Part III. Administrative, Procedural, and Miscellaneous

reasonably estimated to be nondeductible for the following taxable year by the amount of the underestimate.

Section 6033(e)(3) provides that § 6033(e)(1)(A) shall not apply to an exempt organization that establishes to the satisfaction of the Secretary that substantially all the dues or similar amounts paid by persons to the organization are not deductible without regard to § 162(e). The tax imposed by § 6033(e)(2)(A) only applies to organizations subject to the notice requirements of § 6033(e)(1)(A).