Hi everyone, this is David McCree, CPA. Today, I'm going to present a case study of an organization that had its exempt status revoked in error by the IRS. I hope you learned something from it. The purpose of this case study is to demonstrate a typical interaction with the IRS. This is a case where the IRS made an error, which had serious implications for a tax-exempt organization. I was able to resolve the issue, but not without a lot of patience, persistence, and some knowledge of the law. This is a case where a tax-exempt organization's 501(c)(3) public charity status was erroneously revoked under Section 6033(j) for failure to file a return on time for three consecutive years. The revocation date was January 15, 2014, as shown by the red arrow. The notice was actually received from the IRS dated June 16, 2014, but the notice was received by the organization on June 12th. A little information about the organization: it has a fiscal year ending August 31st. So, that means that the 990 is due four and a half months later, which would be January 15th. It could get an extension three-month extension to April 15th, and a second three-month extension is available to July 15th. In this particular case, we're going to take a look at the three years of late filing which caused the revocation. First, in 2009, the Form 990 was filed on time, that is not in dispute. The first late year was 2010. The organization admits that it filed that return late, same thing with 2011. The organization admits that it was late. However, in 2012, the organization did file within the extended due date of July 15th. So, the 2012 Form 990 was due January 15th, 2014. The organization did request an automatic extension...
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Section 4 or 7 of rev proc 2024 11 2024 3 irb 411 Form: What You Should Know
The IRS has recently provided additional guidance regarding reinstatement. The IRS has given this guidance in an October 2024 Letter to Organizations. The IRS has also updated their website with information on their guidance. IRS Proposes New Procedures The IRS has recently recommended a new way for taxpayers and tax-exempt organizations to request their revoked status be reinstated in the Revenue Procedures 2013-25. The guidance includes the following two sections.
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