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Archive for Private Letter Ruling

Recent PLRs Highlight: How Not to Run a Charitable Organization

William Byrnes, Tax Advisor

Organizations described in IRC 501(c)(3) and exempt under section 501(a) must be both organized and operated exclusively for exempt purposes. You have failed to produce documents to establish that you are operated exclusively for exempt purposes and that no part of your net earnings inures to the benefit of private shareholders or individuals. You failed to respond to repeated reasonable requests to allow the Internal Revenue Service to examine your records regarding your receipts, expenditures, or activities as required by section 6001 and 6003(a)(1) of the Code and Rev Ruling 59-95, 1959-1 C.B. 627. You did provide information stating that your organization has been inactive and that there have been no operations conducted or planned. As such, you fail to meet the operational requirements for continued exemption under Section 501(c)(3).

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