501(c)(3) revoked, an inactive organization gave the IRS no records to verify its exempt purpose

Plain-English summary

The IRS revoked an organization's 501(c)(3) status after it failed to answer the agency's information requests during an examination. The organization had been set up by a person who created many nonprofit entities, most of which are no longer operational, and this one was reportedly no longer operating. The examination surfaced a lawsuit alleging the organization received real property worth a large amount and then sold it improperly. When the IRS asked for records of those property transactions, bank statements, and other books, the organization provided nothing, and it ignored two information document requests, a delinquency notice, and a pre-summons notice. Because it produced no evidence that it operated exclusively for exempt purposes or that its earnings did not benefit private individuals, the IRS found it failed the operational test and revoked its exemption. Contributions to it are no longer deductible under Section 170.

Ruling snapshot

• Question: Should the organization's 501(c)(3) exemption be revoked when it provided no records to verify its exempt purpose?
• Outcome: revocation
• Key authorities: IRC §§ 501(c)(3), 170, 6001, 6033; Treas. Reg. § 1.501(c)(3)-1(d)(1)(ii); Rev. Rul. 58-617, 1958-2 C.B. 260

Full text (IRS public release)

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

Date:
August 13, 2025

Taxpayer ID number (last 4 digits):

Form:

Tax periods ended:

Release Number: 202552030
Release Date: 12/26/2025
UIL Code: 501.03-00

Person to Contact:
Name:
ID number:
Telephone:
Fax:

Last day to file petition with United States Tax Court:
November 11, 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: You have not provided
the documentation, records, or other information necessary to demonstrate that your organization operates
exclusively for one or more purposes described in IRC Section 501(c)(3). Furthermore, you have not
demonstrated that no part of your organization's net earnings inured to the benefit of any private shareholder or
individual, as required for the continuation of your exempt status. Therefore, your organization does not meet
the operational requirements under IRC Section 501(c)(3).

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)
Catalog Number 74808E

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)
Catalog Number 74808E

Keep the original letter for your records.

Director, Exempt Organizations Examinations

Enclosures:

Publication 1
Publication 594
Publication 892

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

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

Date:
05/07/2025

Taxpayer ID number:

Form:

Tax periods ended:

Person to contact:
Name:
ID number:
Telephone:

Manager's contact information:
ID number:
Telephone:

CERTIFIED MAIL - Return Receipt Requested

Response due date:
6/7/2025

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. 3-2024)
Catalog Number 34809F

4. Request that we refer this matter for technical advice from the Office of Associate Chief Counsel (Employee
Benefits, Exempt Organizations, and Employment Taxes) if you feel the issue hasn't been addressed in
published precedent or has been treated inconsistently by the IRS. If you're considering making such a request,
contact the person shown at the top of this letter. A decision made in a technical advice memorandum related to
tax-exempt status is final if it is issued before an appeal is requested. You will not be able to appeal to the IRS
Appeals Office if you disagree with the technical advice memorandum.

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.

Supervisory Internal Revenue Agent

Enclosures:
Form 886-A
Form 6018
F4621-A

Letter 3618 (Rev. 3-2024)
Catalog Number 34809F

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

Name of taxpayer         Tax Identification Number         Year/Period

Issue:
Whether (Organization) provided requested information needed to
verify its qualification for exempt purposes per Internal Revenue Code (IRC) 501(c)(3).

Facts:

The Organization was incorporated in the State of         on         , as a domestic
non-profit corporation. Articles of Incorporation state its purpose as:

The Organization's status has been revoked in the State of

        was the creator of this entity and has incorporated over         non-profit entities in
and many more in         of which many are no longer operational/exempt.

        stated during an interview that         was no longer in operation.

There is a judgement entered against         in         of
case         .         is listed as both the President and Secretary of the
Organization. The         involved in the case transferred         pieces of real property valued
in excess of         to the Organization. The         alleged the Organization breached the
covenant of good faith and fair dealing by selling the properties but failing to submit to the
escrow company for that transaction a copy of         note which reflected that the
payment due under that Note was secured by the proceeds from that sale.

        has not provided any documents related to the sale of the properties or
any evidence they operate for an exempt purpose.

The Organization did not respond to the Information Document Request (IDR) #1 issued on
        due on         . This IDR requested pertinent records: copies of Form 8283
(non-cash contributions over $500) and Form 8282 for any sale of donated asset/property within
        years to show an exempt purpose.

The Organization did not respond to the IDR #2 issued on         due on         . The
government also asked for books/records, bank statements, accounting software and none were
provided.

The Organization did not respond to the Delinquency Notice issued on         due on
        . This notice states you haven't provided us with all of the requested information by
the IDR due date and if the organization doesn't fully respond by         we'll make
a preliminary adverse determination based on the information we have.

Catalog Number 20810W         Page 1 of 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)         Explanation of Items

Name of taxpayer         Tax Identification Number         Year/Period

The Organization did not respond to the Pre-Summons Notice issued on         due on
        . Government asked for documentation related to any property transaction and
copies of bank statements/investment accounts and supporting documentation related to any
property sales/rental transactions. We will proceed to make an adverse determination based on
the information we have.

Law:

§ 6001 of the code provides 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 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.

§ 6033(a)(1) of the code provides except as provided in paragraph (3), every organization
exempt from taxation 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 purpose
of carrying out the internal revenue laws as the Secretary may by forms or 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; except that, in the discretion of the Secretary, any organization described in
section 401(a) may be relieved from stating in its return any information which is reported in
returns filed by the employer which established such organization.

IRC 501(c)(3) provides, 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.

IRC 501(c)(3) provides, an organization is not organized or operated exclusively for one or
more exempt purposes unless it serves a public rather than a private interest.

Treas. Reg. Section 1.501(c)(3)-1(d)(1)(ii) provides, to be charitable, an organization must serve
a public rather than a private interest. The organization must demonstrate 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.

Catalog Number 20810W         Page 2 of 4         www.irs.gov         Form 886-A (Rev. 5-2017)

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

Name of taxpayer         Tax Identification Number         Year/Period

Ruling or determination letter holding the organization exempt may be revoked retroactively to
the date of the changes affecting its exempt status, depending upon the circumstances
involved, and subject to the limitations on retroactivity of revocation found in 503 of the Code.

Organization Statement:
The Organization has not provided a position

Government Position:

In accordance with the above-cited provisions of the Code and regulations under sections 6001
and 6033, organizations recognized as exempt from federal income tax must meet certain
reporting requirements. These requirements relate to the filing of a complete and accurate
annual information (and other required federal tax forms) and the retention of records sufficient
to determine whether such entity is operated for the purposes for which it was granted tax-
exempt status and to determine its liability for any unrelated business income tax. The
Government has made numerous requests for documentation to support the Organization's
exempt status. The Organization has not shown or provided any supporting documentation that
it was operated exclusively for exempt purposes per Internal Revenue Code (IRC) 501(c)(3).

According to         in the interview, the organization is no longer in operation but has
provided no support for this. Further, information obtained during the course of the exam
indicate no exempt purpose for this organization and others.

The organization did not produce documents, records, or other information to demonstrate that
it is observing the conditions required for the continuation of IRC 501(c)(3).

Revenue Ruling 58-617, 1958-2 CB 260, (Jan. 01, 1958), provides that rulings and
determinations letters granting exemption from federal income tax to an organization described
in IRC 501(a) of the Internal Revenue Code of 1954, to which contributions are deductible by
donors in computing their taxable income in the manner and to the extent provided by IRC 170,
are effective only so long as there are no material changes in the character of the organization,
the purposes for which it was organized, or its methods of operation. Failure to comply with this
requirement may result in serious consequences to the organization for the reason that the
ruling or determination letter holding the organization exempt may be revoked retroactively to
the date of the changes affecting its exempt status, depending upon the circumstances
involved, and subject to the limitations on retroactivity of revocation found in 503 of the Code

The Organization's exempt status should be revoked for failure to provide information verifying
its continued qualification for exempt status.

Catalog Number 20810W         Page 3 of 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)         Explanation of Items

Name of taxpayer         Tax Identification Number         Year/Period

Conclusion:
It is the government's position that         was not operated exclusively for
exempt purposes per IRC 501(c)(3).

        has failed to demonstrate that it is operated exclusively for one or more of the
purposes described in IRC 501(c)(3) or that no part of its net earnings inured to the benefit of
any private shareholder or individual. The organization did not produce documents, records, or
other information to demonstrate that it is observing the conditions required for the continuation
of IRC 501(c)(3).

The organization does not meet the operational requirements under 501(c)(3) of the Internal
Revenue Code and their tax-exempt status should be revoked effective as of

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