IRS Denies Organization Tax-Exempt Status

Person to Contact: * * *
Employee ID Number: * * *
Tel: * * *
Fax: * * *

UIL: 501.04-00
Release Date: 4/24/2020

Date: December 30, 2019

Employer Identification Number: * * *

Form: * * *

Tar Period(s) Ended: * * *

Dear * * *:

This is a final determination explaining why your organization does not qualify as an organization described in section 501(c)(4) of the Internal Revenue Code (the “Code”) for the tax periods listed above.

This letter is not a determination of (1) your exempt status for any periods other than the tax periods listed above or (2) whether your organization qualifies as an organization described in any other paragraph of section 501(c). In the future, if you believe your organization qualifies for tax exempt status and would like to establish its status, you may request a determination from the Internal Revenue Service by filing Form 1024, Application for Recognition of Exemption Under Section 501(a), or Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code, (as applicable) and paying the required user fee.

Our adverse determination as to your exempt status was made for the following reasons:

* * * is not an organization described in section 501(c)(4) of the Internal Revenue Code because it is not a civic league or organization operated exclusively for the promotion of social welfare. It is not primarily engaged in promoting in some way the common good and general welfare of the people of the community. Its primary activity is to promote the business interests of its members.

We’ll make this letter and the proposed adverse determination letter available for public inspection under Code section 6110 after deleting certain identifying information. We have provided to you, in a separate mailing, Notice 437, Notice of Intention to Disclose. Please review the Notice 437 and the documents attached that show our proposed deletions. If you disagree with our proposed deletions, follow the instructions in Notice 437.

If you decide to contest this determination, you may file an action for declaratory judgment under the provisions of section 7428 of the Code in one of the following three venues: 1) United States Tax Court, 2) the United States Court of Federal Claims, or 3) the United States District Court for the District of Columbia. A petition or complaint in one of these three courts must be filed within 90 days from the date this determination letter was mailed to you. Please contact the clerk of the appropriate court for rules and the appropriate forms for filing petitions for declaratory judgment by referring to the enclosed Publication 892. You can write to the courts at the following addresses:

You may also be eligible for help from the Taxpayer Advocate Service (TAS). 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 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 1-877-777-4778.

If you have any questions about this letter, please contact the person whose name and telephone number are shown in the heading of this letter.

Sincerely,

* * *
Appeals Team Manager

---

Person to Contact: * * *
Employee ID: * * *
Telephone: * * *
Fax: * * *
Manager’s Contact Information: * * *
Employee ID: * * *
Telephone: * * *

UIL: 501.04-00

Date: August 29, 2018

Taxpayer Identification Number: * * *

Form: 990 Return

Tax Year(s) Ended: December 31, 20* * *
December 31, 20* * *

Response Due Date: September 28, 2018

Dear * * *:

Why you’re receiving this letter

We enclosed a copy of our audit report, Form 888-A, Explanation of Items, explaining that your organization doesn’t qualify as an organization described in Internal Revenue Code (IRC) Section 501(c)(4).

This letter is not a determination of your tax-exempt status under IRC Section 501 for any period other than the tax periods above.

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. Well issue a final adverse letter determining that you aren't an organization described in IRC Section 501(c)(4) for the periods above.

If you disagree

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, well issue a final adverse determination letter.

In the future, if you believe your organization qualifies for tax-exempt status and would like a status determination letter from the IRS, you can request a determination by filing Form 1024, Application for Recognition of Exemption Under Section 501(a), and paying the required user fee.

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 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.

For 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.

Sincerely,

Maria Hooke
Director, Exempt Organizations
Examinations

Enclosures:
Form 886-A
Form 6018