Exempt status revoked after organization failed to provide records

Plain-English summary

The IRS issued a final determination that an organization did not qualify for federal income tax exemption under IRC Section 501(c)(3). The organization did not provide records about its receipts, expenditures, activities, or operations, so the IRS concluded that it had not shown that it met the operational and reporting requirements for continued exemption. The IRS revoked the organization's prior determination letter and stated that contributions to it were no longer deductible under IRC Section 170. The released materials also explain the organization's right to seek declaratory judgment in the Tax Court, Court of Federal Claims, or District Court for the District of Columbia under IRC Section 7428.

Ruling snapshot

• Question: Did the organization continue to qualify for exemption under IRC Section 501(c)(3)?
• Outcome: Revocation
• Key authorities: IRC §§ 170, 501(a), 501(c)(3), 6001, 6033, 7428; Treas. Reg. §§ 1.501(c)(3)-1(c), 1.6001-1(c), 1.6001-1(e), 1.6033-1(a)(1), 1.6033-1(h)(2); Rev. Rul. 59-95

Full text (IRS public release)

Department of the Treasury Date:
Internal Revenue Service January 30, 2026

Tax Exempt and Government Entities Taxpayer ID number (last 4 digits): Form:

Tax periods ended:

Person to contact:

ID number:
Telephone:

Release Number: 202633011
Tax Court:
UIL Code: 501.03-00 April 30, 2026

CERTIFIED MAIL - Return Receipt Requested

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 a. is revoked.

Our adverse determination as to your exempt status was made for the following reasons: You have not demonstrated that you meet the operational test under Treas. Reg. § 1.501(c)(3)-1(c) because you did not produce records regarding your receipts, expenditures, or activities to demonstrate that you were operated exclusively for charitable, educational, or other exempt purposes within the meaning of IRC Section 501(c)(3), nor that your net earnings did not inure in whole or in part to the benefit of private shareholders or individuals. In addition, you did not provide any information relating to your operations during the examination as required by IRC Sections 6001, 6033(a)(1) and Treas. Reg. § 1.6033-2(i)(2). As such, you fail to meet the conditions required 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.

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

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

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 filing 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 the letter.

If you prefer to write, use the address shown at the top of the letter. Include your telephone number, the best time to call, and a copy of this letter.

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:
Internal Revenue Service 02/[illegible]/2024

Tax Exempt and Government Entities

Taxpayer ID number:

Tax periods ended:

Person to contact:

ID number:
Telephone:

CERTIFIED MAIL - Return Receipt Requested

ID number:
Telephone:

Response due date:
03/14/2024

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.

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 the 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 tax problem. 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.

Director, Exempt Organizations Examinations

Enclosures:
Form 886-A
Form 6018

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

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

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

ISSUE
Whether qualifies for exemption from Federal income

tax under section 501(c)(3) of the Internal Revenue Code as a charitable organization?

FACTS

was formed in and is recognized as an IRC
Sections 170(b)(1)(A)(vi) tax-exempt with an effective date of

the articles of incorporation dated , state the purpose of the organization.

IRS records show that taxpayer filed an annual Form 990-N electronic notice (e-Postcard) for tax

year ending and the organization indicated that its gross receipts is $50,000 or less. The notice of examination package is dated and consists of Letter 6031 Initial

Examination Appointment, Letter 5464 Information Document Request cover letter, Form 4564 Information Document Request (IDR), Publication 1 Your Rights as a Taxpayer, Notice 609 Privacy Act Notice, Publication 3498-A The Examination Process (Audits by Mail), Publication 5295 Secure Messaging for TE/GE and Form 15314 TEGE Secure Messaging Taxpayer Agreement Authorization of Disclosure to Designated Users.

The notice of examination package was mailed to Exempt
Organization (EO) at the last known address on file for the organization which is as follows:

The response due date for the examination package was

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 (May 2017) Explanations of Items

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

On the examination package was delivered at the and the individual picked up certified mail as indicated in tracking website. The examination package was not returned by the as undeliverable. On , the agent called Secretary/Treasurer at was busy. Called CEO at a female picked up the phone and she advised that I should call in the afternoon. Spoke to former CEO , former

CEO mentioned that he does not work for the organization and I should contact Treasurer Commissioner, then hung up. Called again and left a voice message about the point of contact for the organization.

On , the agent left a voice message to the former CEO requesting a call back about the point of contact for the new officers in the organization. Received voice message from unknown person on , phone number and she advised me to call

called phone number , spoke to the operator and she transferred me to clerk recording office and I left a detailed voice message.

, consists of Letter 5077-B TE/GE IDR Delinquency Notice, Form 4564 Information Document Request (IDR) with a due date. The delinquency notice was mailed to Exempt Organization (EO) at the last known address on file for the organization which is as follows:

The delinquency notice was delivered at the and individual picked up certified mail as indicated in tracking website. The delinquency notice was not returned by the as undeliverable.

LAWS

Section 170(b)(1)(A)(vi) an organization referred to in subsection (c)(2) which normally receives a substantial part of its support (exclusive of income received in the exercise or performance by such organization of its charitable, educational, or other purpose or function constituting the basis

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 (May 2017) Explanations of Items

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

for its exemption under section 501(a)) from a governmental unit referred to in subsection (c)(1) or

from direct or indirect contributions from the general public.
Section 501(c)(3) of the Code provides that an organization organized and operated exclusively

for charitable or educational purposes is exempt from Federal income tax, provided no part of its net earnings inures to the benefit of any private shareholder or individual.

Treas. Reg. § 1.6001-1(c) provides that in addition to such permanent books and records as are required by paragraph (a) of this section with respect to the tax imposed by section 511 on unrelated business income of certain exempt organizations, every organization exempt from tax under section 501(a) shall keep such permanent books of account or records, including inventories, as are sufficient to show specifically the items of gross income, receipts and disbursements. Such organizations shall also keep such books and records as are required to substantiate the information required by section 6033. See section 6033 and §§ 1.6033-1 through 1.6033-3.

Treas. Reg. § 1.6001-1(e) provides that the books or records required by this section shall be kept at all times available for inspection by authorized internal revenue officers or employees, and shall be retained so long as the contents thereof may become material in the administration of any internal revenue law.

Treas. Reg. § 1.6033-1(a)(1) provides that 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.

Treas. Reg. § 1.6033-1(h)(2) provides that every organization which is exempt from tax, whether or not it is required to file an annual information return, shall submit such additional information as may be required by the Internal Revenue Service for the purpose of inquiring into its exempt status and administering the provisions of subchapter F (section 501 and following), chapter 1 of subtitle A of the Code, section 6033, and chapter 42 of subtitle D of the Code.

See section 6001 and § 1.6001-1 with respect to the authority of the district directors or directors of service centers to require such additional information and with respect to the books of account or records to be kept by such organizations.

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 (May 2017) Explanations of Items

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

Rev. Rul. 59-95, 1959-1 C.B. 627, concerns an exempt organization that was requested to produce a financial statement and statement of its operations for a certain year. However, its records were so incomplete that the organization was unable to furnish such statements. The Service held that the failure or inability to file the required information return or otherwise to comply with the provisions of IRC § 6033 and the regulations which implement it, may result in the termination of the exempt status of an organization previously held exempt, on the grounds that the organization has not established that it is observing the conditions required for the continuation of exempt status.

GOVERNMENT'S POSITION

Treas. Reg. § 1.6001-1(c) and § 1.6033(a)(1) provide that 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 return and the retention of records sufficient to determine whether such exempt organization 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 organization has failed repeatedly to respond to the Service’s request for information in contrast to section 1.6033-1(h)(2) of the regulations which require an organization to provide such information as requested to allow the Internal Revenue Service to make a determination of the organization’s exempt status.

The organization failed to meet the reporting requirements under Treas. Reg. § 1.6001-1(c) and

§ 1.6033(a)(1) to be recognized as exempt from federal income tax under Section 501(c)(3). Internal Revenue Service proposed that the organization's exempt status be revoked effective

TAXPAYER’S POSITION

The taxpayer's position is unknown at this time.

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 (May 2017) Explanations of Items

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

Conclusion:

It is the Internal Revenue Service position that the organization does not qualify for exemption from federal income tax under Section 501(c)(3) because it did not meet its reporting requirements for exemption. The proposed date of the revocation is

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