LW :IRSLent Rags and TAMs 0998.2010). LIN. He 0501.0340 Exception FAT lax on capeanont caftan trusts. of. (Exempt y. not excacl): Ratpdt IRS Letter Rulings and TAMs (1998-2010), UIL No. 0501.03-00 Exception from tax on corporations, certain trusts, etc. (Exempt v. not exempt); Religious, charitable, etc., institutions and community chest. IRS Letter Ruling 200945069 (Aug. 13, 2009), Internal Revenue Service, (Aug. 13, 2009) Click to open document in a browser LTR 200945069, August 13, 2009 Symbol: Not Given Uniform Issue List No. 0501.03-00 [Code Sec. 5011 Exception from tax on corporations, certain trusts, etc. (Exempt v. not exempt); Religious, charitable etc. Institutions and community chest This is our final determination that you do not qualify for exemption from Federal income tax as an organization described in Internal Revenue Code section 501(cX3). Recently, we sent you a letter in response to your application that proposed an adverse determination. The letter explained the facts, law and rationale, and gave you 30 days to file a protest. Since we did not receive a protest within the requisite 30 days, the proposed adverse determination is now final. Because you do not qualify for exemption as an organization described in Code section 501(cX3), donors may not deduct contributions to you under Code section 170. You must file Federal income tax returns on the form and for the years listed above within 30 days of this letter, unless you request an extension of time to file. File the returns in accordance with their instructions, and do not send them to this office. Failure to file the returns timely may result in a penalty. We will make this letter and our proposed adverse determination letter available for public inspection under Code section 6110, after deleting certain identifying information. Please read the enclosed Notice 437, Notice of Intention to Disclose, and review the two attached letters that show our proposed deletions. I