EO Central Organization 90-Day Final Adverse Determination Letter (501(c))

Internal Revenue Service

Department of the Treasury

TE/GE Exempt Organizations Examinations [Enter EO Mandatory Review Manager’s Address]

Date: [Insert date]

Taxpayer Identification Number: [Insert TIN] Person to Contact: [Insert name of reviewer] Employee Identification Number: [Insert ID Number]

[Insert name of entity] [Insert attention line] [Insert street address] [Insert city, state, and zip code]

Employee Telephone Number: [Insert phone number] (Phone) [Insert fax number] (Fax)

CERTIFIED MAIL

Dear [Sir or Madam]:

This is a final adverse determination regarding your exempt status under section 501(c)[_] of the Internal Revenue Code (the Code). Our favorable determination letter to you dated [date] is hereby revoked and you are no longer exempt under section 501(a) of the Code effective [date].

The revocation of your exempt status was made for the following reason[s]:

[Insert applicable and appropriate summary of the reasons for the revocation.]

Contributions to your organization are no longer deductible. {Note: If, the organization has deductibility code "2" , this paragraph is not applicable}

Revenue Procedure 80-27 provides guidance on group exemptions. According to this revenue procedure, when we terminate your tax exemption, we also terminate your group exemption. Effective [date], your Group Exemption Number [insert GEN] is no longer valid. Please tell your subordinates of this action. Each subordinate seeking recognition of tax exemption should file an individual application or file a Form 990 series return, as appropriate.

You are required to file federal tax returns for the tax period(s) shown above. Unless an extension of time is granted or the returns are already filed, send them to Ogden Service Center within 60 days from the date on this letter. Returns for later years are filed with the appropriate service center indicated in the return instructions.

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 venues:

• • •

the United States Tax Court the United States Court of Federal Claims the United States District Court for the District of Columbia

A petition or complaint in one of these three courts must be filed before the 91st day after the date this determination was mailed to you if you wish to seek review of our determination. Please contact the clerk of the respective court for rules and the appropriate forms regarding filing petitions for declaratory judgment by referring to the enclosed Publication 892. Please note that the United States Tax Court is the only one of these courts where a declaratory judgment action can be pursued without the services of a lawyer. You may write to the courts at the following addresses:

United States Tax Court 400 Second Street, NW Washington, DC 20217

U.S. Court of Federal Claims 717 Madison Place, NW Washington, DC 20005

U. S. District Court for the District of Columbia 333 Constitution Ave., N.W. Washington, DC 20001

Filing a petition for declaratory judgment however, does not delay the processing of income tax returns and assessments of any taxes due. A petition or complaint must be filed in one of these 3 courts before the 91st day after the date this determination was mailed to you.

You have the right to contact the Taxpayer Advocate Service. Their assistance is not a substitute for established IRS procedures, such as the formal appeals process. They cannot reverse a legally correct tax determination, or extend the time fixed by law that you have to file a petition in a United States court. However, they can see that a tax matter that may not have been resolved through normal channels gets prompt and proper handling. You may call toll-free 1-877-777-4778 and ask for Taxpayer Advocate assistance. If you prefer, you may contact your local Taxpayer Advocate at:

Internal Revenue Service Taxpayer Advocate Service [1st Line Address] [2nd Line Address] [City, State, Zip] [Phone Number]

If you have any questions, please contact the person listed above.

Sincerely,

[Insert name] Director, EO Examinations

Enclosures: Publication 892 Form 6018, Consent to Proposed Action - Section 7428