CERTIFIED MAIL -Return Receipt Requested - Final determination letter for IRS tax exemption (IRC Section 501(c)(3))

Sep 15, 2026

Final determination notice issued via certified mail with return receipt requested, revoking a prior IRS exemption decision under Internal Revenue Code (IRC) Section 501(a) for organizations described in IRC Section 501(c)(3). The letter states the organization was not shown to be operated exclusively for charitable, educational, or other exempt purposes and that net earnings would inure to private individuals or shareholders. It cites failure to respond to requests for IRS examination of receipts, expenditures, and activities, and notes contributions may no longer be deductible under IRC Section 170.

LanguageEnglish

CategoryLetters

FormatPDF

Pages13

Reading Time5 min

AccessFree to download

Why we are sending you this letter

What you must do if you disagree with this determination

How to file your action for declaratory judgment

Information about the IRS Taxpayer Advocate Service

Where you can find more information

Enclosures

Release Number:202339027 Release Date:9/29/2023 UIL Code:501.03-00 # 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 IntermalRevenue 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:Organizationsdescribed in IRC Section 501(c)(3)and exempt under IRC Section 501(a)must be both organized and operatedexclusively for charitablc,educational,or other exempt purposes within the meaning of IRC Section 501(c)(3).You have not demonstrated that you are operated exclusively for charitable,educational,or other exemptpurposes within the meaning of IRC Section 501(c)(3)and that no part of your net earnings inure to the benefitof private shareholders or individuals.You failed to respond to repeated reasonable requests to allow theInternal Revenue Service to examine your records regarding your receipts,expenditures,or activities asrequired by IRC sections 6001,6033(a)(1)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 returnsand 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 ifyou disagree with this determination Ifyou want to contest our final determination,you have 90 days from the date this determination letter wasmailed 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 Ifyou decide to contest this determination,you can file an action for declaratory judgment under the provisionsof Section 7428 of the Code in either: ·The United States Tax Court, ·The United States Court of Federal Clams,or ·The United States District Court for the District of Columbia Date:05/04/2023Taxpayer ID number(last 4 digits); Form: Tax periods ended: Person to contact:Name:ID number:Telephone:Fax: Last day to file petition with United StatesTax Court:08/02/2023 You must file a petition or complaint in one of these three courts within 90 days from the date we mailed thisdetermination letter to you.You can download a fillable petition or complaint form and get information aboutfiling at each respective court's website listed below or by contacting the Office of the Clerk of the Court at oneof the addresses below.Be sure to include a copy of this letter and any attachments and the applicable filing feewith the petition or complaint. You can eFile your completed U.S.Tax Court petition by following the instructions and user guides availableon the Tax Court website at ustaxcourt.gov/dawson.html.You will need to register for a DAWSON account todo so.You may also file your petition at the address below: United States Tax Court400 Second Street,NWWashington,DC 20217 ustaxcourt.gov The websites of the IS.Couart of Federal Claims and the LIS.Distric Conrt for the District of Columbia containinstructions about how to file your completed complaint electronically.You may also file your complaint at one ofthe addresses below: US Court ofFederal Claims717 Madison Place,NWWashington,DC 20439uscfc.uscourts.goV US District Court for the District of Columbia 333 Constitution Avenue,NWWashington,DC 20001 ded.useourts.goV Processing of income tax retums and assessments of any taxes due will not he delayed ifyou file a petition fordeclaratory judgment under IRC Section 7428. We'll notify the appropriate state officials (as permitted by law)of our determination that you aren't anorganization described in IRC Section 501(c)(3). ## Information about the IRS Taxpayer Advocate Service The IRS office whose phone

FAQs

What decision does this certified mail determination letter make?

It provides a final determination that the organization does not qualify for exemption from federal income tax under IRC Section 501(a) for organizations described in IRC Section 501(c)(3). It revokes the determination letter dated earlier.

What reasons does the IRS give for revoking exempt status?

The IRS states the organization did not demonstrate it is operated exclusively for charitable, educational, or other exempt purposes under IRC Section 501(c)(3). It also notes the organization failed to respond to repeated reasonable requests for IRS examination of records.

If you disagree, how long do you have and where can you file?

You have 90 days from the date the determination letter was mailed to file a petition or complaint for declaratory judgment. The letter lists the United States Tax Court, the United States Court of Federal Claims, and the United States District Court for the District of Columbia.

Sep 15, 2026

Uploaded by Valentina