Ezel / IRS Rulings / 202602005
Private Letter Ruling 202602005 Released January 9, 2026 Approved Transcribed from scan

IRS excuses a 501(c)(12) governmental-unit affiliate from filing Form 990

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

An organization exempt under IRC Section 501(c)(12) asked the IRS to be relieved of the requirement to file the annual Form 990 information return. Section 6033(a)(3)(B) gives the IRS discretion to excuse certain exempt organizations from that filing, and Revenue Procedure 95-48 uses that discretion to exempt governmental units and their affiliates. Based on the information provided, the IRS determined the organization qualifies as a governmental unit or an affiliate of one, so under Rev. Proc. 95-48 it does not have to file Form 990. This is a short determination letter (Letter 4715) that applies only to this organization.

Ruling snapshot

  • Question: Does the organization qualify for relief from filing Form 990 as a governmental unit or affiliate under Rev. Proc. 95-48?
  • Outcome: Approved (filing relief granted)
  • Key authorities: IRC § 6033(a)(3)(B); Rev. Proc. 95-48; IRC § 501(a), (c)(12)

Full text (IRS public release)

Department of the Treasury                     Date:
Internal Revenue Service
Tax Exempt and Government Entities              Employer ID number:

IRS                                             Person to contact:
                                                Name:
                                                ID number:
                                                Telephone:
Release Number: 202602005                       Form 990 required:
Release Date: 1/9/2026
Legend:
C = Date                                        UIL: 6033.01-00

Dear

Why you're receiving this letter
This is in response to your C request to be exempt from the requirement to file Form 990, Return of
Organization Exempt from Income Tax.

Internal Revenue Code (IRC) Section 6033(a)(3)(B) and the accompanying regulations provide us discretionary
authority to decide that certain exempt organizations aren't required to file annual information returns on Form 990.
Under this discretionary authority, Revenue Procedure 95-48 explains that governmental units and affiliates of
these units exempt from federal income tax under IRC Section 501(a), don't have to file Form 990. Based on the
information you provided, we determined you qualify for classification as a governmental unit or an affiliate of
this unit. Therefore, in accordance with Rev. Proc. 95-48, you're not required to file Form 990. We'll update
our records accordingly.

What you need to know

As an organization exempt from federal income tax under IRC Section 501(c)(12), you must fulfill other
requirements. You can find helpful information about your responsibilities as tax exempt organization in
Publication 4221-NC, Compliance Guide for Tax Exempt Organizations (other than 501(c)(3) Public Charities
and Private Foundations),

Additional information
If you have questions, you can call the contact person shown on the first page of this letter.

Keep a copy of this letter for your records.

We sent a copy of this letter to the representative as indicated on your power of attorney.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Letter 4715 (Rev. 4-2024)
Catalog Number 57710S