Rev. Proc. 80-27 does not address the
SECTION 4. ISSUANCE OF GROUP
Internal Revenue Bulletin 2020-21 · 2026-10-03 edition · updated 2026-10-04 · United States
EXEMPTION LETTERS
.01 Group exemption letter requests. The IRS will consider requests from central organizations for group exemption letters made in the manner required by section 5.01 of this revenue procedure and Rev. Proc. 2020-5 (or its successor).
.02 Non-acceptance. A group exemption letter request that is missing any item of information required by section 5 of this revenue procedure will not be considered substantially complete and will not be accepted by the IRS.
.03 Circumstances under which group exemption letters are not ordinarily is- sued. The IRS may decline to issue a group exemption letter where the activities described in the group exemption letter request involve complex facts and circumstances that, in the interest of sound tax administration, are more appropriate for determination on an organization-by-organization basis.
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