SECTION 1. WHAT IS

THE PURPOSE OF THIS REVENUE PROCEDURE?

Description of terms used in this revenue procedure

This revenue procedure sets forth procedures for issuing determination letters on issues under the jurisdiction of the Director, Exempt Organizations (EO) Rulings and Agreements. Specifically, it explains the procedures for issuing determination letters on tax-exempt status (in response to applications for recognition of exemption from federal income tax under §§ 501 or 521 other than those subject to Rev. Proc. 2025-4, this Bulletin (relating to pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans)), private foundation status, and other determinations related to tax-exempt organizations. These procedures also apply to revocation or modification of determination letters. This revenue procedure also provides guidance on the exhaustion of administrative remedies for purposes of declaratory judgment under § 7428. Finally, this revenue procedure provides guidance on applicable user fees for requesting determination letters.

.01 For purposes of this revenue procedure—

December 30, 2024 262 Bulletin No. 2025–1

(1) The term “Service” means the Internal Revenue Service.

(2) The term “EO Rulings and Agreements” means the office in Exempt Organizations & Government Entities that is primarily responsible for up-front, customer-initiated activities such as determination letter requests, taxpayer assistance, and assistance to other Exempt Organizations & Government Entities offices. The EO Rulings and Agreements office includes the offices of EO Determinations and EO Determinations Quality Assurance.

(3) The term “EO Determinations” means the office in EO Rulings and Agreements of the Service that is primarily responsible for processing requests for determination letters.

(4) The term “Independent Office of Appeals” (Internal Revenue Service Independent Office of Appeals) means any office under the direction and control of the Chief of Appeals. The purpose of the Independent Office of Appeals is to resolve tax controversies, without litigation, on a fair and impartial basis. The Independent Office of Appeals is independent of EO Rulings and Agreements.

(5) The term “determination letter” means a written statement issued by EO Determinations or the Independent Office of Appeals in response to a request for the Service’s ruling on a question of tax-exempt status, foundation status, or other determination under the jurisdiction of the Director, EO Rulings and Agreements. This includes a written statement issued by EO Determinations or an office of the Independent Office of Appeals on the basis of advice secured from the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) pursuant to the procedures prescribed in Rev. Proc. 2025-2, this Bulletin. A determination letter applies the principles and precedents previously announced to a specific set of facts.

(6) The term “request” means the written submission that an organization uses to obtain a determination letter in accordance with the requirements of this revenue procedure.

(7) The term “application” means a request for recognition of exemption from federal income tax under §§ 501 or 521.

Updated annually .02 This revenue procedure is updated annually but may be modified or amplified during the year.