Note:

Large Business and International (LB&I) has exam jurisdiction over exempt farmers' cooperatives described under IRC 521.

EO: Modification of an organization’s foundation status occurs when the IRS determines, for example, that an organization is:

A private non-operating foundation, though it claims to be or is currently classified as a public charity, or is currently classified as a private operating foundation.

A private operating foundation, though it claims to be or is currently classified as a public charity.

An IRC 509(a)(3) organization, though it claims to be, or is currently classified as, a IRC 509(a)(1) or IRC 509(a)(2) organization.

An IRC 509(a)(2) organization, though it claims to be, or is currently classified as, a IRC 509(a)(1) organization.

An IRC 509(a)(1) organization, but it should be classified differently under IRC 170(b)(1)(A) than it is currently classified; i.e., a IRC 170(b)(1)(A)(ii) school reclassified as a IRC 170(b)(1)(A)(vi) publicly-supported charity.

EO: A determination subject to Section 7428 also includes any organization that claims to be described in IRC 170(c)(2) that the IRS determines is not.

EO: All revocations are treated the same (per the PATH Act of 2015), with declaratory judgment rights being conferred upon all revoked exempt organizations. Accordingly:

All revocations of IRC 501(c) or (d) organizations follow the same procedures and processes as those previously used for IRC 501(c)(3) organizations.

The IRS will revoke (or treat as revocation for declaratory judgement purposes) any organization that no longer qualifies under the code section for which tax-exemption was granted or self-declared.

This includes self-declarer organizations (Status 36 entities) determined not to qualify under the code section for which they filed a return.