Home      Login

Abstract: 

Our regular round up of private letter rulings highlights a number of adverse rulings made by the service against organizations whose articles of incorporation did not clearly limit their purposes to qualifying exempt activities or establish that the organizations operated exclusively for exempt purposes. In PLR 201813017, an education program fails organizational and exempt-purposes tests; in PLR 201816011, the IRS denied IRC§501(c)(3) status to an organization created to operate an apartment housing facility that would provide accessible long-term housing for homeless disabled veterans because it failed to establish that it operated exclusively for this purpose; in PLR 201817019, the service ruled that an organization that fails to respond to requests for information fails to satisfy the public inspection requirements of IRC §§6001 and 6003 and can have its exempt status revoked on that basis; and in PLR 201816012, the service ruled that an addiction counseling organization’s had faulty, but damaging, financial records suggested a pattern of expenditures unrelated to its exempt purpose, leading to revocation.

Keywords: Organizational and Exempt Purposes Tests; Adequate Financial Records

Affiliations:  1: Clark Hill Strasburger.