IRS denies 501(c)(3) status to a mixed-use real-estate redevelopment group that mostly leases commercial space and benefits a for-profit owned by its director

Plain-English summary

An organization applied to be recognized as a tax-exempt charity under IRC
Section 501(c)(3), saying it would redevelop a former production facility in a
poor neighborhood into a mixed-use building with coworking offices, a
cooperative grocery store, a public market, and a rooftop venue, and would
address food insecurity and support the community. The IRS denied the
application, and because the organization did not protest within 30 days, the
denial became final. The IRS found the group failed both required tests.
Organizationally, its articles of incorporation (its controlling document, not
its bylaws) do not limit its purposes to exempt ones and do not dedicate its
assets to charity on dissolution. Operationally, its main activity is
commercial-type leasing of office space to any interested tenant, which is not
a charitable activity, and its plan routes public fundraising toward a
for-profit company that currently owns the building and is 90% owned by one of
the organization's own directors, a private benefit. The IRS distinguished
favorable precedents (like below-cost loans or industrial parks that require
hiring local unemployed residents) because this group did not show its tenants
would provide jobs or training for residents, and it compared the group to
cases where commercial operation and private benefit defeated exemption. The
charitable food and outreach efforts were, at most, incidental. Result: not
exempt, and donors generally cannot deduct contributions.

Ruling snapshot

• Question: Does a mixed-use commercial redevelopment organization qualify for exemption under IRC Section 501(c)(3)?
• Outcome: denied (final adverse determination; no timely protest filed)
• Key authorities: IRC § 501(c)(3); Treas. Reg. § 1.501(c)(3)-1(a), (b), (c), (d); Rev. Rul. 74-587; Rev. Rul. 76-419; Rev. Rul. 77-111; Better Business Bureau v. United States, 326 U.S. 179; B.S.W. Group v. Commissioner, 70 T.C. 352; Airlie Foundation v. United States; Korean American Senior Mutual Association v. Commissioner

Full text (IRS public release)

Department of the Treasury                       Date:
Internal Revenue Service                         01/12/2026
IRS Tax Exempt and Government Entities           Employer ID number:

                                                 Form you must file:
                                                 Tax years:

                                                 Person to contact:
Release Number: 202614036
Release Date: 4/3/2026
UIL Code: 501.00-00, 501.33-00, 501.36-01

Dear

This letter is our 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). Recently, we sent
you a proposed adverse determination in response to your application. The proposed adverse determination
explained the facts, law, and basis for our conclusion, and it gave you 30 days to file a protest. Because we
didn't receive a protest within the required 30 days, the proposed determination is now final.

Because you don't qualify as a tax-exempt organization under IRC Section 501(c)(3). donors generally can't
deduct contributions to you under IRC Section 170.

We may notify the appropriate state officials of our determination, as required by IRC Section 6104(c), by
sending them a copy of this final letter along with the proposed determination letter.

You must file the federal income tax forms for the tax years shown above within 30 days from the date of this
letter unless you request an extension of time to file. For further instructions, forms, and information, visit

www.irs.gov.

We'll make this final adverse determination letter and the proposed adverse determination letter available for
public inspection after deleting certain identifying information, as required by IRC Section 6110. Read the
enclosed Letter 437, Notice of Intention to Disclose - Rulings, and review the two attached letters that show 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 about this letter, you can call the contact person shown above. If you have questions
about your federal income tax status and responsibilities, call our customer service number at 800-829-1040
(TTY 800-829-4933 for deaf or hard of hearing) or customer service for businesses at 800-829-4933.

Letter 4038 (Rev. 11-2021)
Catalog Number 476328

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:

Letter 437

Redacted Letter 4034
Redacted Letter 4038

Letter 4038 (Rev. 11-2021)
Catalog Number 476328

Department of the Treasury
Internal Revenue Service

Date:
11/42/2025

Employer ID number:

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

Legend:                                          UIL:
B = Date                                         501.00-00
C = Facility                                     501.33-00
D = State                                        501.36-01
E = LLC
F = Individual

Dear

We considered your application for recognition of exemption from federal income tax under Internal Revenue
Code (IRC) Section 501(a). We determined that you don’t qualify for exemption under IRC Section 501(c)(3).
This letter explains the reasons for our conclusion. Please keep it for your records.

Issues
Do you qualify for exemption under IRC Section 501(c)(3)? No, for the reasons stated below.

Facts

You were incorporated in D on B. Your Articles state that you are organized as an intentional vehicle to enable
various individuals and groups to give and be a mechanism for empowering neighborhoods by enhancing lives,
building wealth and providing other support to those harmed with injustice. Your Articles are silent regarding
the disposition of your assets up on dissolution. Your Bylaws describe your purposes as those within IRC
Section 501(c)(3) with your assets being distributed for exempt purposes upon dissolution.

Your current board members are all members of the same family. Your board will continue to serve for at least
the first two years until the sale of the facility is fully accomplished. You plan to expand the board in the future.

In your initial application you described your activities as owning most of the shares of the C, a former
production facility now functioning as a shared office space. You are solely responsible for maintaining the
building and its operations. E is a for-profit entity that currently owns the building, and F, an individual, owns
ninety percent of E. F is also listed as your Director. The C is located in an economically challenged part of
your city. You said you may expand to other parts of the city and beyond, as the Board determines. You plan to

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raise funds through public grants and to use these funds to “support individuals or groups who were and are
harmed by injustices from the past and to the present.”

You said that a portion of the building is rented out to individuals and companies as coworking office space to
help pay for building expenses while you wait for development offers. About half of the building is currently
vacant/used for storage.

Your application indicated that you engage (or will engage) in economic development activities, but you didn't
clearly describe the activities. You were required to provide the following about your past, present or future
economic development activities:

e Description of your economic developmental programs (such as job training or business loans),
including your targeted recipients and how you'll market your programs.

• Your geographic area of operation and whether any government has made designations of the area (such

as a deteriorated or blighted area). Provide official documentation of any governmental agency

designations, and include economic information for the area, such as conditions or rankings compared to

other areas.

The median income level and demographics of your geographic area of operation.

The criteria you use to select program recipients or organizations for assistance.

You were required to explain how you would end up owning the building.

You were asked if you are a nonprofit subsidiary of E? If so, provide proper documentation.

You only provided partial responses. You failed to describe the specific economic development programs, or
the criteria that you use to select assistance recipients. Rather, you only provided a generalized description that
your “primary mission is to address food insecurity . . . offer monthly outreach services that include activities
designed to nurture community connections . . . establish strong partnerships with local nonprofits ... and other
businesses within the neighborhood.” In addition, you stated that “we have already had summer markets,
regular community educational events, [and] reduced fees for co-working space for residents.” You said you
will provide resources, funding and expertise to foster economic grow/wealth building and improve conditions,
particularly in the neighborhood of the C. You said you would provide financial resources for projects that
create jobs, support small businesses and improve infrastructures, first contributing to the organizations that are
part of the C. Those efforts will include creating a destination with a grocery store, retail opportunities and
rooftop spaces. You have held “vigorous outreach programs,” including open houses, tours, and community
markets to hear of the various community needs.

When describing the physical location of the C, we asked for you to provide official documentation of any
government agency designations and economic information for the area. You said that the location is the most
under-resourced and under-served area for public services and amenities in the city. The neighborhood is the
poorest zip code in your city.

You said you will eventually become the sole owner and manager of the building known as the C. In response
to the inquiry regarding how your activities further an exempt purpose, you stated that the facility “‘is a
pioneering mixed-use redevelopment . . . our plan is to renovate the building to offer coworking areas (already
functional and generating income), a cooperative resident owned grocery store (the area is a food desert),
business offices, a public market, cultural and educational offerings and a stunning rooftop venue.” In addition,

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you stated that with your “unique resident ownership model, [you] aim to foster wealth creation and long-term
economic growth” for residents and business owners.

You said that two other individuals, in addition to F, own E. Those two individuals both have their own
companies that rent space in the C “at market rate alongside all the other tenants of the building.” You
submitted a financial forecast, which was prepared for E, which shows you receiving a combination of tax
credits, loans, and fundraising. You said that you will take ownership of the C as part of the financial plan. It
shows a very low interest 30-year loan from you to an investment fund.

Your financial data projects obtaining all of your revenue from gifts, grants, and contributions, and none from
your leasing activities. Your expenses will be for fundraising, occupancy, and administrative expenses. You
indicated that in the current year you plan to spend about half of your funds to operate the facility known as the
C. The other half will be used for a consultant to build out the co-op grocery plan and for future years.

Law

IRC Section 501(c)(3) provides for exemption from taxation for “corporations, and any community chest, fund,
or foundation, 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.”

Treasury Regulation Section 1.501(c)(3)-1(a)(1) states that, to be exempt as an organization described in IRC
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.

Treas. Reg. Section 1.501(c)(3)-1(b)(1)(i) provides that an organization is organized exclusively for one or
more exempt purposes only if its articles of organization (as defined in subparagraph (2)) limit its purposes to
one or more exempt purposes and do not expressly empower it to engage, otherwise than as an insubstantial part
of its activities, in activities which in themselves are not in furtherance of one or more exempt purposes.

Treas. Reg. Section 1.501(c)(3)-1(b)(2) provides that the term articles of organization or articles includes the
trust instrument, the corporate charter, the articles of association, or any other written instrument by which an
organization is created.

Treas. Reg. Section 1.501(c)(3)-1(b)(4) holds that an organization is not organized exclusively for one or more
exempt purposes unless its assets are dedicated to an exempt purpose. An organization’s assets will be
considered dedicated to an exempt purpose, for example, if, upon dissolution, such assets would, by reason of a
provision in the organization’s articles or operation of law, be distributed for one or more exempt purposes.

Treas. Reg. Section 1.501(c)(3)-1(c)(1) 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). An organization will not be so regarded if more than an
insubstantial part of its activities is not in furtherance of an exempt purpose.

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Treas. Reg. Section 1.501(c)(3)-1(d)(1)(ii) states that an organization is not operated exclusively for one or
more exempt purposes unless it serves a public rather than a private interest. It must not be operated for the
benefit of designated individuals or the persons who created it.

Rev. Rul. 74-587, 1974-2 C.B. 162, 1-2, held that an organization exclusively providing below cost loans to
businesses in an economically depressed area and giving preference to businesses that will provide employment
opportunities for residents of the area is operated exclusively for charitable purposes.

Rev. Rul. 76-419, 1976 C.B. 146, 1-2 holding that an organization that purchased land in an economically
depressed area, developed it into an industrial park, and required lessees to hire and train a significant number
of unemployed residents is exclusively operated for charitable purposes.

Rev. Rul. 77-111, 1977-1 C.B. 144, 1-2 provides that constructing a retail center and leasing the buildings,
while requiring tenants to employ a certain percentage of minorities is “directed to benefit the businesses in the
shopping center rather than exclusively to accomplish 501(c)(3) purposes.”

The Supreme Court found in Better Business Bureau of Washington. D.C. Inc. v. United States, 326 U.S. 179
(1945), that a single, substantial, non-exempt purpose will bar a claim for exemption, regardless of whether

there are other exempt purposes..

In Universal Life Church, Inc. v. United States, 372 F. Supp. 770 (E.D. Cal. 1974), the court concluded that
“one seeking a tax exemption has the burden of establishing his right to a tax-exempt status.”

In B.S.W. Group, Inc. v. Commissioner, 70 T.C. 352 (1978), the Court found that “the critical inquiry is
whether petitioner's primary purpose for engaging in its sole activity is an exempt purpose, or whether its
primary purpose is the nonexempt one of operating a commercial business producing net profits for petitioner.”
The Court went on to state that “factors such as the particular manner in which an organization's activities are
conducted, the commercial hue of those activities, and the existence and amount of annual or accumulated
profits are relevant evidence of a forbidden predominant purpose.” The organization failed this test because it
provided consulting services for a fee which “constitutes the conduct of a consulting business of the sort which
is ordinarily carried on by commercial ventures organized for profit.” The organization also failed to
demonstrate that it does not compete with commercial firms and “competition with commercial firms is strong
evidence of the predominance of nonexempt commercial purposes.”

In Greater United Navajo Development Enterprises, Inc. v. Commissioner, 74 T.C. 69, 82 (1980), the Tax Court

found that petitioner’s primary purpose was engaging in a commercial business due to the petitioner’s main
business of leasing oil drilling equipment, with no indication that the petitioner employed Navajos,
contradicting its self-stated purpose of economic development of the Navajo Nation.

In Airlie Foundation v. United States, 283 F. Supp. 2d 58 (D.D.C. 2003), the court noted that Airlie acts as an
intermediary and does not directly benefit the public, and Airlie's conference patrons are not limited to exempt
entities. The court acknowledged that Airlie's activities have some noncommercial characteristics but found
these outweighed by other factors such as the nature of Airlie's clients and competition, its advertising
expenditures and substantial revenues derived from wedding and special events. In the court's review, these
factors support an adverse conclusion. The court concluded that Airlie does not qualify under Section 501(c)(3)
of the Code because it operates its conference center in a manner consistent with that of a commercial business.

Letter 4034 (Rev. 01-2021)
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New Dynamics Foundation v. United States, 70 Fed. Cl. 782 (2006), was an action for declaratory judgment
that the petitioner brought to challenge the denial of his application for exempt status. The court, in finding that
the actual purposes displayed in the administrative record supported the Service’s denial, stated “It is well-
accepted that, in initial qualification cases such as this, gaps in the administrative record are resolved against the
applicant.” The court noted that if the petitioner had evidence that contradicted these findings, it should have
submitted it as part of the administrative process. The court also highlighted the principle that exemptions from
income tax are matters of legislative grace.

Korean American Senior Mutual Association Inc. v. Commissioner, T.C. Memo 2020-129, 18 (T.C. 2020),
finding that the petitioner did not qualify for exemption under IRC Section 501(c)(3) because it did not serve a
charitable class, operated in a commercial manner, and served a private, rather than a public interest. The
petitioner did not serve a charitable class because it did not help elderly people without regard to their ability to
pay. The petitioner operated in a commercial manner and served a private, rather than public interest, by
providing burial benefits only to paying members.

Application of law

To qualify for exemption under IRC Section 501(c)(3) you must be both organized and operated exclusively for
exempt purposes as described in Treas. Reg. Section 1.501(c)(3)-1(a)(1). You have failed to meet both the
organizational and operational requirements.

Organizational Test

You are formed as a corporation and your creation document, your Articles of Incorporation, fail to limit your
purposes to those described in IRC Section 501(c)(3), as required by Treas. Reg. Section 1.501(c)(3)-1(b)(1)(i).
Your Bylaws contain the required provisions, but since you’re a corporation, your Articles of Incorporation are
your formation document, not your Bylaws. See Treas. Reg. Section 1.501(c)(3)-1(b)(2). Moreover, your assets
are not dedicated to an exempt purpose in your formation document as required by Treas. Reg. Section
1.501(c)(3)-1(b)(4). Accordingly, you fail the organizational test under Section 501(c)(3).

Operational Test

A substantial portion of your activities are devoted to non-exempt functions; therefore, you do not qualify for
exemption under IRC Section 501(c)(3) as described in Treas. Reg. Section 1.501(c)(3)-1(c)(1). The provision
of commercial-type leasing services to anyone interested, without condition or restriction, is not a charitable or
educational activity within the meaning of Section 501(c)(3).

You plan on acquiring the C from E, a for-profit entity owned, in part, by one of your Directors. The financial
projections you submitted appear to show you receiving public funds while the facility is still owned by E. You
aren’t described in Treas. Reg. Section 1.501(c)(3)-1(d)(1)(ii) because your fundraising efforts will benefit a
for-profit entity.

As in Better Business Bureau of Washington, D.C., Inc., you are engaged in substantial nonexempt activities.
You failed to describe how operating a facility with coworking areas, business offices, a grocery store, public
market, and rooftop venue exclusively furthers exempt purposes.

While you indicated that you will hold educational events, you have not disclosed the percentage of time you
will spend on these events. Additionally, you have not described any specific economic development programs.
As stated in Universal Life Church, Inc., you have the burden of establishing that you qualify for tax exemption.

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Similarly, in New Dynamics Foundation, it was found that an organization must establish, through its
administrative record, that it meets the requirements for exemption. Because you failed to provide sufficient
details in your initial application, and the additional information you provided did not meet the statutory and
regulatory requirements for exemption, you have not established that you meet the requirements for exemption
under Section 501(c)(3).

You are unlike the organization described in Rev. Rul. 74-587 which qualified for tax exemption under IRC
Section 501(c)(3). That organization provided below cost loans and gave preference to businesses that employ
residents. In contrast, you have not demonstrated that the businesses within your development will provide
employment or other job assistance for residents. Leasing an office building to any interested business isn’t,
without more, an exempt purpose under Section 501(c)(3).

You are also unlike the organization described in Rev. Rul. 76-419 which qualified for tax exemption under
IRC Section 501(c)(3) for developing an industrial park in an economically depressed area and requiring lessees
to hire and train unemployed residents. In contrast, you failed to provide documentation that you will require
lessees to hire and/or train residents.

You similar to the organization described in Rev. Rul. 77-111 because you also plan to construct a development
with commercial tenants, including a grocery store and office spaces, Your activities are typical for-profit
landlord-type activities rather than exclusively accomplishing IRC Section 501(c)(3) purposes. The information
you provided doesn’t allow the conclusion that the grocery store or office space are going to function
exclusively for exempt purposes.

You are like the organization described in Korean American Senior Mutual Association which didn’t qualify for
exemption under IRC Section 501(c)(3). Like that organization, you do not exclusively serve a charitable class
and you operate in a manner typical of a for-profit enterprise. Like that organization, you also have not provided
enough information to document that you more than incidentally serve a charitable class.

Like the organization in B.S.W. Group, Inc., you also failed to demonstrate that you do not compete with
commercial developments, which is “strong evidence of the predominance of nonexempt commercial
purposes.” You are also similar to the organization in Greater United Navajo Development Enterprises, Inc.,
which the Tax Court found had a primary commercial business purpose due to it leasing oil drilling equipment
with no indication that the petitioner employed Navajos or was related to an exempt purpose. Likewise, you
lease space within your building without demonstrating measures to assist the residents with employment or
further any exempt purpose.

Like Airlie Foundation, your facility is in competition with for profit commercial buildings. Your space is
available for lease by any individual or business. You said that residents will receive a reduced rent, but it’s
unclear how much of the space is leased to such individuals, what the criteria is to received reduced rent, or the
amount of the reduction. You failed to demonstrate that your mixed-use redevelopment will exclusively serve
exempt purposes under IRC Section 501(c)(3).

Your position

You said your primary mission to address food insecurity by providing fresh produce to families in need. You
said you understand the significant impact that access to nutritious food can have on a family’s well-being, and
you are determined to make a difference in your community. In addition to your food distribution efforts, you

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offer monthly outreach services that include activities designed to nurture community connections and promote
inclusivity. Your events will provide a safe space for families to connect, children to learn, and neighbors to
support one another.

You said you’ ve begun to establish strong partnerships with reputable local nonprofits, and other businesses
within the neighborhood. These collaborations are vital in ensuring the success of your programs and
maximizing your impact. By working together, you can create a supportive network that enhances the safety
and educational opportunities for children and fosters a sense of unity among residents. As you continue to
grow, you will gain more community engagement and create additional programming that address community
needs.

Your goals are build around benefits you can provide to the residents of the neighborhood. All initiatives are
aligned with the fundamental principals of community service and support. You have already had summer
markets, regular community educational events, reduced fees for co-working space for residents and more.

Our response to your position

Although you said your primary mission is to address food insecurity, based on the information you provided,
it’s not your primary activity. Providing for the needy is only incidental to your other activities, such as leasing
office space to any interested party and a cooperative grocery store. Even if the facility is in an economically
depressed area, without more, leasing and office space for any interested business or individual is a substantial
non-exempt purpose. You have provided no details about how the cooperative grocery store would work or
when that would begin. You do not restrict the leasing of the property to any particular group or demographic;
rather, you are operating substantially for the non-exempt purpose of owning and managing a commercial
property with only incidental charitable activities. Accordingly, as explained above, because you haven’t
demonstrated that you are operating exclusively for an exempt purpose as described in IRC Section 501(c)(3),
you are not exempt.

Conclusion

You fail both the organizational and operational tests under IRC Section 501(c)(3). Your organizing document
doesn’t limit your purposes to those described in Section 501(c)(3) and your assets aren’t dedicated to exempt
purposes upon your dissolution, You fail the operational test because your commercial-type facility leasing
activities are substantial, further nonexempt purposes, and serve the private interests of a for-profit entity
owned, in part, by one of your Directors. For all of these reasons, each one individually disqualifying, you do
not qualify for exemption under Section 501(c)(3).

If you agree

If you agree with our proposed adverse determination, you don’t need to do anything. If we don’t hear from
you within 30 days, we’ll issue a final adverse determination letter. That letter will provide information on
your income tax filing requirements.

If you don't agree
You have a right to protest if you don’t agree with our proposed adverse determination. To do so, send us a
protest within 30 days of the date of this letter. You must include:

• Your name, address, employer identification number (EIN), and a daytime phone number
• A statement of the facts, law, and arguments supporting your position

Letter 4034 (Rev. 01-2021)
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• A statement indicating whether you are requesting an Appeals Office conference

• The signature of an officer, director, trustee, or other official who is authorized to sign for the
organization or your authorized representative

• The following declaration:

For an officer, director, trustee, or other official who is authorized to sign for the organization:
Under penalties of perjury, I declare that I have examined this request, or this modification to the
request, including accompanying documents, and to the best of my knowledge and belief, the request
or the modification contains all relevant facts relating to the request, and such facts are true, correct,
and complete.

Your representative (attorney, certified public accountant, or other individual enrolled to practice before the
IRS) must file a Form 2848, Power of Attorney and Declaration of Representative, with us if they haven’t
already done so. You can find more information about representation in Publication 947, Practice Before the
IRS and Power of Attorney.

We’ll review your protest statement and decide if you gave us a basis to reconsider our determination. If so,
we’ll continue to process your case considering the information you provided. If you haven’t given us a basis
for reconsideration, we'll send your case to the Appeals Office and notify you. You can find more information
in Publication 892, How to Appeal an IRS Determination on Tax-Exempt Status.

If you don’t file a protest within 30 days, you can’t seek a declaratory judgment in court later because the
law requires that you use the IRC administrative process first IRC Section 7428(b)(2)).

Where to send your protest
Send your protest, Form 2848, if applicable, and any supporting documents to the applicable address:

U.S, mail: Street address for delivery service:
Internal Revenue Service Internal Revenue Service

EO Determinations Quality Assurance EO Determinations Quality Assurance
Mail Stop 6403 550 Main Street, Mail Stop 6403

PO Box 2508 Cincinnati, OH 45202

Cincinnati, OH 45201

You can also fax your protest and supporting documents to the fax number listed at the top of this letter. If you
fax your statement, please contact the person listed at the top of this letter to confirm that they received it.

You can get 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 listed at
the top of this letter,

Contacting the Taxpayer Advocate Service
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 if you’ve tried but haven’t

Letter 4034 (Rev. 01-2021)
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9

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.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Letter 4034 (Rev. 01-2021}
Catalog Number 47628K