submit such additional information
as may be required by the Service for the purpose of inquiring into its exempt status. You failed to provide
information as required by IRC Sections 6001, 6033(a)(1) and Treas. Reg. § 1.6033-2(i)(2). As such, you fail to
meet the operational requirements for continued exemption under IRC Section 501(c)(3) and Rev. Rul. 59-95,
1959-1 C.B. 627.

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.

Letter 6337 (Rev. 3-2024)
Catalog Number 74808

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.

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

Letter 6337 (Rev. 3-2024)
Catalog Number 74808E

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.

Keep the original letter for your records.

Sincerely,
Digitally signed by Lynn A. Brinkley
Date: 2025.02.27 16:38:06
-05'00'

Lynn A. Brinkley
Director, Exempt Organizations Examinations

Enclosures:
Publication 1
Publication 594
Publication 892

Letter 6337 (Rev. 3-2024)

Catalog Number 74808E

Department of the Treasury Date: 9/27/2023
Internal Revenue Service Taxpayer ID number:
IRS Tax Exempt and Government Entities
Form:

Tax periods ended:

Person to contact:
Name:
ID number:
Telephone:
Fax:
Address:

Manager's contact information:
Name:
ID number:

Telephone:
Response due date:

10/27/2023

CERTIFIED MAIL — Return Receipt Requested
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.

Letter 3618 (Rev. 8-2019)
Catalog Number 34809F

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.

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.

For 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).

2 Letter 3618 (Rev. 8-2019)
Catalog Number 34809F

If you have questions, you can contact the person shown at the top of this letter.

Sincerely,

for Lynn A. Brinkley
Director, Exempt Organizations
Examinations

Enclosures:
Form 886-A
Form 6018
Form 4621-A

3 Letter 3618 (Rev. 8-2019)
Catalog Number 34809F

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit

(May 2017) Explanations of Items

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended

Issues:

1) Whether _(" "), a 501(c)(3) organization status should
be revoked on the grounds that its net earnings inured to the benefit of its
President/CEO, ( ).

Facts:

On ' incorporated in . The purpose of
was stated to"

On , the IRS received Form 1023 Application for Recognition of
Exemption Under Section 501(c)(3) of the Internal Revenue Code. was listed
as a compensated CEO on , of the Form 1023. Also, signed under
penalty of perjury that he was authorized to sign the application, and was true, correct,
and complete on . Attached to the application Form 1023 was a letter
written by requesting the IRS to expedite their application request for tax
exempt status. In the letter explained that he was a founding board member
of and was willing to make a gift during the coming year to upon
being granted tax exempt status. The letter was signed and dated ,
almost a year before the 1023 application was submitted.

founded and serves as its President and Chief Executive Officer.
He is also listed as the registered agent and incorporator in the Articles of Incorporation.

On , the IRS issued a letter to indicating that was
approved as a Section 501(c)(3) public charity under Section 170(b)(1)(A)(ii) with an
accounting period ending with an effective date of exemption of ;

On , Letter 3611 and Form 4564 Information Document Request “IDR’,
were issued to requesting information for the examination, as well as an
interview with an officer. On , the Agent received a faxed 2848 from

. the Power of Attorney (POA) requesting an extension on the IDR and
a reschedule of the tour of the facility.

The agent reviewed some monthly bank statements from its checking
account ending in # and identified questionable expenses made on the account
debit card ending # assigned to . did not fully comply with IDR
as there was missing information and neither the POA nor responded. The
agent issued a summons to on , for the required bank records.

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

Form 886-A Department of the Treasury - Internal Revenue Service Schedule number or
(May 2017) Explanations of Items ~“

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended
On ,IDR was issued to requesting additional information
regarding payments made to debit card. The Agent attempted to reach out to the
POA multiple times, but there was no response from the POA or . On

, the agent received a written notification from the POA notifying the IRS that
he would be withdrawing as the authorized representative for

The agent attempted to contact the officers regarding information not provided from IDR

andIDR via phone calls and mail. Due to the lack of cooperation combined with
the findings in the bank statements reflecting questionable deposits and expenses near
the end of its annual accounting period, the agent expanded the examination into
subsequent tax years.

The lack of noncooperation with the requests resulted in the summoning of for
bank records. A review of those records revealed electronic payments had been made
to a home mortgage company and payments for property taxes.

The agent summoned the mortgage company for records, and upon receipt and review
of the records it was identified that funds are being used to pay for
Home Loan. Further review of the mortgage records also identified that
made payments to "s personal property taxes.

During the examination of 's 1023 application, Articles of Incorporation, and
review financial records, it was confirmed that was a founder/CEO of

Bank statements confirmed that has sole authorization over

finances. Expenses made on behalf of the organization were approved by

Review of : and 's bank statements and canceled checks
revealed that received additional economic benefits not reported as Form W-2
wages:
Description
_ Checks from written to authorized by $ $
, Unsubstantiated transactions made on Debit Card | $ $
| Unsubstantiated payments made to Home Loan $ $
Unsubstantiated __ payments made to Property Taxes | $ $
Total Unsubstantiated payments to/for not reported $ $
Law:

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

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit
(May 2017) Explanations of Items

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended

IRC § 501(c)(3) exempts from federal income tax organizations which are organized
and operated exclusively for religious, charitable, scientific, testing for public safety,
literary, or educational purposes, or to foster national or international amateur sports
competition (but only if no part of its activities involve the provision of athletic facilities or
equipment), or for the prevention of cruelty to children or animals, no part of the net
earnings of which inures to the benefit of any private shareholder or individual, no
substantial part of the activities of which is carrying on propaganda, or otherwise
attempting, to influence legislation (except as otherwise provided in subsection (h)), and
which does not participate in, or intervene in (including the publishing or distributing of
statements), any political campaign on behalf of (or in opposition to) any candidate for
public office.

Section 1.501(c)(3)-1(a)(1) provides that in order to be exempt as an organization
described in section 501(c)(3), 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)(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.

Section 1.501(c)(3)-1(d)(3)(i) defines the word “educational”, as used under section

501(c)(3) of the code, as-

(a) Click to open paragraph tools The instruction or training of the individual for the
purpose of improving or developing his capabilities; or

(b) The instruction of the public on subjects useful to the individual and beneficial to the
community.

Section 1.501(c)(3)-1(f)(2)(i) states that, regardless of whether a particular transaction is
subject to excise taxes under section 4958, the substantive requirements for tax
exemption under section 501(c)(3) still apply to an applicable tax-exempt organization
described in section 501(c)(3) whose disqualified persons or organization managers are
subject to excise taxes under section 4958. Accordingly, an organization will no longer
meet the requirements for tax-exempt status under section 501(c)(3) if the organization
fails to satisfy the requirements of paragraph (b), (c) or (d) of this section.

Section 1.501(c)(3)-1(f)(2)(ii) provided that, in determining whether to continue to
recognize the tax-exempt status of an applicable tax-exempt organization (as defined in
section 4958(e) and § 53.4958—2) described in section 501(c)(3) that engages in one or
more excess benefit transactions that violate the prohibition on inurement under section
501(c)(3), the Commissioner will consider all relevant facts and circumstances,
including, but not limited to, the following—

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

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit

(May 2017) Explanations of Items

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended

(A) The size and scope of the organization's regular and ongoing activities that further
exempt purposes 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 has 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.

Section 4958(c)(1) defines “excess benefit transaction” as 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 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(e)(1) defines “applicable tax-exempt organization” as any organization
which (without regard to any excess benefit) would be described in paragraph (3), (4),
or (29) of section 501(c) and exempt from tax under section 501(a).

Section 4958(f)(1) defines “disqualified person’, with respect to any transaction as - (A)
any person who was, at any time during the five year period ending on the date of such
transaction, in a position to exercise substantial influence over the affairs of the
organization, (B) a member of the family of a disqualified person, or (C) a 35 percent
controlled entity.

The taxpayers have the burden of proof that they are entitled to deductions. See
Hradesky v. Commission. 540 F.2d 821 (5th Cir. 1976), and Welch v. Helvering, 290
U.S. 111, 115 (1933).

In Founding Church of Scientology v. United States, 412 F.2d 1197 (Ct. Cl. 1969), cert.
den., 397 U.S. 1009 (1970), an organization argued that it had paid its founder for

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

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit
(May 2017) Explanations of Items

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended

expenses incurred in connection with his services, made reimbursements to him for
expenditures on its behalf, and made some payments to him as repayments on a loan.
The organization could produce no evidence of contractual agreements for services, or
documents evidencing indebtedness for which expenses had been incurred. The Court
concluded that

nothing we have found in the record dispels the substantial doubts the court
entertains concerning the receipt of benefit by the Hubbards from plaintiff's net
earnings. Since plaintiff has failed to meet its burden of proof, we hold therefore
that a part of the corporate net earnings was a source of benefit to private
individuals. Supra, at 1202.

Taxpayer's Position:

position is not known.

Government's Position:

and its officer have the burden to establish that the debit card purchases,
checks, withdrawals, home loan mortgage payments, and personal property tax
payments, described in this report were connected to the Foundation's activities, thus
furthering its exempt purpose. See Hradesky v. Commission and Welch v. Helvering.

Despite written requests and follow-up phone calls to afford and its
officers to documentation and information, neither provided proof establishing how
these transactions were connected to activities and, thus furthering its
exempt purpose.

The transactions were made to or on behalf of and were personal in nature. For
example, the purchases of , groceries, and meals, the uses of

income to repay personal home loan, his personal property taxes, etc. were, in
fact his personal expenses. Therefore, it's determined that these transactions were not
connected to the exempt activities.

It's therefore determined that net earnings have inured, in substantial part, to
the benefit of , who is an insider as defined by Regs. 1.501(a)-1(c). This
violates Regs. § 1.501(c)(3)-1(c)(2) and warrants revocation of 501(c)(3)
status. Attempting after the fact to demonstrate that an undocumented transaction is a
typical business arrangement is not likely to prevent a finding of inurement. See
Founding Church of Scientology v. United States.

Interaction with IRC §4958

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

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit
(May 2017) Explanations of Items

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended

In determining whether to continue to recognize the tax-exempt status of an applicable
tax exempt organization that engages in one or more excess benefit transactions that
violate the prohibition on inurement under IRC § 501(c)(3), all relevant facts and
circumstances, including, but not limited to, the following are taken into account:

1. The size and scope of the organization's regular and ongoing activities that further
   exempt purposes before and after the excess benefit transaction(s) occurred;

2. 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;

3. Whether the organization has been involved in multiple excess benefit transactions
   with one or more persons;

4. Whether the organization has implemented safeguards that are reasonably
   calculated to prevent excess benefit transactions; and

5. Whether the excess benefit transaction has been corrected, or the organization has
   made good faith efforts to seek correction from the disqualified person(s) who
   benefited from the excess benefit transaction.

All factors should be considered in combination with each other. Depending on the
particular situation, greater or lesser weight may be assigned to some factors than to
others. The safeguard and correction factors will weigh more heavily in favor of
continuing to recognize exemption where the organization discovers the excess benefit
transactions and takes action before the IRS discovers the excess benefit transactions.
Further, with respect to the correction factor, corrections made after excess benefit
transactions are discovered by the IRS, by itself, is never a sufficient basis for
continuing with the exemption. Regs. § 1.501(c)(3)-1(f)(2)(ii).

Discussion of the 5 factors

1. The size and scope of the organization's regular and ongoing activities that further
   exempt purposes before and after the excess benefit transaction(s) occurred;

There's no ascertainable evidence that conducted activities as a from
through . A request to tour the facility to view assets and operations in person

was made on . The POA was unable to further establish contact with the

officers of and was unsure if was operating. did not

provide a listing of students, nor information on how it conducted its activities.

2. 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.

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

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit
(May 2017) Explanations of Items
Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended
Disbursements in tax year ending totaled $ , and in tax year
totaled $
Description
Checks from authorized and issued to $ $
Unsubstantiated transactions made by Debit Card :
Unsubstantiated payments made for personal home loan $ $ |
Unsubstantiated payments made for personal Property Taxes $ $ |
Total Unsubstantiated payments to/for personal expenses |
$ $
As shown above, the size of the excess benefit transaction in relation to the size of
's activities that further its exempt purpose is substantial. It's reasonable to
argue that the excess benefit transaction directly contributed to home loan

and payments to his personal property are not operational to the activities.

3. Whether the organization has been involved in multiple excess benefit transactions
   with one or more persons.

As illustrated above, has been involved in excess benefit
transactions. made payments to himself from bank account and
has not demonstrated that he provided reciprocal economic value to and has
not demonstrated that he received these economic benefits as a bona fide expense to
him. made payments from checking account to his personal home
loan, property taxes, dinning out, groceries and travel. or its officers have not
provided evidence of business connection for such expenses identified from

monthly bank statements.

4. Whether the organization has implemented safeguards that are reasonably
   calculated to prevent excess benefit transactions.

There were no safeguards or checks and balances. had complete control
over the Foundation's bank accounts, which gave him free reign to use bank
account as if they were his personal bank accounts.

5. Whether the excess benefit transaction has been corrected, or the organization has
   made good faith efforts to seek correction from the disqualified person who benefited
   from the excess benefit transaction.

No corrections have been made and no efforts, good faith or otherwise have been made
to seek correction from

Catalog Number 20810W Page 7 www.irs.gov Form 886-A (Rev. 5-2017)

Form 886-A Department of the Treasury — Internal Revenue Service Schedule number or exhibit
(May 2017) Explanations of Items

Name of taxpayer Tax Identification Number (last 4 digits) | Year/Period ended

Considering the 5 factors above, the excess benefit transactions demonstratable
resulted in inurement. Therefore, revocation is warranted.

Conclusion:

tax exempt status under IRC §501(c)(3) should be revoked effective :
, on the grounds of inurement. is required to file a Form 1120, U.S.
Corporation Income Tax Return, for the tax ended year and all future
years.

Catalog Number 20810W Page 8 www.irs.gov Form 886-A (Rev. 5-2017)