Ezel / IRS Rulings / 202603009
Private Letter Ruling 202603009 Released January 16, 2026 Approved Transcribed from scan

IRS excuses a church-affiliated school from Form 990 (but Form 5578 still required)

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

A church-affiliated school exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990. Treasury Regulation Section 1.6033-2(g)(1)(vi) provides that an educational organization below college level, described in IRC Section 170(b)(1)(A)(ii), with a general academic program and affiliated with a church or operated by a religious order, does not have to file Form 990. Based on the information provided, the IRS determined the school qualifies and is not required to file. The letter adds an important reminder: a private school must still certify its racial nondiscrimination annually under Section 4.06 of Revenue Procedure 75-50, which is normally done on Form 990 (Schedule E); a school that does not file Form 990 must instead file Form 5578 each year. This is a short determination letter (enclosing Letter 4715) that applies only to this organization.

Ruling snapshot

  • Question: Does the church-affiliated school qualify for relief from filing Form 990, and what certification still applies?
  • Outcome: Approved (Form 990 relief granted; annual Form 5578 racial-nondiscrimination certification still required)
  • Key authorities: Treas. Reg. § 1.6033-2(g)(1)(vi), (h)(2); IRC § 6033; § 170(b)(1)(A)(ii); § 501(c)(3); Rev. Proc. 75-50

Full text (IRS public release)

Department of the Treasury                     Date:
Internal Revenue Service                        10/24/2025
IRS Tax Exempt and Government Entities          Employer ID number:

                                                Person to contact:
                                                Name:
                                                ID number:
                                                Telephone:

                                                Form 990 required:
Release Number: 202603009
Release Date: 1/16/2026
UIL:
6033.01-00

Dear:

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

Treasury Regulation Section 1.6033-2(g)(1)(vi) provides that an educational organization (below college level)
described in Internal Revenue Code (IRC) Section 170(b)(1)(A)(ii) with a program of general academic nature
and is affiliated with a church, or operated by a religious order, isn't required to file Form 990. Treas. Reg. Section
1.6033-2(h)(2) clarifies what it means to be affiliated with a church. Based on the information you provided,
we determined you qualify for classification as one of these educational organizations. Therefore, in accordance
with Treas. Reg. Section 1.6033-2(g)(1)(vii), you're not required to file Form 990. We'll update our records
accordingly.

However, be aware that Section 4.06 of Revenue Procedure 75-50 requires private schools provide us with
annual certification of racial nondiscrimination. This is normally done on Form 990 (Schedule E), Schools.

If you don't file Form 990, you must complete Form 5578, Annual Certificate of Racial Nondiscrimination for a
Private School Exempt from Federal Income Tax, annually to certify you're complying with Rev. Proc. 75-50.

What you need to know
As an organization exempt from federal income tax under IRC Section 501(c)(3), you must fulfill other
requirements. You can find helpful information about your responsibilities as tax exempt organization in
Publication 4221-PC, Compliance Guide for 501(c)(3) Public Charities.

Additional information

We'll make this determination letter available for public inspection after making deletions required by IRC
Section 6110, such as names, addresses, and other identifying details. We've enclosed Letter 437, Notice of
Intention to Disclose Rulings, and a copy of the letter that shows our proposed deletions.

• If you disagree with our proposed deletions, follow the instructions in the Letter 437 on how to notify us.
• If you agree with our deletions, you don't need to take any further action.

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.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:
Letter 437
Redacted Letter 4715