SECTION 5. RETROACTIVE

REINSTATEMENT OF TAX-EXEMPT STATUS WITHIN 15 MONTHS OF REVOCATION.

.01 An organization that is not eligible to apply under SECTION 4 of this revenue procedure may apply to have its taxexempt status retroactively reinstated effective from the Revocation Date if it does all of the following:

(1) Completes and submits the appro priate Application to the address provided in the instructions to the Application not later than 15 months after the later of the date of the Revocation Letter or the date on which the IRS posted the organization’s name on the Revocation List. To facilitate processing, organizations should write “Revenue Procedure 2014–11, Retroactive Reinstatement” on top of the Application. (2) Includes the appropriate user fee

with the Application. See Rev. Proc. 2013–8, 2013–1 I.R.B. 237, section 6.07, or its successor. (3) Includes the Reasonable Cause Statement described in SECTION 8.01 of this revenue procedure with the Application; (4) Includes a statement with the Ap plication confirming that it has filed the Annual Returns required in step (5) below. (5) Files properly completed and exe cuted paper Annual Returns for all

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have been or will be taken to avoid or mitigate future failures.

.05 The following factors would weigh in favor of finding reasonable cause (with no single factor being either necessary or determinative):

(1) The organization’s failure was due to its reasonable, good faith reliance on erroneous written information from the IRS, stating that the organization was not required to file a return or notice under section 6033, provided the IRS was made aware of all relevant facts; (2) The failure to file the return or notice arose from events beyond the organization’s control (“impediment”) that made it impossible for the organization to file a return or notice for the year; (3) The organization acted in a responsible manner by undertaking significant steps to avoid or mitigate the failure to file the required return or notice and to prevent similar failures in the future, including, but not limited to— (a) Attempting to prevent an impedi ment or a failure, if it was foreseeable; (b) Acting as promptly as possible to

remove an impediment or correct the cause of the reporting failure, once the failure was discovered; and (c) After the failure was discovered,

implementing safeguards designed to ensure future compliance with the reporting requirements under section 6033; and (4) The organization has an established history of complying with its reporting requirements (if any) under section 6033 and/or any other applicable reporting or other requirements under the Code.

.06 The Reasonable Cause Statement must also include an original declaration, dated and signed under penalties of perjury by an officer, director, trustee, or other official who is authorized to sign for the organization in the following form:

I, (Name), (Title) declare, under penalties of perjury, that I am authorized to sign this request for retroac

taxable years in the consecutive three-year period for which the organization was required, and failed, to file Annual Returns (and for any other taxable years after such period and before the Post-Mark Date for which required returns were due and not filed). The Annual Returns must be mailed to the following address:

Department of the Treasury Internal Revenue Service Center Ogden, UT 84201-0027

.02 The Service will not impose the penalty under section 6652(c) for the failure to file Annual Returns for the three consecutive taxable years for which the organization was required, but failed, to file Annual Returns, if the organization’s Application is approved, it satisfies all the requirements of SECTION 5.01 of this revenue procedure, and the organization is retroactively reinstated effective from the Revocation Date. The organization should write “Retroactive Reinstatement” on the Annual Returns.