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PART II CIRCLE SECTION›Rev. Proc. 2025-5

SECTION 2. NATURE

Internal Revenue Bulletin 2025-1 · 2026-10-03 edition · updated 2026-10-04 · United States

OF CHANGES TO REV. PROC. 2024-5 AND RELATED REVENUE PROCEDURES AND FORMS

What changes have been made to Rev. Proc. 2024-5?

.01 This revenue procedure updates Rev. Proc. 2024-5, 2024-1 IRB 262, which deals with procedures for issuing Exempt Organization determination letters. Notable changes to Rev. Proc. 2024-5 that appear in this year’s update include—

(1) Section 3.01(1) of this revenue procedure was updated with a note to explain the application of § 4958 to organizations formerly recognized as described in § 501(c)(3) that are now recognized as described in a different paragraph of § 501(c).

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(2) Section 6.05(2) of this revenue procedure was updated to revise subparagraph (w) and add subparagraphs (z) through (cc) with additional organizations that are not eligible to submit Form 1023-EZ and must use Form 1023 to apply for recognition of exemption under § 501(c)(3).

(3) Editorial changes were made throughout including minor non-substantive changes, dates, and cross-references. Citations to other revenue procedures were changed to reflect the appropriate annual revenue procedures.

Related revenue procedures .02 This revenue procedure supplements the following revenue procedures—

(1) Rev. Proc. 80-27, 1980-1 CB 677, which sets forth procedures under which tax-exempt status may be recognized on a group basis for subordinate organizations affiliated with and under the general supervision and control of a central organization.

(2) Rev. Proc. 72-5, 1972-1 CB 709, which provides information for religious and apostolic organizations seeking recognition of exemption under § 501(d).

(3) Rev. Proc. 2015-17, 2015-7 IRB 599, which provides information regarding procedures for organizations described in § 501(c)(29).

(4) Rev. Proc. 2014-11, 2014-3 IRB 411, which sets forth procedures for reinstating the taxexempt status of organizations that have had their tax-exempt status automatically revoked under § 6033(j)(1).

(5) Rev. Proc. 2016-41, 2016-30 IRB 165, which sets forth the procedure for an organization to notify the Service, consistent with § 506, that it is operating as an organization described in § 501(c)(4).

(6) Rev. Proc. 2018-15, 2018-9 IRB 379, which describes the circumstances under which a domestic § 501(c) organization that changes its form or place of organization will not be required to file a new exemption application and such an organization’s reporting requirements.

Related forms that are not a request for a determination letter

.03 Forms that are not requests for a determination . Certain organizations are required to submit the following forms, but such forms are not requests for a determination and, thus, are not subject to the procedures in this revenue procedure.

(1) Form 3115, Application for Change in Accounting Method . A tax-exempt organization described in § 501(c) that wants to change its method of accounting for computing taxable income must follow the procedures that are generally applicable to all taxpayers for requesting the Commissioner’s consent to an accounting method change, including, if applicable, filing a Form 3115, Application for Change in Accounting Method ( see, e.g., Rev. Proc. 2015-13, 2015-5 IRB 419, as modified and clarified by Rev. Proc. 2021-34, 2021-35 IRB 337 (or any successor)). A tax-exempt organization described in § 501(c) must request consent to change its method of accounting for computing taxable income only if the tax-exempt organization has previously adopted a method of accounting for computing taxable income for the item(s) being changed. A taxpayer generally adopts a method of accounting in the first year in which an item is taken into account in computing taxable income. Thus, a tax-exempt organization that has adopted a method of accounting for an item of income or expense from an unrelated trade or business must generally request consent in order to change its method of accounting for reporting the item in any subsequent year, regardless of whether the gross income from the unrelated trade or business

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SECTION 3. UNDER WHAT CIRCUMSTANCES DOES EO DETERMINATIONS ISSUE DETERMINATION LETTERS?

Matters on which EO Determinations will issue a determination letter

is greater than or equal to $1,000 in such subsequent year. However, a tax-exempt organization that has not yet adopted a method of accounting for an item does not have to request consent to change the methodology of reporting the item. Thus, a tax-exempt organization that is required to file a Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax under section 6033(e)) solely due to owing a § 6033(e)(2) proxy tax but has not yet adopted a method of accounting for an item of income or expense does not have to request consent to change its methodology for reporting such item on its Form 990-T (or Form 990, as applicable). See Rev. Proc. 2015-13, as modified and clarified by Rev. Proc. 2021-34, and Section 9 of Rev. Proc. 20251, this Bulletin for procedures applicable to taxpayers, including tax-exempt organizations, for requesting changes in method of accounting.

(2) Form 8871, Political Organization Notice of Section 527 Status . A political party, a campaign committee for a candidate for federal, state, or local office, and a political action committee are all political organizations subject to tax under § 527. To be tax-exempt, a political organization may be required to notify the Service that it is to be treated as a § 527 organization by electronically filing Form 8871, Political Organization Notice of Section 527 Status . See IRS. gov (“Tax Information for Political Organizations”).

(3) Form 8976, Notice of Intent to Operate Under Section 501(c)(4) . An organization described in § 501(c)(4) must, no later than 60 days after the date the organization is established, notify the Service that it is operating as an organization described in § 501(c)(4) by submitting a completed Form 8976, Notice of Intent to Operate Under Section 501(c)(4) and the accompanying user fee. Se e IRS.gov (“Electronically Submit Your Form 8976, Notice of Intent to Operate Under Section 501(c)(4)”).

.01 EO Determinations issues determination letters on the following matters—

(1) Initial qualification for tax-exempt status of organizations described in §§ 501 or 521 (including reinstatement of organizations that have been automatically revoked pursuant to § 6033(j) and subordinate organizations included in a group exemption letter that have been revoked pursuant to that provision). See Rev. Proc. 2018-15 for procedures applicable to an entity changing its form or state of organization;

Note : EO Determinations will issue a determination letter to an organization currently recognized as described in § 501(c)(3) that seeks recognition as described in a different paragraph of § 501(c) if the organization establishes that, as of the submission date of its application, (i) it has distributed its assets to another § 501(c)(3) organization or government entity and (ii) it otherwise meets the requirements for the § 501(c) status requested. This determination letter will only be effective from the submission date of the new application. This also applies to an organization automatically revoked under § 6033(j) that was described in § 501(c)(3) that seeks retroactive reinstatement as described in a different paragraph of § 501(c). If the organization is a private foundation, however, it will not be recognized as described in a different paragraph of § 501(c) before terminating its private foundation status in accordance with § 507. See § 509(b) and (c). An organization formerly recognized as described in § 501(c)(3) will continue to be treated as an applicable tax-exempt organization subject to § 4958 for a period of five years after ceasing to be exempt as described in § 501(c)(3) unless it is a private foundation or a governmental unit or affiliate. See § 4958(e) and Treas. Reg. § 53.4958-2(a)(2).

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(2) Updated tax-exempt status letter (affirmation letter) to reflect changes to an organization’s name or address, or to replace a lost tax-exempt status letter;

(3) Classification or reclassification of private foundation status, including whether an organization is—

(a) A private foundation;

(b) A public charity described in §§ 509(a)(1) and 170(b)(1)(A) (other than clauses (v), (vii), and (viii));

(c) A public charity described in § 509(a)(2) or (4);

(d) A public charity described in § 509(a)(3), whether such organization is described in § 509(a) (3)(B)(i), (ii), or (iii) (supporting organization type), and whether or not a Type III supporting organization is functionally integrated;

(e) A private operating foundation described in § 4942(j)(3); or

(f) An exempt operating foundation described in § 4940(d)(2).

(4) Recognition of unusual grants to certain organizations under §§ 170(b)(1)(A)(vi) and 509(a) (2);

(5) Requests for relief under Treas. Reg. § 301.9100-1 in connection with applications for recognition of exemption;

(6) Terminations of private foundation status under § 507(b)(1)(B);

(7) Advance approval of certain set-asides described in § 4942(g)(2);

(8) Advance approval under § 4945(g) of organizations' grant making procedures;

(9) Advance approval of voter registration activities described in § 4945(f);

(10) Whether an organization is exempt from filing annual information returns under § 6033, as provided in Treas. Reg. § 1.6033-2(g)(1), Rev. Proc. 95-48, 1995-2 CB 418, and Rev. Proc. 96-10, 1996-1 CB 577;

(11) Determination of foundation status under § 509(a)(3) of non-exempt charitable trusts described in § 4947(a)(1); and

(12) Government entity voluntary termination of § 501(c)(3) recognition (must include documentation that the organization is not subject to income tax, other than under § 501(a)).

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Circumstances under which determination letters are not issued

.02 The Service may decline to issue a determination letter when appropriate in the interest of sound tax administration or on other grounds whenever warranted by the facts or circumstances of a particular case. In addition, the Service will not issue a determination letter in response to any request if—

(1) the request involves an issue under the jurisdiction of the Office of Associate Chief Counsel described in Rev. Proc. 2025-1;

(2) the same issue involving the same taxpayer, or a related taxpayer, is pending in a case in litigation or before the Independent Office of Appeals. If the issue in litigation involving the same taxpayer or a related taxpayer is not the taxpayer or a related taxpayer’s qualification as a tax-exempt entity (such as a declaratory judgment action under § 7428), the Service may issue a determination letter on tax-exempt status after consultation with counsel;

(3) the determination letter is requested by an industry, trade association, or similar group on behalf of individual taxpayers within the group (other than subordinate organizations covered by a group exemption letter);

(4) the determination letter is requested by an organization seeking to qualify under § 501(c) (5) the purpose of which is directed to the betterment of conditions of those engaged in the pursuits of labor, agriculture, or horticulture, the improvement of the grade of their products, and the development of a higher degree of efficiency in their respective occupations relating to an activity involving controlled substances (within the meaning of schedule I and II of the Controlled Substances Act, 21 USC § 801 et seq.) that is prohibited by federal law regardless of its legality under the law of the state in which such activity is conducted;

(5) the determination letter is requested by an organization seeking to qualify under § 501(c)(6) the purpose of which is directed to the improvement of business conditions of one or more lines of business relating to an activity involving controlled substances (within the meaning of schedule I and II of the Controlled Substances Act, 21 USC § 801 et seq.) that is prohibited by federal law regardless of its legality under the law of the state in which such activity is conducted;

(6) the request is based on alternative plans of proposed transactions or on hypothetical situations. An application based on proposed activities that satisfies section 6.07(2) of this revenue procedure (related to recognizing tax-exempt status in advance of actual operations) is not considered to be based on hypothetical situations;

(7) an organization currently recognized as exempt under § 501(c) of the Code seeks a new determination letter confirming that the organization is still recognized under the same Code section under the current facts;

(8) an organization seeks a determination of foundation status that is identical to its current foundation status as determined by EO Determinations. For example, an organization that is already recognized as described in §§ 509(a)(1) and 170(b)(1)(A)(ii) as a school generally will not receive a new determination letter that it is still described in §§ 509(a)(1) and 170(b)(1)(A)(ii) under the current facts;

(9) an organization currently recognized as exempt under § 501(c) (other than a government entity as specified in section 3.01(12) of this revenue procedure) requests a determination to relinquish its tax-exempt status under § 501(a);

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Technical advice may be requested in certain cases

Review of determination letters

Determination letter based solely on administrative record

(10) a domestic organization currently recognized as exempt under § 501(c) seeks a determination letter but is not required to reapply because it has changed its form or state of organization in accordance with the requirements in Rev. Proc. 2018-15. An organization may request an affirmation letter to reflect changes to its name or address as provided in section 3.01(2) of this revenue procedure; or

(11) an organization applies for a group exemption letter. Notice 2020‑36, 2020-21 IRB 840, provides that the Service will not accept any requests for group exemption letters until publication of the final revenue procedure described in the Notice or other guidance in the Internal Revenue Bulletin.

Note : In some circumstances, an organization may seek a letter ruling from the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) on a specific legal issue, including whether an activity furthers an organization’s exempt purpose. See Rev. Proc. 2025-1 and Rev. Proc. 2025-3, this Bulletin.

.03 EO Determinations generally issues determination letters only if the question presented is answered by a statute, tax treaty, regulation, court opinion, or guidance published in the Internal Revenue Bulletin. At any time during the course of consideration by EO Determinations, if either EO Determinations or the organization believes that its case involves an issue on which there is no published precedent, or there has been non-uniformity in the Service’s handling of similar cases, EO Determinations may decide to seek, or the organization may request that EO Determinations seek, technical advice from the Office of Associate Chief Counsel with subject matter jurisdiction over the issue. See Rev. Proc. 2025-2.

.04 Determination letters issued under this revenue procedure are not generally reviewed by any other office outside of EO Rulings and Agreements before they are issued. For post-determination review of determination letters by EO Determinations Quality Assurance, see section 11.03 of this revenue procedure.

.05 A determination letter is issued based solely upon the facts, attestations, and representations contained in the administrative record.

(1) The taxpayer is responsible for the accuracy of any factual representations or attestations contained in the request.

(2) Any oral representation of additional facts, or modification of facts, as represented or alleged in the request, must be reduced to writing and signed by the taxpayer under a penalty of perjury statement, in accordance with section 4.06 of this revenue procedure.

(3) The failure to disclose a material fact or misrepresentation of a material fact on the request, which includes an incorrect representation or attestation, may adversely affect the reliance that the organization submitting the request would otherwise obtain through issuance by the Service of a favorable determination letter. See section 11.02 of this revenue procedure for additional information. ARE THE GENERAL INSTRUCTIONS FOR REQUESTING DETERMINATION LETTERS?

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In general .01 This section explains the general instructions for requesting determination letters. In addition to these general instructions, specific procedures apply to requests submitted by letter (as described in section 5 of this revenue procedure) and to requests for determinations submitted on Form 8940, Request for Miscellaneous Determinatio n (as described in section 7 of this revenue procedure).

Format of request .02 Which form, if any, should be used for the request? Some requests are made by letter and some requests are made by submitting a specific form.

Form 1023 application (1) Form 1023 application . An organization seeking recognition of exemption under § 501(c) (3) (including an organization to which § 501(e), (f), (k), (n), (q), or (r) is applicable) must electronically submit a completed Form 1023 at www.pay.gov. In the case of an organization that provides credit counseling services, see § 501(q). In the case of an organization that is a hospital and is seeking tax-exempt status under § 501(c)(3), see § 501(r). Notwithstanding the foregoing, eligible organizations may seek recognition of exemption under § 501(c)(3) by submitting a completed Form 1023-EZ, as described in section 6.06(2) of this revenue procedure, rather than by submitting Form 1023. For additional information about the electronic submission process, refer to Form 1023 and its Instructions.

Form 1023-EZ application (2) Form 1023-EZ application . An eligible organization, as described in section 6.05 of this revenue procedure, may, but is not required to, seek recognition of exemption under § 501(c)(3) by submitting a completed electronic Form 1023-EZ.

Alternatively, an eligible organization may seek tax-exempt status under § 501(c)(3) by submitting a completed Form 1023, as described in section 6.06(1) of this revenue procedure.

For additional information about the electronic submission process, refer to Form 1023-EZ and its instructions.

Form 1024 application (3) Form 1024 application . An organization seeking a determination letter from the Service recognizing tax-exempt status under § 501(c)(2), (5)-(19), (21)-(23), (25)-(29), or (d) must electronically submit a completed Form 1024, Application for Recognition of Exemption Under Section 501(a) or Section 521 . An organization seeking a determination letter from the Service recognizing tax-exempt status under § 521 may also electronically submit Form 1024.

Organizations that seek to operate under § 501(c)(9) or (17) must apply for recognition of exemption. See § 505. Other organizations may choose to seek a determination letter recognizing tax-exempt status under § 501 by filing Form 1024, but are not required to do so except in certain cases ( see, for example, § 6033(j)(2) regarding failures to file annual information returns or annual electronic notifications required under § 6033(a) or (i)).

Form 1024-A application (4) Form 1024-A application . An organization seeking a determination letter from the Service recognizing tax-exempt status under § 501(c)(4) must electronically submit a completed Form 1024-A and the accompanying user fee at www.pay.gov. In the case of an organization that provides credit counseling services and seeks recognition of exemption under § 501(c)(4), see § 501(q).

Section 501(c)(4) organizations may choose to seek a determination letter recognizing taxexempt status under § 501(c)(4) by filing Form 1024-A, but are not required to do so except in certain cases ( see, for example, § 6033(j)(2) regarding failures to file annual information returns or annual electronic notifications required under § 6033(a) or (i)).

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Submission of Form 1024-A does not relieve an organization of the requirement to submit Form 8976, Notice of Intent to Operate Under Section 501(c)(4) . For additional information about the electronic submission process, refer to Form 1024-A and its Instructions.

Form 1028 application (5) Form 1028 application . An organization seeking recognition of exemption under § 521 may submit a completed Form 1028, Application for Recognition of Exemption Under Section 521 of the Internal Revenue Code, along with Form 8718. Note that an organization seeking a determination letter from the Service recognizing tax-exempt status under § 521 may instead electronically submit the revised Form 1024.

Form 8940 request for miscellaneous determination

(6) Form 8940 request for miscellaneous determination . An organization requesting certain miscellaneous determinations or providing certain notices to the IRS must electronically submit a completed Form 8940, Request for Miscellaneous Determination, at www.pay.gov. The Form 8940, Request for Miscellaneous Determination, is used for the following determination letter requests and notices—

(a) Advance approval of certain set-asides described in § 4942(g)(2);

(b) Advance approval of voter registration activities described in § 4945(f);

(c) Advance approval of scholarship procedures described in § 4945(g);

(d) Exception from Form 990 filing requirements;

(e) Advance approval that a potential grant or contribution constitutes an unusual grant;

(f) Change in Type (or initial determination of Type) of a § 509(a)(3) organization;

(g) Reclassification of foundation status, including a voluntary request from a public charity for private foundation status;

(h) Termination of private foundation status under § 507(b)(1)(B)—advance ruling request;

(i) Notice Only – Termination of private foundation status under § 507(b)(1)(B);

(j) Termination of private foundation status under § 507(b)(1)(B)—60-month period ended;

(k) Voluntary termination of § 501(c)(3) recognition by a government entity; and

(l) Canadian registered charities: listing on Pub. 78 Data and/or public charity classification.

Letter request (7) Letter request.

(a) Letter applications. A central organization that has previously received or is concurrently requesting recognition of its own tax-exempt status can request a group exemption letter by

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submitting a letter application along with Form 8718. But see, section 3.02(12) of this revenue procedure.

(b) Other letter request s. Any determination letter request which is not required to be submitted on a form may be submitted by letter.

Language requirements .03 All requests must be submitted in English. All documents submitted in support of such requests must be in English or accompanied by an accurate and complete English translation.

Signature on request .04 Signature on request . The request for determination letter must be signed and dated by the taxpayer or, when applicable, the taxpayer's authorized representative. Neither a stamped signature nor a faxed signature is permitted. However, a faxed signature is permitted if requested by the Service in the case of an organization replacing its initial request with a request for a determination under a different subsection of § 501(c) during processing of an initial request, or as otherwise requested during the processing of an initial request.

(1) Individual authorized to sign Form 1023, Form 1023-EZ, Form 1024, Form 1024-A or Form 8940 on behalf of an organization . In the case of a request for a determination letter made by filing Form 1023, Form 1023-EZ, Form 1024, Form 1024-A or Form 8940, an officer, director, trustee, or other official who is authorized to sign for the organization must sign the applicable form. The signature of a representative authorized by a power of attorney who is not an officer, director, trustee, or other official of the organization will not satisfy the signature requirement for Form 1023, Form 1023-EZ, Form 1024, Form 1024-A or Form 8940. See the instructions to the applicable form for more information on who may sign the application on behalf of an organization.

(2) Authorized representatives for all other requests . Except as provided in (1) of this section 4.04, to sign the request, or to appear before the Service in connection with the request, the authorized representative must be listed in Appendix B.

Power of attorney and declaration of representative

Penalty of perjury statement

.05 Power of attorney and declaration of representative . Any representative authorized by a power of attorney, whether or not licensed to practice, must comply with the conference and practice requirements of the Statement of Procedural Rules (26 CFR §§ 601.501-601.509) and Treasury Department Circular No. 230, which provide the rules for representing a taxpayer before the Service.

Form 2848, Power of Attorney and Declaration of Representative must be used to provide the authorized representative’s authorization (Part I of Form 2848, Power of Attorney ) and the authorized representative’s qualification (Part II of Form 2848, Declaration of Representative ).

The name of the individual signing Part I of Form 2848 should also be typed or printed on this form. A stamped signature is not permitted.

An original, a copy, or a facsimile transmission (fax) of the power of attorney is acceptable so long as its authenticity is not reasonably disputed.

.06

(1) Penalty of perjury statement requirements for requests for determination letters made on Form 1023, Form 1023-EZ, Form 1024, Form 1024-A, or Form 8940. The signature of an

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individual described in section 4.04(1) of this revenue procedure satisfies the penalty of perjury statement signature requirements for requests on Form 1023, Form 1023-EZ, Form 1024, Form 1024-A, or Form 8940, as applicable.

(2) Penalty of perjury statement requirements for letter requests and responses to requests for additional information. Any letter request or information submitted at a later time (regardless of the format of the original request), must be accompanied by the following declaration—

"Under penalties of perjury, I declare that I have examined this request, or this modification to the request, including accompanying documents, and, to the best of my knowledge and belief, the request or the modification contains all the relevant facts relating to the request, and such facts are true, correct, and complete."

This declaration must be signed and dated by the taxpayer, not the taxpayer’s representative authorized by a power of attorney. The signature of an individual described in section 4.04(1) of this revenue procedure is the signature of the taxpayer for purposes of the penalty of perjury statement. The signature of an authorized representative described in section 4.04(2) of this revenue procedure will not satisfy the penalty of perjury statement requirements (except as otherwise provided in Appendix B). See the instructions to the relevant form for additional detail. Neither a stamped signature nor a faxed signature is permitted. However, a faxed signature is permitted if requested by the Service in the case of information submitted in response to a request by the Service for additional information after the request for a determination.

The individual who signs for a corporate taxpayer must be an officer of the corporate taxpayer who has personal knowledge of the facts, and whose duties are not limited to obtaining a determination letter from the Service.

The individual signing for a trust, a state law partnership, or a limited liability company must be, respectively, a trustee, general partner, or member-manager who has personal knowledge of the facts.

Applicable user fee .07 Section 7528 requires taxpayers to pay user fees for requests for determination letters. See section 14 and Appendix A of this revenue procedure for more information.

Where will copies of the determination letter be sent?

.08 The original of the determination letter will be sent to the taxpayer and a copy of the determination letter will be sent to up to two authorized representatives listed on Form 2848 as appointed to receive notices and communications.

Expedited processing .09 Requests for determination letters are normally processed in the order of receipt by the Service. However, expedited processing of a request for a determination letter may be approved where a request for expedited processing is made in writing and contains a compelling reason for processing the request for a determination letter ahead of others. Upon approval of a request for expedited processing, a request for a determination letter will be considered ahead of the normal order. This does not mean the request for a determination letter will be immediately approved or denied.

(1) Procedures for requesting expedited handling . In the case of the electronically submitted Form 1023, Form 1024, Form 1024-A, or Form 8940, a request for expedited handling must be indicated on the form and a supporting written statement must be submitted as an attachment with the completed application.

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Non-acceptance for processing

In the case of other requests for determination letters, the request for expedited handling must be made in writing, preferably in a separate letter sent with, or soon after filing, the request for the determination letter. If the request is not made in a separate letter, then the letter in which the determination letter request is made should say, at the top of the first page: “ Expedited Handling Is Requested. See page ___ of this letter. ”

A request for expedited handling will not be forwarded to the appropriate group for action unless the application has been accepted for processing. See section 6.06(1) of this revenue procedure (requirements for a complete application).

Whether the request will be granted is within the Service's discretion. Circumstances generally warranting expedited processing include—

(a) a grant to the applicant is pending and the failure to secure the grant may have an adverse impact on the organization’s ability to continue to operate;

(b) the purpose of the newly created organization is to provide disaster relief to victims of emergencies such as flood and hurricane; and

(c) there have been undue delays in issuing a determination letter caused by a Service error.

Because most requests for determination letters cannot be processed ahead of their regular order, the Service urges all taxpayers to submit their requests well in advance of the contemplated transaction. In addition, in order to facilitate prompt action on determination letter requests, taxpayers are encouraged to ensure that their initial submissions comply with all of the requirements of this revenue procedure, and to promptly provide any additional information requested by the Service.

(2) Applications on Form 1023-EZ are ineligible for expedited handlin g. An organization may not request expedited handling of a Form 1023-EZ.

.10 The Service will not accept for processing any request that is substantially incomplete.

(1) Requests other than Form 1023-EZ . An application other than Form 1023-EZ that is missing any item of information listed in section 6.06(1) of this revenue procedure will be considered substantially incomplete and will not be accepted for processing. A request other than an application may be considered substantially incomplete if it does not contain the information, documentation, and other materials required by sections 4, 5, or 7 of this revenue procedure, or Form 8940 and its Instructions, as applicable to the particular request.

(2) Requests on Form 1023-EZ .

(a) Incomplete Form 1023-EZ . A submitted Form 1023-EZ that is not a completed Form 1023-EZ within the meaning of section 6.06(2) of this revenue procedure will not be accepted for processing by the Service. The Service may, but is not required to, request additional information to validate information presented or to clarify an inconsistency on a Form 1023-EZ.

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