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Homeowners Group Is Denied Exemption

FEB. 11, 2015

LTR 201519034

DATED FEB. 11, 2015
DOCUMENT ATTRIBUTES
Citations: LTR 201519034

Contact person/ID number: * * *

 

Contact telephone number: * * *

 

 

UIL Code: 501.32-00

 

Release Date: 5/8/2015

 

Date: February 11, 2015

 

 

Employer ID number: * * *

 

 

Form you must file: * * *

 

 

Tax years: * * *

 

 

Dear * * *:

This letter is our final determination that you don't qualify for tax-exempt status under Section 501(c)(3) of the Internal Revenue Code (the Code). 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 Section 501(c)(3) of the Code, donors can't deduct contributions to you under Section 170 of the Code. You must file federal income tax returns for the tax years listed at the top of this letter using the required form (also listed at the top of this letter) within 30 days of this letter unless you request an extension of time to file.

We'll make this final adverse determination letter and the proposed adverse determination letter available for public inspection (as required under Section 6110 of the Code) after deleting certain identifying information. Please read the enclosed Notice 437, Notice of Intention to Disclose, and review the two attached letters that show our proposed deletions. If you disagree with our proposed deletions, follow the instructions in the Notice 437 on how to notify us. If you agree with our deletions, you don't need to take any further action.

We'll also notify the appropriate state officials of our determination by sending them a copy of this final letter and the proposed determination letter (under Section 6104(c) of the Code). You should contact your state officials if you have questions about how this determination will affect your state responsibilities and requirements.

If you have questions about this letter, you can contact the person listed at the top of this letter. If you have questions about your federal income tax status and responsibilities, call our customer service number at 1-800-829-1040 (TTY 1-800-829-4933 for deaf or hard of hearing) or customer service for businesses at 1-800-829-4933.

Sincerely,

 

 

Tamera Ripperda

 

Director, Exempt Organizations

 

Enclosures:

Notice 437

Redacted Letter 4036, Proposed Adverse Determination Under IRC Section 501(c)(3)

Redacted Letter 4038, Final Adverse Determination Under IRC Section 501(c)(3) -- No Protest

 

* * * * *

 

 

Contact Person: * * *

 

Identification Number: * * *

 

Contact Number: * * *

 

FAX Number: * * *

 

 

UIL: 501.32-00, 501-32-01, 501.33-00

 

Date: November 18, 2014

 

 

Employer Identification Number: * * *

 

 

LEGEND:

 

 

B = Incorporation date

 

C = State

 

D = County

 

 

Dear * * *:

We considered your application for recognition of exemption from federal income tax under Section 501(a) of the Internal Revenue Code (the Code). Based on the information provided, we determined that you don't qualify for exemption under Section 501(c)(3) of the Code. This letter explains the basis for our conclusion. Please keep it for your records.

 

ISSUES

 

 

  • Do you qualify for exemption under section 501(c)(3) of the Code? No, for the reasons described below.

  • Do you meet the requirements under section 501(q) of the Code? No, for the reasons described below.

FACTS

 

 

You are an organization that counsels local homeowners about their options and rights with respect to foreclosure and loan modifications.

You were incorporated on B as a non-profit corporation under C law "to provide education and charitable assistance to the general public by helping people acquire and maintain housing."

All of your directors are experienced in the fields of real estate, housing counseling/services, foreclosure prevention counseling/services and credit/debt management. All three directors also serve as officers. You have adopted a conflict of interest policy with respect to your directors.

Directors will not be paid salaries; however, they may be paid a reasonable fee for attending meetings of the board. In addition, they may be allowed reasonable reimbursement or advancement for expenses incurred in the performance of their duties. Compensation of officers will be reasonable and paid in return for the performance of services related to your tax-exempt purposes. No current plans exist to contract for services from third parties.

Article II of your Bylaws states that your objectives and purposes are to help people own and keep their own homes through:

  • Educational classes and individual counseling for first time home buyers

  • Facilitating down payment assistance for low income home buyers

  • Educational classes to help homeowners keep and maintain their homes

  • Counseling home owners who are having trouble making their monthly payments

  • Working with banks to modify mortgages

  • Facilitating the delivery of rescue funds to help low income homeowners become current on their mortgages

  • Buying homes to keep people from having to move out including facilitating lease or lease with option to buy agreements for seniors who lose their homes

  • Property management, especially of properties in those lease and lease option arrangements

  • Processing short sales agreements and counseling people who are losing their homes on the their housing options

  • Processing mortgage loan applications to enable low and medium income people to buy homes

  • Counseling seniors on reverse mortgages to help them keep their homes

  • Facilitating real estate sales and purchases for low and median income families

 

You will help people own and keep their own homes. You initially considered property management, especially of properties in lease and lease option arrangements, to be your main directive. Several of your activities were expected to generate income. The income producing activities included:
  • Property management,

  • Processing short sale agreements,

  • Counseling people who are losing their homes on the their housing options,

  • Processing mortgage loan applications to enable low and medium income people to buy homes and

  • Facilitating real estate sales and purchases for low and median income families.

 

Funds are also raised through donations, gifts and grants.

You concentrate on helping clients residing in D county but you will not turn away any C residents in need of your services. Low income seniors are your primary focus.

To help clients having trouble making their monthly mortgage payments, you initially planned to offer:

  • Educational classes followed by counseling and working with lenders to facilitate a mortgage modification,

  • Rescue funds to bring mortgages current if a homeowner does not qualify for a loan modification,

  • Education for seniors concerning reverse mortgages,

  • To buy the home in a short sale and rent it back to the client if no other option works,

  • To work with the client to improve their financial situation in order to allow the client to purchase the home back when the lease terminates, or

  • Help process the short sale and counsel the client on their housing options if all else fails.

 

You also intended to educate and counsel first time homebuyers. If a client improved his/her financial situation to the point which would qualify for a home loan, you expected to locate down payment assistance for the purchase. In addition, you would process mortgage applications to help low and medium income people to buy homes and facilitate real estate purchases.

You subsequently made changes to the proposed activities described in your application. You no longer plan to manage or own any properties, process mortgage applications, facilitate real estate sales/purchases, be involved with down payment assistance, or offer pre-purchase housing counseling, post-purchase housing classes, or financial education classes/credit counseling. You will conduct foreclosure prevention counseling 100% of your time. In the future, you estimate your time will be allocated to:

  • Foreclosure prevention counseling -- 20%

  • Pre-purchase housing counseling -- 40%

  • Post purchase housing classes -- 20%

  • Financial education classes and counseling -- 40%

 

When asked to submit detailed descriptions of your proposed pre-purchase housing counseling, post purchase housing classes, and financial education classes and counseling, you stated you no longer expect to provide any of these services.

Foreclosure prevention counseling is your only remaining activity. In conducting this program, you:

  • Interview the clients to obtain financial data as well as information regarding the mortgage delinquency issue,

  • Explain various options such as refinance, loan modification, repayment plan, partial claim, bankruptcy, deed in lieu, or selling the house, and

  • Explain effects of each of the options to assist the client in determining the best option for their situation.

 

Your program involves from one to ten meetings with clients. The initial meeting usually lasts about an hour. At that meeting, the client provides basic financial information and details about the delinquent mortgage. After reviewing the client's responses, you discuss the client's budget based upon the data provided and recommend an approach. The client makes the final decision as to which approach to take. To date, all your clients have chosen apply for the loan modification option. You do not provide a written budget analysis or ongoing educational sessions.

Your counselor assists each client with completing the paperwork to submit a request to the lender for mortgage mitigation. The counselor also communicates with the lender on behalf of the client. While your counselor is a HUD certified housing counselor, you have not (nor expect to) applied for certification as a HUD approved housing counseling agency.

Any subsequent meetings are much shorter (except for the meeting to discuss the mortgage company's determination).

You sometimes refer people to attorneys or real estate agents. A list of bankruptcy attorneys and real estate agents may be provided to clients in need of services; however, no particular individual is recommended.

None of your directors are compensated for providing services to you, and you do not charge a fee for your program.

 

LAW

 

 

Section 501(c)(3) of the Code provides that corporations may be exempted from tax if they are organized and operated exclusively for charitable or educational purposes and no part of their net earnings inures to the benefit of any private shareholder or individual.

Section 1.501(c)(3)-1(a)(1) of the Income Tax Regulations ("regulations") provides that, in order to be exempt as an organization described in section 501(c)(3) of the Code, 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.

Section 1.501(c)(3)-1(b)(1)(i) of the regulations provides that an organization is organized exclusively for one or more exempt purposes only if its articles of organization:

 

(a) Limit the purposes of such organization to one or more exempt purposes; and

(b) Do not expressly empower the organization to engage, otherwise than as an insubstantial part of its activities, in activities that in themselves are not in furtherance of one or more exempt purposes.

 

Section 1.501(c)(3)-1(b)(4) of the regulations provides that an organization's assets must be dedicated to an exempt purpose, either by an express provision in its governing instrument or by operation of law.

Section 1.501(c)(3)-1(c)(1) of the regulations provides that an organization will be regarded as "operated exclusively" for one or more exempt purposes only if it engages primarily in activities that accomplish one or more of such exempt purposes specified in section 501(c)(3) of the Code. An organization will not be so regarded if more than an insubstantial part of its activities is not in furtherance of an exempt purpose.

Section 1.501(c)(3)-1(d)(1)(ii) of the regulations assigns the burden of proof to an applicant organization to show that it serves a public rather than a private interest and specifically that it is not organized or operated for the benefit of private interests, such as designated individuals, the creator or his family, shareholders of the organization, or persons controlled, directly or indirectly, by such private interests.

Section 1.501(c)(3)-1(d)(2) of the regulations provides that the term "charitable," is used in section 501(c)(3) in its generally accepted legal sense and includes the relief of the poor and distressed or of the underprivileged.

Section 1.501(c)(3)-1(d)(3)(i) of the regulations provides that the term "educational," as used in section 501(c)(3) of the Code, relates to:

 

(a) The instruction or training of the individual for the purpose of improving or developing his capabilities; or

(b) The instruction of the public on subjects useful to the individual and beneficial to the community.

 

Section 501(q) imposes requirements on organizations otherwise described in § 501(c)(3) or (4) if "the provision of credit counseling services is a substantial purpose."

Section 501(q)(4)(A) defines, for purposes of § 501(q), the term "credit counseling services" to mean (i) the providing of educational information to the general public on budgeting, personal finance, financial literacy, saving and spending practices, and the sound use of consumer credit, (ii) the assisting of individuals and families with financial problems by providing them with counseling, or (iii) a combination of the activities described in clauses (i) and (ii).

In Rev. Rul. 69-441, 1969-2 C.B. 115, the Service found that a nonprofit organization formed to help reduce personal bankruptcy by informing the public on personal money management and aiding low-income individuals and families with financial problems was exempt under section 501(c)(3) of the Code. Its board of directors was comprised of representatives from religious organizations, civic groups, labor unions, business groups, and educational institutions.

The organization provided information to the public on budgeting, buying practices, and the sound use of consumer credit through the use of films, speakers, and publications. It aided low-income individuals and families who have financial problems by providing them with individual counseling, and if necessary, by establishing budget plans. Under the budget plan, the debtor voluntarily made fixed payments to the organization, holding the funds in a trust account and disbursing the funds on a partial payment basis to the creditors. The organization did not charge fees for counseling services or proration services. The debtor received full credit against his debts for all amounts paid. The organization did not make loans to debtors or negotiate loans on their behalf. Finally, the organization relied upon contributions, primarily from the creditors participating in the organization's budget plans, for its support.

The Service found that, by aiding low-income individuals and families who have financial problems and by providing, without charge, counseling and a means for the orderly discharge of indebtedness, the organization was relieving the poor and distressed. Moreover, by providing the public with information on budgeting, buying practices, and the sound use of consumer credit, the organization was instructing the public on subjects useful to the individual and beneficial to the community. Thus, the organization was exempt from federal income tax under section 501(c)(3) of the Code.

The Service compared this holding with the holding of Rev. Rul. 65-299, which holds that a nonprofit organization formed to advise, counsel, and assist individuals in solving their financial difficulties by budgeting their income and expenses and effecting an orderly program for the payment of their obligations qualifies for exemption from Federal income tax under section 501(c)(4) of the Code (rather than under section 501(c)(3)).

Outside the context of credit counseling, individual counseling has, in a number of instances, been held to be a tax exempt charitable activity. Rev. Rul. 78-99, 1978-1 C.B. 152 (free individual and group counseling of widows); Rev. Rul. 76-205, 1976-1 C.B. 154 (free counseling and English instruction for immigrants); Rev. Rul. 73-569, 1973-2 C.B. 178 (free counseling to pregnant women); Rev. Rul. 70-590, 1970-2 C.B. 116 (clinic to help users of mind-altering drugs); Rev. Rul. 70-640, 1970-2 C.B. 117 (free marriage counseling); Rev. Rul. 68-71, 1968-1 C.B. 249 (career planning education through free vocational counseling and publications sold at a nominal charge). Overwhelmingly, the counseling activities described in these rulings were provided free, and the organizations were supported by contributions from the public.

Rev. Proc. 86-43, 1986-2 C.B. 729, describes the methodology test the Internal Revenue Service uses to determine when the advocacy of a particular viewpoint or position is educational under sections 501(c)(3) of the Code and 1.501(c)(3)-1(d)(3) of the regulations. The revenue procedure states that the focus of section 1.501(c)(3)-1(d)(3) is on the method the organization uses to communicate to others, not the content of its communication. The method of communication is not educational "if it fails to provide a development from the relevant facts that would materially aid a listener or reader in a learning process." One factor indicating the method is not educational is as follows: "[t]he approach used in the organization's presentations is not aimed at developing an understanding on the part of the intended audience or readership because it does not consider their background or training in the subject matter." The remaining factors relate specifically to advocacy organizations and the "full and fair exposition" part of the regulation.

In Better Business Bureau of Washington, D.C v. U.S., 326 U.S. 279, 283, 66 S. Ct. 112, 90 L. Ed. 67 (1945), the Supreme Court held that the "presence of a single . . . [nonexempt] purpose, if substantial in nature, will destroy the exemption regardless of the number or importance of truly . . . [exempt] purposes."

In B.S.W. Group, Inc. v. Commissioner, 70 T.C. 352 (1978), the court found that a corporation formed to provide consulting services did not satisfy the operational test under section 501(c)(3) of the Code because its activities constituted the conduct of a trade or business that is ordinarily carried on by commercial ventures organized for profit. Its primary purpose was not charitable, educational, or scientific, but rather commercial. In addition, the court found that the organization's financing did not resemble that of the typical section 501(c)(3) organizations. It had not solicited, nor had it received, voluntary contributions from the public. Its only source of income was from fees from services, and those fees were set high enough to recoup all projected costs and to produce a profit. Moreover, it did not appear that the corporation ever planned to charge a fee less than "cost." And finally, the corporation did not limit its clientele to organizations that were section 501(c)(3) exempt organizations.

In Consumer Credit Counseling Service of Alabama, Inc. v. United States, 78-2 U.S.T.C. 9660 (D.D.C. 1978), the court held that an organization that provided free information on budgeting, buying practices, and the sound use of consumer credit qualified for exemption from income tax because its activities were charitable and educational.

The Consumer Credit Counseling Service of Alabama is an umbrella organization made up of numerous credit counseling service agencies. These agencies provided information to the general public through the use of speakers, films, and publications on the subjects of budgeting, buying practices, and the sound use of consumer credit. They also provided counseling on budgeting and the appropriate use of consumer credit to debt-distressed individuals and families. They did not limit these services to low-income individuals and families, but they did provide such services free of charge. As an adjunct to the counseling function, they offered a debt management plan. Approximately 12 percent of a professional counselor's time was applied to the debt management plan as opposed to education. The agencies charged a nominal fee of up to $10 per month for the debt management plan. This fee was waived in instances when payment of the fee would work a financial hardship.

The professional counselors employed by the organizations spent about 88 percent of their time in activities such as information dissemination and counseling assistance rather than those connected with the debt management programs. The primary sources of revenue for these organizations were provided by government and private foundation grants, contributions, and assistance from labor agencies and United Way. An incidental amount of their revenue was from service fees. Thus, the court concluded that "each of the plaintiff consumer credit counseling agencies was an organization described in section 501(c)(3) as a charitable and educational organization." See also, Credit Counseling Centers of Oklahoma, Inc. v. United States, 79-2 U.S. Tax Case. 9468 (D.D.C. 1979), in which the facts were virtually identical and the law was identical to those in Consumer Credit Counseling Service of Alabama, Inc. v. United States, discussed immediately above.

In Solution Plus, Inc. v. Commissioner, T.C. Memo. 2008-21, the Tax Court held that a credit counseling organization was not exempt under section 501(c)(3) because it was not organized and operated exclusively for educational or charitable purposes and impermissibly served private interests. The organization was formed by an individual with experience selling debt management plans. The founder and his spouse were the only members of the organization's board of directors. The organization did not have any meaningful educational program or materials for providing to people who contacted the organization, and its financial education seminars for students constituted an insignificant part of the organization's overall activities.

The Court held that the organization's purposes were not educational because its "activities are primarily structured to market, determine eligibility for, and enroll individuals in DMPs." Its purposes are not to inform consumers "about understanding the cause of, and devising personal solutions to, consumers' financial problems," or "to consider the particular knowledge of individual callers about managing their personal finances." The Tax Court also held that the organization's purposes were not charitable because "its potential customers are not members of a [charitable] class that are benefited in a 'non-select manner * * * because they will be turned away unless they meet the criteria of the participating creditors."

The Tax Court further held the organization would operate for the private interests of its founder because the founder and spouse were the only directors, the founder was the only officer and employee, and his compensation was based in part on the organization's DMP sales activity levels. The organization was "a family-controlled business that he personally would run for financial gain, using his past professional experience marketing DMPs and managing a DMP call center." The Court further held that the organization's principal activity of providing DMP services, which were only provided if approved by a caller's creditors, furthered the benefit of private interests.

Finally, the Tax Court held that the facts in Credit Counseling Services of Alabama v. United States, 78-2 U.S.T.C. 9660 (D.D.C. 1978) "stand in stark contrast" because "the sale of DMPs is the primary reason for [Solution Plus's] existence, and its charitable and educational purposes are, at best, minimal."

 

APPLICATION OF LAW

 

 

Section 501(c)(3) of the Code sets forth two main tests for an organization to be recognized as exempt. An organization must be both organized and operated exclusively for purposes described in section 501(c)(3). Section 1.501(c)(3)-1(a)(1) of the Regulations.

To satisfy the section 501(c)(3) operational test, an organization must establish that it is operated exclusively for one or more exempt purposes. Section 1.501(c)(3)-1(c)(1) of the Regulations. You failed to establish that you are operated exclusively for one or more exempt purposes.

Your Activities Are Not Educational

You are distinguishable from the organizations in Consumer Credit Counseling Service of Alabama, supra, and Rev. Rul. 69-441 by the methodology you use to conduct your counseling activities. To date, you have not held any seminars, clinics, workshops or other educational programs. The only activity that you currently conduct is the provision of foreclosure counseling and the processing of loan modifications. You typically meet with clients only once for about an hour before recommending a particular approach. Clients provide you with basic financial information as well as information regarding their delinquent mortgage. You do not provide a written budget analysis to clients. Unlike the organizations in Consumer Credit Counseling Service of Alabama, supra, and Rev. Rul. 69-441, supra, you do not offer counseling sessions that are structured primarily to improve your clients' understanding of their financial problems or their skills in solving them. While your counselor does explain options to the client, essentially all of your time is spent filling out the information that is needed to submit a statement of their financial condition to the lender. Communicating with a homeowner to fill out a financial worksheet and an intake sheet is not an educational activity because the communication does not provide a development from the relevant facts that would materially aid a listener or reader in a learning process. Rev. Proc. 86-43, supra.

You do not provide an ongoing educational program to your clients. Your counseling sessions are used solely to solicit the information required to submit a statement of financial condition to the lender in an effort to obtain a loan modification. Finally, a significant amount of your time is spent on the negotiation process with the lender. Therefore, you failed to establish that your interactions with clients provide instruction or training "useful to the individual and beneficial to the community" within the meaning of Section 1.501(c)(3)-1(d)(3)(i) of the Regulations.

You do not operate a substantive on-going educational program. You do not dedicate any revenue to activities involving educational programs. You do not allocate any expenses to training employees. Like the organization in Solution Plus, supra, you did not provide evidence that you help clients develop an understanding of the cause of their financial problems or a plan to address their financial problems. You provided no evidence that you intend to establish long-term counseling relationships with your clients. Thus, your activities are not educational within the meaning of section 501(c)(3).

In addition, you do not meet the requirements for consideration under section 501(q) of the Code because you do not provide educational information or counseling to the public.

Your Activities Are Not Charitable

All of your time and resources are devoted to providing foreclosure prevention services to individuals. While you stated that your primary focus is on seniors, you offer your services to any resident of C. Therefore, your services are not directed exclusively to low-income individuals or any other recognized charitable class. Accordingly, you are unlike the organizations described in Consumer Credit Counseling Service of Alabama, supra and Rev. Rul. 69-441, supra, which aided low-income individuals and families who have financial problems, thereby relieving the poor and distressed. Thus, you failed to establish that your activities are charitable within the meaning of Section 501(c)(3) of the Code.

Private Benefit

An organization is not organized or operated exclusively for exempt purposes unless it serves a public rather than a private interest. See Section 1.501(c)(3)-1(d)(1)(ii) of the Regulations. Your financial assistance to homeowners in refinancing their mortgages directly benefits the homeowner by performing a service that they would otherwise have to provide themselves.

Therefore, you have not demonstrated that your operations serve a public rather than a private interest as required by Section 1.501(c)(3)-1(d)(1)(ii) of the Regulations.

 

CONCLUSION

 

 

Based on the facts and information provided, you are not operated exclusively for an exempt purpose as required by Sections 1.501(c)(3)-1(a)(1) and 1.501(c)(3)-1(c)(1) of the Regulations because you are not educating your clients nor do you provide your services to poor or distressed individuals. Any public purposes for which you may operate are only incidental to your primary nonexempt purpose of assisting clients with obtaining a mortgage modification or otherwise deal with a foreclosure. You do not serve a public rather than a private interest as required by Section 1.501(c)(3)-1(d)(1)(ii) of the Regulations. Accordingly, you do not qualify for exemption as an organization described in Section 501(c)(3) of the Code.

If you don't agree

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

  • Your name, address, employer identification number (EIN), and a daytime phone number

  • A copy of this letter highlighting the findings you disagree with

  • An explanation of why you disagree, including any supporting documents

  • The law or authority, if any, you are relying on

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

  • One of the following declarations:

  •  

    For an officer, director, trustee, or other official who is authorized to sign for the organization:

    Under penalties of perjury, I declare that I examined this protest statement, including accompanying documents, and to the best of my knowledge and belief, the statement contains all relevant facts and such facts are true, correct, and complete.

    For authorized representatives:

    Under penalties of perjury, I declare that I prepared this protest statement, including accompanying documents, and to the best of my knowledge and belief, the statement contains all relevant facts 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 he or she hasn'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 provided a basis for us to reconsider our determination. If so, we'll continue to process your case considering the information you provided. If you haven't provided a basis for reconsideration, we'll forward your case to the Office of Appeals and notify you. You can find more information about the role of the Appeals Office in Publication 892, How to Appeal an IRS Decision on Tax-Exempt Status.

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

Where to send your protest

Please send your protest statement, Form 2848, if needed, and any supporting documents to the applicable address:

U.S. mail:

 

 

Internal Revenue Service

 

EO Determinations Quality Assurance

 

Room 7-008

 

P.O. Box 2508

 

Cincinnati, OH 45201

 

 

Street address for delivery service:

 

 

Internal Revenue Service

 

EO Determinations Quality Assurance

 

550 Main Street, Room 7-008

 

Cincinnati, OH 45202

 

 

You can also fax your statement 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 he or she received it.

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.

You can find all forms and publications mentioned in this letter on our website at www.irs.gov/formspubs. If you have questions, you can contact the person listed at the top of this letter.

Sincerely,

 

 

Director, Exempt Organizations

 

Enclosure:

 

Publication 892
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