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Introduction

SECTION 7. DISCLOSURE OF

Internal Revenue Bulletin 2015-1 · 2026-10-03 edition · updated 2026-10-04 · United States

APPLICATIONS AND DETERMINATION LETTERS

Sections 6104 and 6110 provide rules for the disclosure of applications, including any additional information received by the Service from the organization pursuant to section 5.03, and determination letters.

.01 Disclosure of favorable determina- tions. The favorable determination letters issued by the Service and the associated Forms 1023–EZ (including any additional information received by the Service from the organization) are available for public

inspection under § 6104(a)(1). However, there are certain limited disclosure exceptions for a trade secret, patent, process, style of work, or apparatus, if the Service determines that the disclosure of the information would adversely affect the organization.

(1) The Service is required to make favorable determination letters and the associated applications available upon request. The public can request this information by submitting Form 4506–A, Request for Public Inspection or Copy of Exempt or Political Organization IRS Form . Organizations applying for exemption should ensure that their applications do not include unnecessary personal identifying information (such as bank account numbers or social security numbers) that could result in identity theft or other adverse consequences if publicly disclosed.

(2) The exempt organization is required to make its exemption application and determination letter available for public inspection without charge. For more information about the exempt organization’s disclosure obligations, see Publication 557, Tax-Exempt Status for Your Or- ganization .

.02 Disclosure of adverse determina- tions. The Service is required to make adverse determination letters available for public inspection under § 6110 after the deletion of names, addresses, and other identifying information. Upon issuance of a final adverse determination letter to an eligible organization pursuant to section 5.05, both the proposed adverse determination letter and the final adverse determination letter will be available for public inspection in accordance with section 8.02 of Rev. Proc. 2015–9.

.03 Disclosure to state officials. (1) The Service may disclose to State officials the name, address, and EIN of any organization that has applied for recognition of exemption under § 501(c)(3), including an organization that applies using Form 1023–EZ under this revenue procedure.

(2) The Service may notify the appropriate State officials of a refusal to recognize an organization as tax-exempt under § 501(c)(3). See § 6104(c). The notice to the State officials may include a copy of a proposed or final adverse determination letter or ruling the Service issued to the

organization. The Service does not consider the non-acceptance of an application under section 5.02 to be a refusal. See section 8.03 of Rev. Proc. 2015–9, for more information about disclosure to appropriate State officials in cases where the Service refuses to recognize an organization as exempt under § 501(c)(3).

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