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Judicial Watch • Lerner IRS emails production

Lerner IRS emails production

Lerner IRS emails production

Page 1: Lerner IRS emails production

Category:Obtained Document

Number of Pages:1157

Date Created:December 11, 2014

Date Uploaded to the Library:April 09, 2015

Tags:applications, Cases, political, Department of the Treasury, grant, organizations, Bill Clinton, Lerner, Exempt, production, Obama, FBI, White House, FOIA, Supreme Court, IRS, ICE


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b)(7)(A)
JW1559-006745
(b)(7)(A)
JW1559-006746
(b)(7)(A)
JW1559-006747
(b)(7)(A)
JW1559-006748
(b)(3)/6103; (b)(5) DP; (b)(7)(A)
JW1559-006749
(b)(3)/6103; (b)(5) DP; (b)(7)(A)
JW1559-006750
(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
JW1559-006759
(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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JW1559-006795
(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(3)/6103; (b)(5) DP; (b)(7)(A)
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(b)(7)(A)
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(b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006806
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006807
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006808
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006822
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006823
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006824
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006827
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
JW1559-006828
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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JW1559-006844
(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(5) DP; (b)(3)/6103; (b)(7)(A)
(b)(5) DP; (b)(3)/6103
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(b)(7)(A)
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JW1559-006947
From:
Cook Janine
Sent:
Thursday, May 09, 2013 7:22
To:
Kindell Judith Brown Susan
Subject:
FW: Thanks for Your Support!
Attachments:
Meeting notes 4-30-13 with JC.docx
Judy, did you send these along? You responded sure wasnt sure what that meant. havent had chance get
back them this afternoon. Your notes are detailed that sure you didnt miss much, anything. the draft
above, had few edits that are track changes; Youll want look those and finalize before sending Nikole.
Since these are detailed, Nikole might want something more summary fashion. can help with that you want.
-----Original Message ----From: Cook Janine
Sent: Thursday, May 09, 2013 1:06
To: Kindell Judith
Cc: Brown Susan
Subject: RE: Thanks for Your Support!
didnt get too far. you want see Nikole needs these now draft?
-----Original Message ----From: Kindell dith [mailto:Judith.E.Kindell@irs.gov]
Sent: Thursday, May 09, 2013 11:46
To: Cook Janine
Cc: Brown Susan
Subject: RE: Thanks for Your Support!
Here the latest version notes.
-----Original Message ----From: Cook Janine [mailto:Janine.Co ok@irscounsel.treas.gov]
Sent: Thursday, May 09, 2013 9:15
To: Kindell Judith
Subject: RE: Thanks for Your Support!
now running behind. Have meeting and will turn this 11.
-----Original Message ----From: Kindell Judith [mailto:Judith.E.Kindell@irs.gov]
Sent: Wednesday, May 08, 2013 5:11
To: Cook Janine
Subject: RE: Thanks for Your Support! still slogging way through (still getting sidetracked), but thought would share what have far.
JW1559-006948
-----Original Message ----From: Cook Janine [mailto:Janine.Cook@irscounsel.treas.gov]
Sent: Wednesday, May 08, 2013 8:56
To: Kindell Judith
Subject: Re: Thanks for Your Support! understand.
----- Original Message ----From: Kindell dith [mailto:Judith.E.Kindell@irs.gov]
Sent: Wednesday, May 08, 2013 08:30
To: Cook Janine
Cc: Brown Susan
Subject: RE: Thanks for Your Support! sorry meant finish notes yesterday but got sidetracked. working them now and ill get them
you soon possible.
-----Original Message ----From: Kindell Judith
Sent: Tuesday, May 07, 2013 8:50
To: Cook Janine
Cc: Brown Susan
Subject: RE: Thanks for Your Support! still finishing them up, but will soon finish.
-----Original Message ----From: Cook Janine [mailto:Janine.Cook@irscounsel.treas.gov]
Sent: Tuesday, May 07, 2013 8:45
To: Kindell Judith
Cc: Brown Susan
Subject: RE: Thanks for Your pport!
Judy, you want send your notes first, can quick scan pages and see have any thing add
before sending Nikole?
-----Original Message ----From: Kindell Judith [mailto:Judith.E.Kindell@irs.gov]
Sent: Tuesday, May 07, 2013 12:33
To: Barre Catherine Cook Janine
Cc: Flax Nikole
Subject: Re: Thanks for Your Support!
Yes
----- Original Message ----From: Barre Catherine
Sent: Monday, May 06, 2013 11:05 Eastern Standard Time
To: Kindell Judith Coo Janine
Cc: Flax Nikole
Subject: RE: Thanks for Your Support!
JW1559-006949
Today Steve asked could get set meeting notes late Wednesday Thursday. that possible?
Thanks
-----Original Message ----From: Kindell Judith
Sent: Wednesday, May 01, 2013 4:29
To: Cook Janine; Lerner Lois Flax Nikole Marks Nancy Brown Susan Barre Catherine Sinno Suzanne
Cc: Park Nalee; Paz Holly Megosh Andy; Downing Nanette
Subject: RE: Thanks for Your Support! will circulate notes once get them typed up, but the meantime, thought would circulate our -do list. Lois
and talked last night about getting the info and have included our thoughts who would get it. Let know
have missed anything.
-----Original Message ----From: Cook Janine [mailto:Janine.Cook@irscounsel.treas.gov]
Sent: Wednesday, May 01, 2013 12:48
To: Lerner Lois Flax Nikole Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzanne
Subject: RE: Thanks for Your Support! pages worth....
-----Original Message ----From: Lerner Lois [mailto:Lois.G.Lerner@irs.gov]
Sent: Wednesday, May 01, 2013 12:20
To: Flax Nikole Cook Janine; Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzanne
Subject: RE: Thanks for Your Support! didnt know Judy and Nan took some --not sure they are comprehensive. guessing Janine also some
Lois Lerner
Director Exempt Organizations
-----Original Message ----From: Flax Nikole
Sent: Wednesday, May 01, 2013 12:16
To: Lerner Lois Cook Janine; Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzan
Subject: RE: Thanks for Your Support! thought went well. Did anyone take good notes that can type for Steve? will also set some time talk
him thorough the discussion before his hearing.
-----Original Message ----From: Lerner Lois
Sent: Wednesday, May 01, 2013 10:26
To: Flax Nikole Cook Janine; Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzanne
JW1559-006950
Subject: Thanks for Your Support!
Yesterdays marathon went well thanks the village. Glad have all you part that village.
Lois Lerner-------------------------- Sent from BlackBerry Wireless Handheld
JW1559-006951
(b)(5)
JW1559-006952
(b)(5)
JW1559-006953
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(b)(5)
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(b)(5)
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(b)(5)
JW1559-006968
From:
Flax Nikole
Sent:
Thursday, May 09, 2013 3:28
To:
Lemons Terry (Terry.L.Lemons@irs.gov); Eldridge Michelle
Subject:
FW: data question
(MICHELLE.L.ELDRIDGE@irs.gov)
See figures below. Number approvals slightly higher well.
From: Paz Holly
Sent: Thursday, May 09, 2013 4:26
To: Flax Nikole Lerner Lois
Subject: RE: data question
Increase section 501c4 applications
2008 1410
2009 1571
2010 1591
2011 2242
2012 3398
2013 2,092 (through March 26, 2013)
From: Flax Nikole
Sent: Thursday, May 09, 2013 4:21
To: Lerner Lois Paz Holly
Subject: Re: data question
Right this fine just need the application numbers.
From: Lerner Lois
Sent: Thursday, May 09, 2013 04:01 Eastern Standard Time
To: Paz Holly Flax Nikole
Subject: RE: data question
Dont think need that --were focusing the 300 --so dont kill your self
Lois Lerner
Director Exempt Organiza tions
From: Paz Holly
Sent: Thursday, May 09, 2013 3:30
To: Lerner Lois Flax Nikole
Subject: RE: data question
136 approvals 5/9/13
JW1559-006969 withdrawn think the reference must have been all withdrawn apps and that number now stands 37)
Will get back you total number apps shortly.
Have meeting have do.
From: Lerner Lois
Sent: Thursday, May 09, 2013 2:32
To: Flax Nikole Paz Holly
Subject: RE: data question
Have sent Cindy the question
Lois Lerner
Director Exempt Org anizations
From: Flax Nikole
Sent: Thursday, May 09, 2013 2:30
To: Lerner Lois Paz Holly
Subject: RE: data question
Yes
From: Lerner Lois
Sent: Thursday, May 09, 2013 2:23
To: Flax Nikole Paz Holly
Subject: RE: data question assume you want you want know about whether the 120 have increased, not whether
weve received more applications
Lois Lerner
Director Exempt Organizations
From: Flax Nikole
Sent: Thursday, May 09, 2013 1:59
To: Paz Holly Lerner Lois
Subject: data question the following the most recent has there been any movement should recognize.
Thanks the approximately 300 section 501(c)(4) advocacy cases, more than 120 have been approved and nearly
have withdrawn.
JW1559-006970
From:
Grodnitzky Steven
Sent:
Monday, May 13, 2013 8:38
To:
Goehausen Hilary; Cundiff Susan
Subject:
FW: Action: May SCRs due COB 05/17/2013
Attachments:
SCR April 2013 Advocacy Orgs.doc; SCR April 2013 SCR April 2013
6103
(b)(3)/6103
6103
(b)(3)/6103
6103
(b)(3)/6103
SCR April 2013
SCR April 2013 Medical Marijuana.doc; SCR April 2013
Newspaper Cases.doc; SCR April 2013
Cases.doc; SCR April 2013
Importance:
SCR April 2013
6103
(b)(3)/6103
SCR April 2013 HMOs PPOs Related Health Care Orgs.doc; SCR April 2013
6103
(b)(3)/6103
(b)(3)/6103
6103
6103
(b)(3)/6103 SCR April 2013
6103
(b)(3)/6103
6103
(b)(3)/6103 SCR April 2013 Pooled Trust SCR April 2013
6103
(b)(3)/6103 SCR April 2013
High
Please complete the SCRs COB Wednesday, May 15th.
Thank you.
From: Trilli Darla
Sent: Friday, May 10, 2013 3:18
To: Grodnitzky Steven; Shoemaker Ronald Lieber Theodore Salins Mary Biss Meghan Megosh Andy; Thomas
Cindy
Cc: Trilli Darla
Subject: Action: May SCR due COB 05/17/2013
Importance: High
SCRs for May updates.
Need these updated COB Friday, May 17, 2013.
Mike taking leave starting the apologize for the short turnaround.
and our meeting with Holly over these 10am the
Thanks, Darla
JW1559-006971
(b)(3)/6103; (b)(5) DP; partially non-responsive
JW1559-006972
(b)(3)/6103; (b)(5) DP; partially non-responsive
JW1559-006973
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006974
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006975
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006976
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006977
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006978
(b)(3)/6103; (b)(5)/DP
JW1559-006979
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006980
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006981
TAX PERIODS: 2006 and forward
CASE NAME:
HMOs, PPOs, similar type health care
organizations.
EARLIEST STATUTE DATE:
TIN/EIN:
POA: None
FUNCTION REPORTING:
INITIAL REPORT FOLLOW-UP REPORT
FINAL REPORT
POD: Washington, D.C.
SENSITIVE CASE CRITERIA:
Potentially involves large dollars ($10M
greater)
Other (explain Case Summary)
Likely attract media Congressional
attention
Unique novel issue
Affects large number taxpayers
FORM TYPE(S):
(1) Form 1023 (2) Form 1024
START DATE:
1/26/2013
POTENTIAL DOLLARS INVOLVED (IF $10M)
Unknown
CRIMINAL REFERRAL? Unknown YES, WHEN?
Freeze Code 914 Yes No)
CASE ISSUE SUMMARY:
The following organizations applied for recognition exemption under either section 501(c)(3)
further charitable purpose section 501(c)(4) promote social welfare They include HMOs,
PPOs, organizations engaging similar health care acti vities. EOD transfers the applications
directly Technical and they are worked Washington. Due the sensitive nature issues
associated with these organizations, the cases are coordinated with TEGE Counsel.
CURRENT SIGNIFICANT ACTIONS CASE: Applications for Exemption Open Cases
(1)
501(c)(3)
b(3)6103; non-responsive
b(3)6103; non-responsive
(2)
(3)
(4)
501(c)(3)
b(3)6103; non-responsive
b(3)6103; non-responsive
b(3)6103; non-responsive
501(c)(3)
b(3)6103; non-responsive
501(c)(4)
(b)(3)/6103
(b)(3)/6103
(5)
501(c)(4)
(b)(3)/6103
(b)(3)/6103
(6)
(b)(3)/6103
501(c)(4)
(b)(3)/6103
JW1559-006982
(b)(3)/6103
(7)
501(c)(4)
(b)(3)/6103
(b)(3)/6103
(8)
b(3)6103; non-responsive
(9)
501(c)(3)
501(c)(3)
b(3)6103; non-responsive
(10)
(11)
(12)
(13)
(14)
b(3)6103; non-responsive
b(3)6103; non-responsive
501(c)(4)
(b)(3)/6103
(b)(3)/6103
501(c)(4)
(b)(3)/6103
(b)(3)/6103
501(c)(4)
(b)(3)/6103
b(3)6103; non-responsive
(b)(3)/6103
501(c)(4)
(b)(3)/6103
501(c)(3)
(b)(3)/6103
b(3)6103; non-responsive Applications for Exemption Closed Cases All favorable
(1)
(2)
(3)
(4)
(5)
b(3)6103; non-responsive
501(c)(3) b(3)6103; non-responsive
b(3)6103; non-responsive
b(3)6103; non-responsive
501(c)(3)
b(3)6103; non-responsive
(b)(3)/6103
501 (4)
501(c)(3)
b(3)6103; non-responsive
b(3)6103; non-responsive
501(c)(3)
b(3)6103; non-responsive
(b)(3)/6103
ESTIMATED CLOSURE DATE:
SIGNIFICANT NEXT STEPS, ANY:
Continue developing and resolving cases, while
December 31, 2013
coordinating with TEGE Counsel novel
issues.
BARRIERS RESOLUTION, ANY:
SUBMITTED BY: Steven Grodnitzky
SE:T:EO:RA:T:1
DATE: March 24, 2013
MANAGER: MICHAEL SETO, SE:T:EO:RA
JW1559-006983
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006984
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006985
non-responsive
JW1559-006986
non-responsive
JW1559-006987
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006988
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006989
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006990
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006991
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006992
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006993
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006994
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006995
(b)(3)/6103; (b)(5) DP; non-responsive
JW1559-006996
From:
Kindell Judith
Sent:
Sunday, May 12, 2013 9:44
To:
Marks Nancy
Subject:
Fw: Thanks for Your Support!
Attachments:
Meeting notes 4-30-13.docx
Sorry, got little distracted
----- Original Message ----From: Kindell Judith
Sent: Thursday, May 09, 2013 11:45 Eastern Standard Time
To: Cook Janine
Cc: Brown Susan Susan.D.Brown@irscounsel.treas.gov
Subject: RE: Thanks for Your Support!
Here the latest version notes.
-----Original Message ----From: Cook Janine mailto:Janine.Cook@irscounsel.treas.gov
Sent: Thursday, May 09, 2013 9:15
To: Kindell Judith
Subject: RE: Thanks for Your Support!
now running behind. Have meeting and will turn this 11.
-----Original Message ----From: Kindell Judith mailto:Judith.E.Kindell@irs.gov
Sent: Wednesday, May 08, 2013 5:11
To: Cook Janine
Subject: RE: Thanks for Your Support! still slogging way through (still getting sidetracked), but thought would share what have far.
-----Original Message ----From: Cook Janine mailto:Janine.Cook@irscounsel.treas.gov
Sent: Wednesday, May 08, 2013 8:56
To: Kindell Judith
Subject: Re: Thanks for Your Support! understand.
----- Original Message ----From: Kindell Judith mailto:Judith.E.Kindell@irs.gov
Sent: Wednesday, May 08, 2013 08:30
To: Cook Janine
Cc: Brown Susan
Subject: RE: Thanks for Your Support!
JW1559-006997 sorry meant finish notes yesterday but got sidetracked. working them now and will get them
you soon possible.
-----Original Message ----From: Kindell Judith
Sent: Tuesday, May 07, 2013 8:50
To: Cook Janine
Cc: Brown Susan
Subject: RE: Thanks for Your Support! still finishing them up, but will soon finish.
-----Original Message ----From: Cook Janine mailto:Janine.Cook@irscounsel.treas.gov
Sent: Tuesday, May 07, 2013 8:45
To: Kindell Judith
Cc: Brown Susan
Subject: RE: Thanks for Your Support!
Judy, you want send your notes first, can quick scan pages and see have any thing add
before sending Nikole?
-----Original Message ----From: Kindell Judith mailto:Judith.E.Kindell@irs.gov
Sent: Tuesday, May 07, 2013 12:33
To: Barre Catherine Cook Janine
Cc: Flax Nikole
Subject: Re: Thanks for Your Support!
Yes
----- Original Message ----From: Barre Catherine
Sent: Monday, May 06, 2013 11:05 Eastern Standard Time
To: Kindell Judith Cook Janine
Cc: Flax Nikole
Subject: RE: Thanks for Your Support!
Today Steve asked could get set meeting notes late Wednesday Thursday. that possible?
Thanks
-----Original Message ----From: Kindell Judith
Sent: Wednesday, May 01, 2013 4:29
To: Cook Janine; Lerner Lois Flax Nikole Marks Nancy Brown Susan Barre Catherine Sinno Suzanne
Cc: Park Nalee; Paz Holly Megosh Andy; Downing Nanette
Subject: RE: Thanks for Your Support! will circulate notes once get them typed up, but the meantime, thought would circulate our -do list. Lois
and talked last night about getting the info and have included our thoughts who would get it. Let know
have missed anything.
JW1559-006998
-----Original Message ----From: Cook Janine mailto:Janine.Cook@irscounsel.treas.gov
Sent: Wednesday, May 01, 2013 12:48
To: Lerner Lois Flax Nikole Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzanne
Subject: RE: Thanks for Your Support! pages worth....
-----Original Message ----From: Lerner Lois mailto:Lois.G.Lerner@irs.gov
Sent: Wednesday, May 01, 2013 12:20
To: Flax Nikole Cook Janine; Marks Nancy Kindell Judith Brown Susan arre Catherine Sinno Suzanne
Subject: RE: Thanks for Your Support! didnt know Judy and Nan took some --not sure they are comprehensive. guessing Janine also had some
Lois Lerner
Director Exempt Organizations
-----Original Message ----From: Flax Nikole
Sent: Wednesday, May 01, 2013 12:16
To: Lerner Lois Cook Janine; Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzanne
Subject: RE: Thanks for Your Support! thought went well. Did anyone take good notes that can type for Steve? will also set some time talk
him thorough the discussion before his hearing.
-----Original Message ----From: Lerner Lois
Sent: Wednesday, May 01, 2013 10:26
To: Flax Nikole Cook Janine; Marks Nancy Kindell Judith Brown Susan Barre Catherine Sinno Suzanne
Subject: Thanks for Your Support!
Yesterdays marathon went well thanks the village. Glad have all you part that village.
Lois Lerner-------------------------- Sent from BlackBerry Wireless Handheld
JW1559-006999
(b)(5)
JW1559-007000
(b)(5)
JW1559-007001
(b)(5)
JW1559-007002
(b)(5)
JW1559-007003
(b)(5)
JW1559-007004
(b)(5)
JW1559-007005
(b)(5)
JW1559-007006
(b)(5)
JW1559-007007
(b)(5)
JW1559-007008
(b)(5)
JW1559-007009
(b)(5)
JW1559-007010
(b)(5)
JW1559-007011
(b)(5)
JW1559-007012
(b)(5)
JW1559-007013
(b)(5)
JW1559-007014
(b)(5)
JW1559-007015
(b)(7)(A)
JW1559-007016
(b)(7)(A)
JW1559-007017
(b)(7)(A); (b)(3)/6103
JW1559-007018
(b)(7)(A); (b)(3)/6103
JW1559-007019
(b)(7)(A); (b)(3)/6103
JW1559-007020
(b)(7)(A); (b)(3)/6103
JW1559-007021
(b)(7)(A); (b)(3)/6103
JW1559-007022
(b)(7)(A); (b)(3)/6103
JW1559-007023
(b)(7)(A); (b)(3)/6103
JW1559-007024
(b)(7)(A); (b)(3)/6103
JW1559-007025
(b)(7)(A); (b)(3)/6103
JW1559-007026
(b)(7)(A); (b)(3)/6103
JW1559-007027
(b)(7)(A); (b)(3)/6103
JW1559-007028
(b)(7)(A); (b)(3)/6103
JW1559-007029
(b)(7)(A); (b)(3)/6103
JW1559-007030
(b)(7)(A); (b)(3)/6103
JW1559-007031
(b)(7)(A); (b)(3)/6103
JW1559-007032
(b)(7)(A); (b)(3)/6103
JW1559-007033
(b)(7)(A); (b)(3)/6103
JW1559-007034
(b)(7)(A); (b)(3)/6103
JW1559-007035
(b)(7)(A); (b)(3)/6103
JW1559-007036
(b)(7)(A); (b)(3)/6103
JW1559-007037
(b)(7)(A); (b)(3)/6103
JW1559-007038
(b)(7)(A); (b)(3)/6103
JW1559-007039
(b)(7)(A); (b)(3)/6103
JW1559-007040
(b)(7)(A); (b)(3)/6103
JW1559-007041
(b)(7)(A); (b)(3)/6103
JW1559-007042
(b)(7)(A); (b)(3)/6103
JW1559-007043
(b)(7)(A); (b)(3)/6103
JW1559-007044
(b)(7)(A); (b)(3)/6103
JW1559-007045
(b)(7)(A); (b)(3)/6103
JW1559-007046
(b)(7)(A); (b)(3)/6103
JW1559-007047
(b)(7)(A); (b)(3)/6103
JW1559-007048
(b)(7)(A); (b)(3)/6103
JW1559-007049
(b)(7)(A); (b)(3)/6103
JW1559-007050
(b)(7)(A); (b)(3)/6103
JW1559-007051
(b)(7)(A); (b)(3)/6103
JW1559-007052
(b)(7)(A); (b)(3)/6103
JW1559-007053
(b)(7)(A); (b)(3)/6103
JW1559-007054
(b)(7)(A); (b)(3)/6103
JW1559-007055
(b)(7)(A); (b)(3)/6103
JW1559-007056
(b)(7)(A); (b)(3)/6103
JW1559-007057
(b)(7)(A); (b)(3)/6103
JW1559-007058
(b)(7)(A); (b)(3)/6103
JW1559-007059
(b)(7)(A); (b)(3)/6103
JW1559-007060
(b)(7)(A); (b)(3)/6103
JW1559-007061
(b)(7)(A); (b)(3)/6103
JW1559-007062
(b)(7)(A); (b)(3)/6103
JW1559-007063
(b)(7)(A)
JW1559-007064
(b)(7)(A)
JW1559-007065
(b)(7)(A)
JW1559-007066
(b)(7)(A)
JW1559-007067
(b)(7)(A)
JW1559-007068
(b)(7)(A)
JW1559-007069
(b)(7)(A)
JW1559-007070
(b)(7)(A)
JW1559-007071
(b)(7)(A)
JW1559-007072
(b)(7)(A)
JW1559-007073
(b)(7)(A)
JW1559-007074
(b)(7)(A)
JW1559-007075
(b)(7)(A)
JW1559-007076
(b)(7)(A)
JW1559-007077
(b)(7)(A)
JW1559-007078
(b)(7)(A)
JW1559-007079
(b)(7)(A)
JW1559-007080
(b)(7)(A)
JW1559-007081
(b)(7)(A)
JW1559-007082
(b)(7)(A)
JW1559-007083
(b)(7)(A)
JW1559-007084
From:
Lerner Lois
Sent:
Thursday, May 26, 2011 5:18
To:
Paz Holly Fish David
Subject:
FW:
Importance:
High told Chip Hull heading the --scaring me--can get briefing?
Lois Lerner
Director, Exempt Organizations
From: Lerner Lois
Sent: Thursday, May 26, 2011 5:45
To: Downing Nanette Grant Joseph
Cc: Urban Joseph Fish David Paz Holly
Subject: RE:
(b)(3)/6103
Lois Lerner
Director, Exempt Organizations
From: Downing Nanette
Sent: Thursday, May 26, 2011 3:55
To: Lerner Lois Grant Joseph
Cc: Urban Joseph Fish David
Subject: have received referrals and tracking sheets for both are attached.
One was
and the other
(b)(3)/6103
Nan
JW1559-007085
From:
Lerner Lois
Sent:
Thursday, June 02, 2011 4:47
To:
Downing Nanette
Cc:
Grant Joseph
Subject:
RE:
Yep--and will probably happening more. While the application pending, they
need file, need process
(b)(3)/6103
Lois Lerner
Director, Exempt Organizations
From: Downing Nanette
Sent: Thursday, June 02, 2011 2:54
To: Lerner Lois
Cc: Grant Joseph
Subject: RE: think need discuss this. not currently have anything place when the org has pendi exemption. What the exemption never finalizes denied? How would know track that. right now, any org that not
exempt send SBSE because they should filing some type return. think this may brand new arena for exam classification.
From: Lerner Lois
Sent: Tuesday, May 31, 2011 4:03
To: Downing Nanette
Cc: Grant Joseph
Subject: RE:
Lois Lerner
Director, Exempt Organizations
From: Downing Nanette
Sent: Tuesday, May 31, 2011 4:50
To: Lerner Lois
Cc: Grant Joseph
Subject: RE:
JW1559-007086 they are not exempt send over SBSE they would 1120 filer.
From: Lerner Lois
Sent: Tuesday, May 31, 2011 2:33
To: Downing Nanette
Cc: Grant Joseph
Subject: RE:
Sorry-- was just trying figure out what where.
(b)(3)/6103
What happens when you get referral org that hasnt approved filed?
Lois Lerner
Director, Exempt Organizations
From: Downing Nanette
Sent: Monday, May 30, 2011 7:26
To: Lerner Lois Grant Joseph
Cc: Urban Joseph Fish David Seto Michael Fish David Kindell Judith
Subject: RE:
shoot email you want join the last bit the conversation.
Otherwise will just wait hear from you about
this.
From: Lerner Lois
Sent: Friday, May 27, 2011 5:27
To: Downing Nanette Grant Joseph
Cc: Urban Joseph Fish David Seto Michael Fish David Kindell Judith
Subject: RE:
(b)(3)/6103
Nan-we may not need you for the first part, but will want talk you also some oint
Lois Lerner
Director, Exempt Organizations
From: Downing Nanette
Sent: Thursday, May 26, 2011 3:55
JW1559-007087
To: Lerner Lois Grant Joseph
Cc: Urban Joseph Fish David
Subject: have received referrals and tracking sheets for both are attached.
One was
and the other
(b)(3)/6103
Nan
(...
JW1559-007088
From:
Lerner Lois
Sent:
Tuesday, June 07, 2011 1:43
To:
Williams Grant; Kindell Judith
Cc:
Lemons Terry Burke Anthony; Eldridge Michelle
Subject:
RE: checking any answers you may have, and perhaps few
OK--Im getting little tired this guy.
Judy will provide: the two statutory definitions political expenditure. The 501(c)(3) language which tracked the rags for (c)(4 )s,
and the 527 definition which applies (c) (4)s through the 527(f) tax --a tax investment income the extent has
political expenditures. the link the 2002 CPE text that discusses political campaign activity for c3s, 4s, and 6s.3. repetition her previous answer what you get you apply for rather than self declare. how does the IRS definition political activity expense match differ from those that trigger reporting
requirements the FEC, not answering that. Ill give him definition and hell need compare that with the FEC
definition--we cant and shouldn speak how the FEC sees it. the 2007 990 and line instructions --we dont have that=you guys may able find the Forms and Pubs
page.
Lois Lerner
Director, Exempt Organizations
-----Original Message ----From: CHARLES BABCOCK, BLOOMBERG/ NEWSROOM: mailto:cbabcock1@bloomberg.net
Sent: Tuesday, June 07, 2011 10:59
To: Williams Grant
Subject: checking any answers you may have, and perhaps few
checking any answers you may have, and perhaps few
bottom line questions that will help both cut through the
details: how does the irs define political expenditures?
(as worded question thru 2007 form 990 --and btw
like copy the line instructions which cant find
website) how does the irs definition political activity expense match differ from those that trigger reporting
requirements the FEC? what benefits does the c4,5,6
exemption bestow applicant? (i.e. you dont require
them even file 1024, why does anyone apply? there some
JW1559-007089
tangible tax exemption?)
JW1559-007090
From:
Lerner Lois
Sent:
Tuesday, June 14, 2011 8:54
To:
Williams Grant; Kindell Judith
Cc:
Lemons Terry Eldridge Michelle
Subject:
Re: Update: Bloomberg and non-c-3 groups computer crashed yesterday and Blackberry doesnt work office just saw this. Unfortunately, tied until least and because Blackberry truncates, cant see bottom email. From what can see --work plan was
made public Dec. always when work plan, built around the resources have and anticipate for the
year. seems think resources are separate from projects. That the point developing work plan --how best
allocate the resources have. So, have staff 100 audits, you wouldnt see increase the audits --we
would divide them out internally according what want look at. Also, often use the ROO initial research
Before starting audits --they dont touch taxpayers, but can look publicly available info about orgs. Hope this useful. need talk when get out here? 1111
Lois Lerner-------------------------Sent from BlackBerry Wireless Handheld
From: Williams Grant
Sent: Monday, June 13, 2011 07:14
To: Lerner Lois Kindell Judith
Cc: Lemons Terry Eldridge Michelle
Subject: Update: Bloomberg and non -c-3 groups everyone,
Chuck Babcock Bloomberg wrote this (Monday) afternoon and said that tomorr may the last chance for respond his questions its the first time hes referred deadline. followed later thanking for sticking
with him through his inquiries.
Below Ill paste the key parts his most recent messa ges (which you havent seen); youll get idea what
focusing what may the end his reporting efforts. Please let know how youd like handle his questions.
One about the date the current ork Plan; believe was released the public December 2010? down below Ill paste -mail message Mr. Babcock which Ive drafted but not yet sent that based the
material that Judy provided the other day. you give final go-ahead, Ill send Mr. Babcock tomorrow
(Tuesday) morning.
Meanwhile, combing through all his questions date see Ive missed anything that should re-bring your
attention. told Mr. Babcock that call him tomorrow touch base and Ill let you know ight away what says.
Thank you,
Grant
Grant illiams
IRS National Media Relations
(202) 622-4000
MR. BABCOCKS MOST RECENT EMAILS:
JW1559-007091
--- progress any newest questions? and
what btw the date the directors 2011 work plan
that mentions are increasing our focus 501c4,5 and
org? asked about manpower for that. more bottom line, what
evidence can you cite show you are doing what the director
said. specifics such audits have increased from
what? Checking back progress queries. Like date the 2011 work plan and evidence the irs focusing more including political activity. Thanks. Any news today? Running out time. Tomorrow [Tuesday the 14th] may last chance. Particularly need answers
evidence you can cite that folks taking closer look 501cs work plan said, and whether any has ever
had exemption revoked for politicial activity. so, would like details course thanks again for sticking with this. DRAFT MESSAGE MR. BABCOCK (that Ill send him when you give the green light): Chuck,
(b)(5)
Ill give you call soon today touch base, Chuck.
Sincerely,
Grant illiams
IRS National Media Relations
(202) 622-4000
JW1559-007092
From:
Lerner Lois
Sent:
Tuesday, June 14, 2011 9:40
To:
Kindell Judith Williams Grant
Cc:
Lemons Terry Eldridge Michelle
Subject:
Re: Update: Bloomberg and non-c-3 groups
Thanks Judy
Lois Lerner-------------------------Sent from BlackBerry Wireless Handheld
From: Kindell Judith
Sent: Tuesday, June 14, 2011 10:23
To: Williams Grant; Lerner Lois
Cc: Lemons Terry Eldridge Michelle
Subject: RE: Update: Bloomberg and non -c-3 groups
The work plan for fiscal year 2011 was released December 15, 2010.
This the plan for use our resources for the
current fiscal year. There other information available concerning the projects entified the work plan, including
the 501(c)(4), (5) and (6) project.
Your write-up looks fine me.
From: Williams Grant
Sent: Monday, June 13, 2011 7:14
To: Lerner Lois Kindell Judith
Cc: Lemons Terry Eldridge Michelle
Subject: Update: Bloomberg and non -c-3 groups everyone,
Chuck Babcock Bloomberg wrote this (Monday) afternoon and said that tomorrow may the last chance for respond his questions its the first time referred deadline. followed later thanking for sticking
with him through his inquiries.
Below Ill paste the key parts his most recent messages (which you havent seen); youll get idea what
focusing what may the end his reporting efforts. Please let know how youd like handle his questions.
One about the date the current ork Plan; believe was released the public December 2010? down below Ill paste -mail message Babcock which Ive drafted but not yet sent that based the
material that Judy provided the other day. you give final go-ahead, Ill send Mr. Babcock tomorrow
(Tuesday) morning.
Meanwhile, combing through all his questio date see Ive missed anything that should re-bring your
attention. told Mr. Babcock that call him tomorrow touch base and Ill let you know right away what says.
Thank you,
Grant
JW1559-007093
Grant illiams
IRS National Media Relatio
(202) 622-4000
MR. BABCOCKS MOST RECENT EMAILS:
--- progress any newest questions? and
what btw the date the directors 2011 work plan
that mentions are increasing our focus 501c4,5 and
org? asked about manpower for that. more bottom line, what
evidence can you cite show you are doing what the director
said. specifics such audits have increased from
what? Checking back progress queries. Like date the 2011 work plan and evidence the irs focusing more including political activity. Thanks. Any news today? Running out time. Tomorrow [Tuesday the 14th] may last chance. Particularly need answers
evidence you can cite that folks taking closer look 501cs work plan said, and whether any has ever
had exemption revoked for politicial activity. so, would like details course thanks again for sticking with this. DRAFT MESSAGE MR. BABCOCK (that Ill send him when you give the green light): Chuck,
(b)(5)
Ill give you call soon today touch base, Chuck.
Sincerely,
Grant illiams
IRS National Media Relations
(202) 622-4000
JW1559-007094
JW1559-007095
From:
Seto Michael
Sent:
Friday, July 15, 2011 4:21
To:
Lerner Lois Light Sharon Kindell Judith Letourneau Diane
Cc:
Neuhart Paige; Trilli Darla Paz Holly
Subject:
SCR Report for June
Attachments:
SCR Report Table June 2011.doc
Summary SCR cases Item interest:
(b)(3); 6103
(b)(3)/6103
(b)(3)/6103
JW1559-007096 Technical
Significant Case Report
(June 30, 2011) open SCs Open SCs:
Name
Org/Group
Group
#/Manager
EIN
Received
T2/Ron
Shoemaker
(b)(3)/6103
Issue
Tax Law
Estimated
Specialist Completion
Date
Status/Next action
Being Elevated TEGE
Commissioner
This Month
Whether tea party organization
meets the requirements under
section 501(c)(3) and not involved political intervention. Whether
organization condu cting excessive
political activity deny exemption
under section 501(c)(4)
(b)(3)/6103
(b)(3)/6103
JW1559-007097
(b)(3)/6103 (b)(5)/DP
JW1559-007098
(b)(3)/6103 (b)(5)/DP
JW1559-007099
(b)(3)/6103 (b)(5)/DP
JW1559-007100
(b)(3)/6103 (b)(5)/DP
JW1559-007101
(b)(3)/6103 (b)(5)/DP
JW1559-007102
(b)(3)/6103 (b)(5)/DP
JW1559-007103
(b)(3)/6103 (b)(5)/DP
JW1559-007104
From:
Keith Frank
Sent:
Tuesday, July 19, 2011 12:25
To:
Eldridge Michelle Lemons Terry Lerner Lois Grant Joseph Flax Nikole
Cc:
Burke Anthony; Williams Grant
Subject:
RE: New York Times Stephanie Strom c4s/determination letters understand it, could not trying send message releasing these because their release required under
IRC 6110.
From: Eldridge Michelle
Sent: Tuesday, July 19, 2011 12:06
To: Keith Frank; Lemons Terry Lerner Lois Grant Joseph Flax Nikole
Cc: Burke Anthony; Williams Grant
Subject: FW: New York Times Stephanie Strom c4s/determination letters
FYI--We have heard back from Stephanie Strom with more details her story, and her questions relates some
(c)4 determination letters. Here are two the three determination letters she references.
She asking for answers
today--not sure that her firm deadline not...
The link 201128034 is: http://www.irs.gov/pub/irs -wd/1128034.pdf
The link 201128035 is: http://www.irs.gov/pub/irs -wd/1128035.pdf attaching the two -mails relating Stephanies inbound from today and yesterday wit her questions. Please advise how you wish handle. Thanks. --Michelle
From: Strom, Stephanie mailto:ssstrom@nytimes.com
Sent: Tuesday, July 19, 2011 10:59
To: Williams Grant
Subject: RE: Stephanie
So, working story about the three determination letters related c4s that were released last Thursday. Not
surprisingly, theres pretty intense speculation about who they might and whether the I.R.S. trying send
message with the rel ease know, know, you all cant say ANYTHING about any that.
What trying get grip what c4s are required terms filing for I.R.S. approval tax exemption.
there form, 1024, for them use, but was talkin with Lois awhile back, and she said that c4s fact not have
seek approval. They can set themselves up, begin operating and then file 990 the end their fiscal year, which sort automatically creates their exemption. one question is: all c4s required file 1024 and get determination
letter from the I.R.S.? so, what point their lifetime they have that? other question one you all probably cant/wont answer, but have ask: When did these three orga nizations file
their 1024s? The determination letters say two were founded 2006 and one 2007 did they apply within year
their creation? The letters also refer application forms for the years 2010 and 2011, which suggestss maybe the
application was more recent.
Many thanks, Stephanie
From: Burke Anthony
Sent: Monday, July 18, 2011 12:36
To: Eldridge Michelle
Subject: New York Times 501(c)(4)s denied exempt status
JW1559-007105
Michelle, received call from New York Times reporter Stephanie Strom who asked for particular PLR: 201128092,
which has not yet been posted IRS.gov. Stephanie became interested the PLR after reading item Paul
Streckfus the Journal: Tax Journal 2011-118
Paul Streckfus, July 18, 2011 5:50
Some interesting PLRs were released the IRS last week. Today note the ones found most interest. IRS Denies 501(c)(4) Status Three Organizations Primarily Benefiting Political Party Three-Year Wait Rewarded PLR 201128027
The IRS probably got right this private letter ruling (reprinted below), involving ecumenical ministry that offers
broad range social service programs the poor and distressed underprivileged, but lots slippery slopes had
scaled, least opinion. Continue http://eotaxjournal.com/eotj/
She said the article referred PLRs 201128034 and 201128035. PLR 201128024 final determination that entity
did not qualify for exempt status under 501(c)(4) because activities were conducted primarily for the benefit
political party and private group individual rather than the community whole. hen explained that the PLR
referred the Paul Streckfus item, 20112892 was probably the process being redacted before could placed IRS.gov, she had follow -up questions.
JW1559-007106
From:
Lerner Lois
Sent:
Tuesday, July 19, 2011 1:05
To:
Eldridge Michelle
Subject:
Re: New York Times Stephanie Strom c4s/determination letters out this meeting 2:30. Can talk then?
Lois Lerner-------------------------Sent from BlackBerry Wireless Handheld
From: Eldridge Michelle
Sent: Tuesday, July 19, 2011 12:05
To: Keith Frank; Lemons Terry Lerner Lois Grant Joseph Flax Nikole
Cc: Burke Anthony; Williams Grant
Subject: FW: New York Times Stephanie Strom c4s/determination letters
FYI--We have heard back from Stephanie Strom with more details her story, and her questions relates some
(c)4 determination letters. Here are two the three determination letters she references.
today--not sure that her firm deadline not...
She asking for answers
The link 201128034 is: http://www.irs.gov/pub/irs -wd/1128034.pdf
The link 201128035 is: http://www.irs.gov/pub/irs -wd/1128035.pdf attaching the two -mails relating Stephanies inbound from today and yesterday with her questions. Please advise how you wish handle. Thanks. --Michelle
From: Strom, Stephanie mailto:ssstrom@nytimes.com
Sent: Tuesday, July 19, 2011 10:59
To: Williams Grant
Subject: RE: Stephanie
So, working story about the three determination letters related c4s that were released last Thursday. Not
surprisingly, theres pretty intense speculation about who they might and whether the I.R.S. trying send
message with the release know, know, you all cant say ANYTHING about any that.
What trying get rip what c4s are required terms filing for I.R.S. approval tax exemption. know
there form, 1024, for them use, but was talking with Lois awhile back, and she said that c4s fact not have
seek approval. They can set themselves up, begin operating and then file 990 the end their fiscal year, which sort automatically creates their exemption. one question is: Are all c4s required file 1024 and get determination
letter from the I.R.S.? so, what point their lifetime they have that? other question one you all probably cant/wont answer, but have ask: When did these three organizations file
their 1024s? The determination letters say two were founded 2006 and one 2007 did they apply within year
their creation? The letters also refer application forms for the years 2010 and 2011, which suggestss maybe the
application was more recent.
Many thanks, Stephanie
From: Burke Anthony
Sent: Monday, July 18, 2011 12:36
JW1559-007107
To: Eldridge Michelle
Subject: New York Times 501(c)(4)s denied exempt status
Michelle, received call from New York Times reporter Stephanie Strom who asked for particular PLR: 201128092,
which has not yet been post IRS.gov. Stephanie became interested the PLR after reading item Paul
Streckfus the Journal: Tax Journal 2011-118
Paul Streckfus, July 18, 2011 5:50
Some interesting PLRs were released the IRS last week. Today note the ones found most interest. IRS Denies 501(c)(4) Status Three Organizations Primarily Benefiting Political Party Three-Year Wait Rewarded PLR 201128027
The IRS probably got right this private letter ruling (reprinted below), involving ecumenical ministry that offers
broad range social service programs the poor and distressed underprivileged, but lots slipper slopes had
scaled, least opinion. Continue http://eotaxjournal.com/eotj/
She said the article referred PLRs 201128034 and 201128035. PLR 201128024 final determination that entity
did not qualify for exempt status under 501(c)(4) because activities were conducted primarily for the benefit
political party and private group individuals rather than the community whole. hen explained that the PLR
referred the Paul Streckfus item, 20112892 was probably the process being redacted before could placed IRS.gov, she had follow -up questions.
JW1559-007108
From:
Lerner Lois
Sent:
Tuesday, July 19, 2011 1:06
To:
Fish David
Cc:
Paz Holly Letourneau Diane
Subject:
Fw: New York Times Stephanie Strom c4s/determination letters
Will talking them 2:30 know why the denial dated Jan and the one dates April came out same time?
redaction? Why would one take much longer than the other? Not complaining --just need something say. Thanks
Lois Lerner-------------------------Sent from BlackBerry Wireless Handheld
From: Flax Nikole
Sent: Tuesday, July 19, 2011 12:17
To: Lerner Lois Kindell Judith Fish David
Subject: FW: New York Times Stephanie Strom c4s/determination letters
Can someone talk about this? Thanks
2-5055
From: Eldridge Michelle
Sent: Tuesday, July 19, 2011 12:06
To: Keith Frank; Lemons Terry Lerner Lois Grant Joseph Flax Nikole
Cc: Burke Anthony; Willia Grant
Subject: FW: New York Times Stephanie Strom c4s/determination letters
FYI--We have heard back from Stephanie Strom with more details her story, and her questions relates some
(c)4 determination letters. Here are two the thr determination letters she references. She asking for answers
today--not sure that her firm deadline not...
The link 201128034 is: http://www.irs.gov/pub/irs -wd/1128034.pdf
The link 201128035 is: http://www.irs.gov/pub/irs -wd/1128035.pdf attaching the two -mails relating Stephanies inbound from today and yesterday with her questions. Please advise how you wish handle. Thanks. --Michelle
From: Strom, Stephanie mailto:ssstrom@nytimes.com
Sent: Tuesday, July 19, 2011 10:5
To: Williams Grant
Subject: RE: Stephanie
So, working story about the three determination letters related c4s that were released last Thursday. Not
surprisingly, theres pretty intense speculation about who they might and whether the I.R.S. trying send
message with the release know, know, you all cant say ANYTHING about any that.
What trying get grip what c4s are required terms filing for I.R.S. approval tax exemption. know
there form, 1024, for them use, but was talking with Lois awhile back, and she said that c4s fact not have
seek approval. They can set themselves up, begin operating and then file 990 the end their fiscal year, which sort automatically creates their exemption. one question is: Are all c4s required file 1024 and get determination
letter from the I.R.S.? so, what point their lifetime they that?
JW1559-007109 other question one you all probably cant/wont answer, but have ask: When did these three organizations file
their 1024s? The determination letters say two were founded 2006 and one 2007 did they apply within year
their creation? The letters also refer application forms for the years 2010 and 2011, which suggestss maybe the
application was more recent.
Many thanks, Stephanie
From: Burke Anthony
Sent: Monday, July 18, 2011 12:36
To: Eldridge Michelle
Subject: New York Times 501(c)(4)s denied exempt status
Michelle, received call from New York Times reporter Stephanie Strom who asked for particular PLR: 201128092,
which has not yet been posted IRS.gov. Stephanie became interested the PLR after reading item Paul
Streckfus the Journal: Tax Journal 2011-118
Paul Streckfus, July 18, 2011 5:50
Some interesting PLRs were released the IRS last week. Today note the ones found most interest. IRS Denies 501(c)(4) Status Three Organizations Primarily Benefiting Political Party Three-Year Wait Rewarded PLR 201128027
The IRS probably got right this private letter ruling (reprinted below), involving ecumenical ministry that offers
broad range social service programs the poor and distressed underprivileged, but lots slippery slopes had
scaled, least opinion. Continue http://eotaxjournal.com/eotj/
She said the article referred PLRs 201128034 and 201128035. PLR 201128024 final determination that entity
did not qualify for exempt status under 501(c)(4) because activities were conducted primarily for the nefit
political party and private group individuals rather than the community whole. hen explained that the PLR
referred the Paul Streckfus item, 20112892 was probably the process being redacted before could placed IRS.gov, she had follow -up questions.
JW1559-007110
From:
Flax Nikole
Sent:
Tuesday, July 19, 2011 1:06
To:
Lerner Lois Kindell Judith Fish David
Subject:
RE: New York Times Stephanie Strom c4s/determination letters you guys have the full streckfus story? thanks
From: Flax Nikole
Sent: Tuesday, July 19, 2011 12:17
To: Lerner Lois Kindell Judith Fish David
Subject: FW: New York Times Stephanie Strom c4s/determination letters
Can someone talk about this Thanks
2-5055
From: Eldridge Michelle
Sent: Tuesday, July 19, 2011 12:06
To: Keith Frank; Lemons Terry Lerner Lois Grant Joseph Flax Nikole
Cc: Burke Anthony; Williams Grant
Subject: FW: New York Times Stephanie Strom c4s/determination letters
FYI--We have heard back from Stephanie Strom with more details her story, and her questions relates some
(c)4 determination letters. Here are two the three determination letters she ref erences. She asking for answers
today--not sure that her firm deadline not...
The link 201128034 is: http://www.irs.gov/pub/irs -wd/1128034.pdf
The link 201128035 is: http://www.irs.gov/pub/irs -wd/1128035.pdf attaching the two -mails relating Stephanies inbound from today and yesterday with her questions. Please advise how you wish handle. Thanks. --Michelle
From: Strom, Stephanie mailto:ssstrom@nytimes.com
Sent: Tuesday, July 19, 2011 10:59
To: Williams Grant
Subject: RE: Stephanie
So, working story about the three determination letters related c4s that were released last Thursday. Not
surprisingly, theres pretty intense speculation about who they might and whether the I.R.S. trying send
message with the release know, know, you all cant say ANYTHING about any that.
What trying get grip what c4s are required terms filing for I.R.S. approval tax exemption.
there form, 1024, for them use, but was talking with Lois awhile back, and she said that c4s fact not have
seek approval. They can set themselves up, begin operating and then file 990 the end their fiscal year, which sort automatically creates their exemption. one question is: Are all c4s required file 1024 and get determination
letter from the I.R.S.? so, what point their lifetime they have that? other question one you all probably cant/wont answer, but have ask: When did these three organizations file
their 1024s? The determination letters say two were founded 2006 and one 2007 did they apply within year
their creation? The letters also refer application forms for the years 201 and 2011, which suggestss maybe the
application was more recent.
JW1559-007111
Many thanks, Stephanie
From: Burke Anthony
Sent: Monday, July 18, 2011 12:36
To: Eldridge Michelle
Subject: New York Times 501(c)(4)s denied exempt status
Michelle, received call from New York Times reporter Stephanie Strom who asked for particular PLR: 201128092,
which has not yet been posted IRS.gov. Stephanie became interested the PLR after reading item Paul
Streckfus the Journal: Tax Journal 2011-118
Paul Streckfus, July 18, 2011 5:50
Some interesting PLRs were released the IRS last week. Today note the ones found most interest. IRS Denies 501(c)(4) Status Three Organizations Primarily Benefiting Political Party Three-Year Wait Rewarded PLR 201128027
The IRS probably got right this private letter ruling (reprinted below), involv ing ecumenical ministry that offers
broad range social service programs the poor and distressed underprivileged, but lots slippery slopes had
scaled, least opinion. Continue http://eotaxjournal.com/eotj/
She said the article referred PLRs 201128034 and 201128035. PLR 201128024 final determination that entity
did not qualify for exempt status under 501(c)(4) because activities were conducted primarily for the benefit
political party and private group individual rather than the community whole. hen explained that the PLR
referred the Paul Streckfus item, 20112892 was probably the process being redacted before could placed IRS.gov, she had follow -up questions.
JW1559-007112
From:
Fish David
Sent:
Tuesday, July 19, 2011 1:14
To:
Flax Nikole
Cc:
Kindell Judith Lerner Lois
Subject:
FW: Tax Journal 2011-118
From: paul streckfus [mailto:pstreckfus@gmail.com]
Sent: Monday, July 18, 2011 5:43
To: paul streckfus
Subject: Tax Journal 2011 -118
From the Desk Paul Streckfus,
Editor, Tax Journal
Email Update 2011-118 (Monday, July 18, 2011)
Copyright 2011 Paul Streckfus
Some interesting PLRs were released the IRS last week. Today note the ones found most interest. IRS Denies 501(c)(4) Status Three Organizations Primarily Benefiting Poli tical Party Three-Year Wait Rewarded PLR 201128027
The IRS probably got right this private letter ruling (reprinted below), involving ecumenical ministry that offers
broad range social service programs the poor and distressed nderprivileged, but lots slippery slopes had scaled, least
opinion.
_________________________ IRS Denies 501(c)(4) Status Three Organizations Primarily Benefiting Political Party
Three organizations that appear similar the rganization that was the subject 1989 Tax Court opinion American Campaign
Academy Commissioner, T.C. 1053) were denied exemption under section 501(c)(4) Denial Letters 201128032, 201128034,
and 201128035. Denial letter 201128034 set out below. The facts each denial letter, while heavily redacted, appear describe
separate organizations, which have different dates formation 2006 -2007. The Law and Analysis each denial letter the same.
None the organizations appea have protested the IRS proposed determination. Since section 501(c)(4) status issue, they
are not entitled judicial review under section 7428 the Code, but will probably still end court.
PLR 201128034
Contact Person:
Identification Number:
Contact Number:
Employer Identification Number:
Form Required Filed:
Tax Years:
UIL: 501.04 -00
Date: April 18, 2011
Release Date: 7/15/2011
Dear
JW1559-007113
This our final determination that you qualify for exemption from Federal income tax under Internal Revenue Code section
501(a) organization described Code section 501(c)(4). made this determination for the following reason(s):
You are not operated primarily promote social lfare because your activities are conducted primarily for the benefit political
party and private group individuals, rather than the community whole.
You must file Federal income tax returns the form and for the years listed above within days this letter, unless you request
extension time file. File the returns accordance with their instructions, and not send them this office. Failu file the
returns timely may result penalty. 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 Intention Disclose, and review the two
attached letters show our proposed deletions. you disagree with our proposed deletions, follow the instructions Notice 437.
you agree with our deletions, you not need take any further action. you have any questions about this letter, please contact person whose name and telephone number are shown the heading
this letter. you have any questions about your Federal income tax status and responsibilities, please contact IRS Customer
Service 1-800-829-1040 the IRS Customer Service number for businesses, 1-800-829-4933. The IRS Customer Service number for
people with hearing impairments 1-800-829-4059.
Sincerely,
Lois Lerner
Director, Exempt Organizations
Internal Revenue Service
Washington, D.C.
Enclosure
Notice 437
Redacted Proposed Adverse Determination Letter
Redacted Final Adverse Determination Letter
Contact Person
Identification Number:
Contact Number:
FAX Number:
Employer Identification Number:
UIL Code: 501.04 -00
Date: January 14, 2011
LEGEND:
State
Party
Dear have considered your application for recogn ition exemption from Federal income tax under section 501(a) the Internal
Revenue Code (the Code). Based the information provided, have concluded that you not qualify for exemption under
section 501(c)(4) the Code. The basis for our con clusion set forth below.
FACTS
You were formed December 21, 2007 nonprofit corporation under the laws State. Your Articles Organization and laws
state that your purpose
JW1559-007114
and operate exclusively promote the social welfare within the meaning Section 501(c)(4) the Internal Revenue Code.
Your Articles Organization and Bylaws provide that upon dissolution, your assets shall dedicated social welfare purp oses, and
that part your net income assets may inure the benefit any director, officer, member, private individual.
You conduct training program for who are members Party. The program includes sessions covering
Your recruitment students began and training began
You charge tuition for your training program. You provide scholarships for tuition expenses and make payment plans
available. You select part icipants each year.
Your website contains number materials related your training program. Your homepage states that you are You des cribe
your curriculum follows:
Your website states that you select tudents for your training program based evidence
Your 2010 Program Application shows that one your training dates coincides with the [Party]s State Convention and contain and, applicant did not then asked explain why.
Your 2010 Program Application also contains which requires the applicant affirm the following: your page you state you are, the same page, you state, answering the question What makes [you] unique? you state that you are You also state that you are materials you provide potential donors, you note your rograms success stating that the
LAW
Section 501(a) the Internal Revenue Code (Code) exempts from federal income tax organizations described section 501(c
)(4).
Section 501(c)(4)(A) the Code describes civic leagues organizations organized for profit but operated exclusively for the
promotion social welfare. Section 501(c)(4)(B) indicates that subparagraph (A) shall not apply entity unless part the net
earnings such entity inures the benefit any private hareholder individual.
Section 1.501(c)(4) -1(a)(1) the Income Tax Regulations (regulations) states that described section 501(c)(4) the Code, organization must not organized operated for profit and must operated exclusively
for the promotion social welfare.
Section 1.501(c)(4) -1(a)(2) the regulations states that organization operated exclusively for the promotion social welfare primarily engaged promoting some way the common good and general lfare the people the community.
Additionally, states that organization described within this section operated primarily for the purpose bringing
about civic
betterments and social improvements.
Rev. Rul. -306, 1973 C.B. 179, provides that organization formed for the purpose promoting the common interest tenants
who reside particular apartment complex does not qualify for exemption under section 501(c)(4) the Code. Any person
regularly living the complex was eligibl for membership. The organization represented its member -tenants negotiations with the
JW1559-007115
management the complex order secure better maintenance and services, well reasonable rentals. The ruling holds
that the
organization was not described section 501(c)(4) because operated essentially benefit its members and, thus, was not primarily
engaged activities that promote the common good and general welfare the community. contrast, Rev. Rul. -206, 1980
C.B. 185, holds that organization formed promote the legal rights all tenants community, instead limiting its benefits
member-tenants, does qualify for exemption under section 501(c)(4) the Code.
Rev. Rul. -349, 1973 C.B. 179, holds that organizati formed purchase groceries for its members the lowest possible
nterprise
prices cooperative basis not exempt under section 501(c)(4) the Code. Rather, the organization was cooperative
operated primarily for the private economic benefi convenience its members, and provided only incidental benefit the
community.
Rev. Rul. -286, 1975 C.B. 210, describes organization that was formed the residents city block preserve and beautify
that block, improve all publi facilities within the block, and prevent physical deterioration the block. Its activities consisted
paying the city government plant trees public property within the block, organizing residents pick litter and ref use the
public streets and public sidewalks within the block, and encouraging residents take active part beautifying the block
between
placing shrubbery public areas. Much the public area improved the organization was part the public roadway lying
was
the sidewalk and the street front private property owned members the organization. Membership the organization
restricted residents the block and those owning property operating businesses there.
Because the activities enhanc the value the members property rights, the organization served the private interests its members
and did not qualify for exemption under section 501(c)(3). The restricted nature its membership and limited area which
improvements were made ere further indicators private benefit. However, beautifying and preserving public property
cooperation with the local government, the organization was considered primarily promote the general welfare the commun
ity
even though its activities also benefited its members. Therefore, the organization did qualify under section 501(c)(4). Erie Endowment United States, 316 F.2d 151 (3d Cir. 1963), the court held that qualify for exemption within the meaning
Id. 156.
section 501(c)(4) the Code, the organization must community movement designed accomplish community ends. Commissioner Lake Forest, Inc., 305 F.2d 814 (4th Cir. 1962), corporation was organiz World War veterans for the
purpose purchasing government housing project and converting cooperative, nonprofit housing for its members. Indiv iduals
became members the corporation purchasing apartment unit and, such, the numb members was limited the number units available. The court held that the organization was not described section 501(c)(4) the Code because was
public-
spirited but privately -devoted endeavor that provided only incidental benefit community. Id. 818. The organization did not
and did
promote social welfare because furnished housing only certain group individuals, rather than community basis,
not offer service program for the direct betterment improvement the community whole. New York State Association Real Estate Boards Group Insurance Fund Commissioner, T.C. 1325 (1970), association
organized small group interested obtaining group insurance did not qualify for exemption cause offered its benefits only limited class its members and their employees. The court noted [t]here not such organization the requisite civ concern constitute social welfare required for qualification under section 501(c)(4). Where the primary benefit from organization
limited that organizations members, and not provided the community whole, the organization not operated primar ily for
the social welfare. Contracting Plumbers Cooperative Restoration Corp United States, 488 F.2d 684 (2d Cir. 1973), cert. denied, 419 U.S. 827
(1974), plumbers working New York City were responsible for the cuts they made the city streets. Prior the organizat ions
existence, the city had repaired the cuts and bil led the plumbers individually what proved highly inefficient system. The
organization was formed order restore the city streets. only repaired cuts made its members. The joint effort
the plumbers
reduced their liability and their expenses, and more efficiently repaired the city streets. While the court found that the program
provided substantial benefits the public, concluded that the organization primarily served the private economic interes its
members and, thus, could not considered exempt under section 501(c)(4) the Code. American Campaign Academy Commissioner, T.C. 1053 (1989), the organizations primary activity was operate school
(the Academy) training individuals for careers political cam paign professionals. The organization represented its application
for exemption that the Academy was outgrowth programs operated the National Republican Congressional Committee
(NRCC) that were designed train candidates and train and bsequently place campaign professionals Republican
campaigns. addition, the NRCC contributed physical assets the Academy, two the Academys six full -time faculty members
had been previously involved the NRCCs training program, one the ademys three initial directors was the Executive Director the NRCC the time, and another initial director was member the Republican National Committee the time. The Acad emys
activities were exclusively funded the National Republican Cong ressional Trust. The Academys curriculum included discussions
concerning How some Republicans have won Black votes, NRCC/RNC/NRSC/State Party naughtiness, and Use GOP allies,
without counterbalance comparable studies other political parti es.
JW1559-007116
While applicants the Academy were not required formally declare their political affiliation attend the organization school, the
admission panel could deduce such affiliation from the campaign experiences and political references the appl ications. The court
found that this knowledge applicants political affiliations allowed the admission panel limit enrollment applica nts who
were likely subsequently work Republican organizations and campaigns. Indeed, the court found tha graduate was known
affiliate with any political party other than the Republican Party. substantial number the members the Academys admi
ssion
panel were affiliated with the Republican Party.
The Service determined that the organization ope rated for substantial, non -exempt private purpose. The Tax Court agreed, holding
the organization did not operate exclusively for exempt, educational purposes under section 501(c)(3) the Code because
conducted its activities benefit the private interests Republican entities and candidates. Although these entities and candidates
cause
were not organization insiders, the court stated that the conferral nonincidental benefits disinterested persons may
organization serve private terest. While the school had legitimate educational program, conducted these activities with the
partisan objective benefiting Republican candidates and entities. such, more than incidental private benefit was conf erred
Republican entities and candidates who employed the Academys students, one that precluded exemption under section 501(c)(3).
ANALYSIS
Based the information you submitted with your application and subsequent correspondence, you are not operated exclusive for
the promotion social welfare within the meaning section 501(c)(4) the Code because your activities primarily serve private
interests. Therefore, you not qualify for exemption from federal income tax organization described section 501(c) (4).
Your activities not primarily promote social welfare because you primarily benefit private individuals and interests. organization operated exclusively for the promotion social welfare primarily engaged promoting some the
common good and general welfare the people the community. Section 1.501(c)(4) -1(a)(2)(i) the regulations. organization
recognized under section 501(c)(4) operated primarily for the purpose bringing about civic betterments and social
improvements. Id. qualify for exemption under section 501(c)(4), organization must primarily benefit the community whole, rather tha select
individuals groups. See Contracting Plumbers Coop. Restoration Corp., supra; New York State Assn Real state Boards Group
Ins. Fund, supra; Lake Forest, Inc., supra; Rev. Rul. -286,supra. section 501(c)(4) organization must community
movement designed accomplish community ends. Erie Endowment, supra. such, tenants organization that benef its all the
tenants the community qualifies for exemption, while one that directs its activities toward benefiting only its member -tenants does
not. Compare Rev. Rul. -206, supra, with Rev. Rul. -306, supra; see also Rev. Rul. -349, supra. Therefore, conferring
sufficient amount private benefit select individuals will preclude exemption under section 501(c)(4) for organizatio that
would otherwise qualify. Even organization substantially benefits the community, will fail qualify for exemption
primarily benefits private interests. See Contracting Plumbers, supra.
mmon good.
Educational activities undertaken provide partisan benefit are considered serve private interests, rather than the American Campa ign Academy, supra, the court denied exemption under section 501(c)(3) school organized train individuals
for careers political campaign professionals because its educational activities were operated with the partisan purpose
benefiting
Republican Party entities and candidates. The private benefit conferred these persons was more than incidental, and thus
demonstrated substantial non -exempt purpose that precluded exemption. While you are requesting recognition organization
described section 501(c)(4) and not section 501(c)(3) (as was American Campaign Academy), the standard for determining what
constitutes private benefit described American Campaign Academy applies both sections such, for purposes both section
501(c)(3) and section 501(c)(4), organization which conducts its educational activities benefit political party and its candi dates
serves private interests. And, discussed above, organization that primarily serves private interests fails qualify exemption
under section 501(c)(4).
Thus, notwithstanding any benefit your educational activities may provide the community, you fail qualify for exemption
because your training program primarily benefits the interests the Party and its candida tes. According your Articles, Bylaws, and
website, your primary activity train and recruit who are members Party run for political office. Moreover,
your
program application asks prospective students disclose specific details the political participation member Party, and
clearly discloses that you limit your membership registered members the Party Like the school
American Campaign
Academy, your purpose conducting this activity provide education lely individuals affiliated with certain political party
who want enter politics. Indeed, you measure your success terms the number your graduates who have won elective
ffice
representing the Party.
Because your primary activity ucational program that limited who are members Party and conducted with the
partisan objective increasing the number Partys elected officials, you primarily serve private interests. Therefore, operation
JW1559-007117 your program does not promote social welfare within the meaning section 501(c)(4) the Code.
CONCLUSION
benefit summary, you are not operated primarily promote social welfare because your activities are conducted primarily for the political party and privat group individuals, rather than the community whole. Accordingly, you not qualify for
exemption organization described section 501(c)(4) the Code and you must file federal income tax returns.
[Standard paragraphs deleted]
Sincerely,
Holly Paz, Acting Director
Exempt Organizations Rulings Agreements
Internal Revenue Service
Washington, D.C.
___________________________ Three-Year Wait Rewarded PLR 201128027
The IRS probably got right this private letter ruling (repr inted below), involving ecumenical ministry that offers broad range social service programs the poor and distressed underprivileged, but lots slippery slopes had scaled,
ast
opinion.
Query: Does this private letter ruling break new ground sufficient fall back facts and circumstances (facts that are not all
that clear)? indebted Bill Brockner for his analysis and comments, which tried follow, but any errors are mine which sure point out.
The IRS ruled PLR 201128027 that the use the [community] center tenants (to conduct substantially related activitie and
programs) will constitute substantially related use you for purposes section 514(b)(1)(A). According the stat ement facts,
You would rent space cost clubs, community foundations, church groups, schools and other nonprofit organizations and
individuals that respond community needs. How cost defined?
Are these facts covered Rev. Rul. -572 (reprinted below) Rev. Rul. -547, neither which cited PLR 201128027? Rev.
Rul. 69-572 states: Because the close connection between this organization and the charitable functions the tenant organizations, the rental the organizations facilities rates substantially below their fair rental value, and the operation the
organization with the intention realizing amount sufficient only meet annual operating costs, the organization dicated
carrying out the charitable deavors the community chest and its member agencies. Rev. Rul. -547, the other hand, holds
that lease, the parties which are both exempt under section 501(c)(3) the Code and which otherwise constitutes bus iness
lease within the meaning section 514 the Code, will not considered substantially related the charitable purpose the
lessor solely because the lessee likewise exempt organization. the organization described PLR 201128027 sufficiently different from organization described Rev. Rul. -360, which
describes health club? PLR 201128027, the annual membership fee has been set less than percent the fees charge the
other commercial centers the neighborhoods. Anyone who has been member health club compared fees knows pricing
varies all over the place, with various discounts available, with various plans membership available, etc., saying one
club
percent cheaper than others probably can established any firm basis. The organization PLR 201128027 says would turn one away because inability pay. How does that work? publicized? How inability pay defined? noted, facts and circumstances seem play big role this ruling rationale. The ruling indicates that the recreational facilities
benefit significant segment underserved population with affordable membership fees. all this not enough, the IRS cites the Restatement (Second) Trusts for the proposi tion that organization promoting the
general happiness community charitable. Does that include organization giving out free beer? beer cost? Supp ose that
part ecumenical ministry? Are number slippery slopes with rulin like PLR 201128027?
PLR 201128027
Contact Person:
Identification Number:
Telephone Number:
JW1559-007118
Employer Identification Number:
UIL: 513.00 -00, 514.00 -00
Release Date: 7/15/2011
Date: April 20, 2011
LEGEND:
Dear
empt have considered your request dated, December 2007, for ruling with regard whether income produced rental and
activities related your debt -financed property will included the computation your unrelate business income under section
512 the Internal Revenue Code (Code). made charitable bequest ecumenical ministry that offers broad range social service programs the poor and
distressed underprivileged. consists several ter ritories, including and you. made the gift construct community
centers underserved urban areas throughout the country that would attend spiritual and physical needs, combat juvenile
delinquency and provide opportunities for community buil ding. The trust requires place one -half the gift capital building
fund purchase real properties and construct, furnish and equip the community centers, and place the other half separa
endowment fund used for employee salaries other operating expenses. plans divide the gift equally between the
territories, which will allocate the funds accordance with the trust provisions.
Before died, she gave funds build prototype community center. found that the port ion the funds allocated the
endowment fund produced only percent the revenue necessary cover its operating costs. this time, temporarily
redirecting other resources cover the deficit. You are concerned that, since your allocation funds will identical, your reserves
would also insufficient cover the operating costs your new centers. ensure adequate level funding for your new centers ongoing operations, you plan finance your centers differently You
would issue construction bonds and use the proceeds purchase investment securities that would comprise reserve fund capable
generating significant portion the income necessary cover operating costs and serve sinking fund for retiring
the
construction bonds. You agree that the outstanding bond indebtedness acquisition indebtedness defined section 514(c) (1)
the Code.
You have received your part the gift and identified several communities that you believe would get the most enefit. One center
currently operating and the others are the planning and construction stages, but you expect them substantially simil ar. You
intend to:
Integrate the spiritual ministry with other services provided the centers,
Link the centers programs the existing social -service programs that you have established the communities,
Provide high -quality personal development opportunities that build character, confidence and competence young people, families
and individuals inclusive manner, including opportunities education, recreation and the arts, and
Ensure that the centers are accessible and target population children, families and individuals that are underserve
You selected the communities that howed the most need based the information collected from the local offices federal, state and
local governments population, economic, and demographic statistics. For example, the information you gathered with rega
one community showed that percent the population lives poverty (about twice the citywide figure). Residents this
community have twice the citywide rate public assistance, single -parent families, and households with children under 18.
You base your representations approximations the center that currently operating. All your centers would offer
memberships the public. You gathered fee information from the health and fitness centers the communities and set your nnual
membership fees less than percent the fees charged the other commercial centers the neighborhoods. Your annual fees
would include use all areas the centers, except for classes, skating, camps and programs. You would also offer fees sliding
scale based governm ent standards for assistance and scholarships anyone who demonstrates financial need. person
unable pay, but does not qualify for scholarship, you have committed reduce the fee amount that the person can
pay. You
state that you ould turn one away because inability pay.
JW1559-007119
You state that you would devote percent more your property programs that further exempt purposes. For example,
would devote percent your properties religious and educational progr ams. The faith and family center would include
worship area, nursery, food pantry, and dedicated spaces for senior and youth programs. The learning and technology center uld
offer computer usage, classrooms/seminar rooms, tutoring, technology instructi programs, literacy instruction, GED training,
vocation-specific programs and creative arts classes. Finally, the visual/performing arts theater center would offer public performanc music and dance, youth, family and community theater, music lessons dance programs, visual arts and crafts instruction and
exhibition.
You would also use approximately percent your properties for recreational programs. Your indoor recreational area would
offer fitness center, basketball and sports gymnasium, ind oor running/walking track, game room and locker rooms. You would offer
general-purpose swimming pool, leisure pool for childrens entertainment, relaxation, fitness and swim instruction and therapeutic
whirlpool for relaxation and rehabilitation. Final ly, you would provide outdoor area for outdoor sports, recreation, and soccer
field, softball/Little League fields, grass volleyball court, general -purpose recreation fields, skateboarding park, outdoor
amphitheater, childrens playground, and horti cultural center for family and youth development.
Your special programs, which would comprise percent your facilities, would offer healthy living center, childcare cen ter,
kitchen, library, gathering space, and emergency/disaster services. You wou use your kitchen provide free meals every Monday
through Friday persons who are homeless, unemployed, otherwise cannot afford hot meal.
You plan rent space for various purposes. You would rent space cost clubs, community foundations church groups, schools
and other non -profit organizations and individuals that respond community needs. You estimate that you would rent approximately
two percent floor space and use less than one percent total open hours for other activities. would not provide any services
connection your rental income and you not anticipate using the facility for any long -term rental activities.
RULINGS REQUESTED Provided that substantially all the use the centers will used described,
the rental income, any, that you derive from the
non-exempt purpose use the centers will qualify for the exclusion provided section 514(b)(1)(A). The income that you will receive from the various recreational, charitable, religious, and educ ational activities conducted the
centers, described herein, will not constitute income from unrelated trade business defined under section 513(a)
because
those activities are substantially related your tax -exempt purposes. The use the center tenants (to conduct substantially related activities and programs), from which you may derive rental
income will constitute substantially related use you for purposes section 514(b)(1)(A).
LAW
Section 511 the Internal Revenue Code (Code) imposes tax the unrelated business taxable income (as defined section 512) organizations described sections 401(a) and 501(a).
Section 512(a) the Code states that the term unrelated business taxable income means the gross income
derived any
organization from any unrelated trade business (as defined section 513) regularly carried it, less the deductions
this chapter which are directly connected with the carrying such trade business, both computed
allowed
with the modifications
provided subsection (b).
Section 512(b)(3) the Code states that any rents from real property (and incidental related personal property) are not tre ated
unrelated business income unless the real property debt -financed under section 514.
Section 513(a)(2) the Code states, pertinent part, that the term unrelated trade business means, the case
organization subject the tax imposed section 511, any trade business the conduct which not substantially related the
exercise performance such organization its charitable, educational, other purpose function constituting the sis for its
exemption under section 501, except that such term does not clude any trade business which carried the organization
primarily for the convenience its members, students, patients, officers, employees.
Section 513(c) the Code states that the term unrelated trade business includes any activi that carried for the production income from the sale goods the performance services. For purposes the preceding sentence, activity does not
lose
identity trade business merely because carried within larger aggr egate similar activities within larger complex other endeavors, which may, may not related the exempt purposes the organization.
JW1559-007120
Section 514(a)(1) the Code states that there shall included with respect each debt -financed operty item gross income
taxable
derived from unrelated trade business amount which the same percentage the total gross income derived during the
year from account such property (A) the average acquisition indebtedness for the taxable year with respect the property (B) the average amount the adjusted basis such property during the period held the organization during uch taxable
year.
Section 514(b)(1)(A)(i) the Code states that the term debt -financed property means any property which held produce income
and with respect which there acquisition indebtedness (as defined subsection (c)) any time during the taxable
year except
that such term does not include any property substan tially all the use which substantially related (aside from the need the
purpose
organization for income funds) the exercise performance such organization its charitable, educational other
function constituting the basis for exemption under section 501.
Section 514(c)(1) the Code states that the term acquisition indebtedness means, with respect any debt -financed property, the
unpaid amount the indebtedness incurred the organization acquiring improving property, the indebtedness incurred
before the acquisition improvement such property such indebtedness would not have been incurred but for such acquisi tion
improvement, and the indebtedness incurred after the acquisition improvement uch property such indebtedness would not
have been incurred but for such acquisition improvement and the incurrence such indebtedness was reasonably foreseeable the
time such acquisition improvement.
Section 1.501(c)(3) -1(d)(2) the easury Regulations (regulations) states that the term charitable used section 501(c)(3) its
generally accepted legal sense and is, therefore not construed limited the separate enumeration section 501(c) (3) other
tax-exempt purp oses which may fall within the broad outlines charity developed judicial decisions. Such term includes,
part, relief the poor and distressed the underprivileged, advancement religion, advancement education scien
ce, and the
promotion social welfare organizations designed accomplish any the above purposes, lessen neighborhood tensi ons, combat community deterioration and juvenile delinquency.
Section 1.513 -1(d)(1) the regulations states that gross income derives from unrelated trade business, within the meaning
section 513(a), the conduct the trade business which produces the income not substantially related (other than rough the
production funds) the purposes for which exempti granted. The presence this requirement necessitates examination
the relationship between the business activities which generate the particular income question the activities, that is, producing distributing the goods performin the services involved and the accomplishment the organizations exempt purposes.
Section 1.513 -1(d)(2) the regulations provides that trade business related exempt purposes, the relevant sense, only
where the conduct the busines activities has causal relationship the achievement exempt purposes (other than through the
production income); and substantially related, for purposes section 513, only the causal relationship ubstantial one.
Thus, for the conduct trade business from which particular amount gross income derived substantially related
which the
purposes for which exemption granted, the production distribution the goods the performance the services from
gross income derived must contribute importantly the accomplishment those purposes. Whether activities productive oss
income contribute importantly the accomplishment any purpose for which organization granted exemption depends
each
case upon the facts and circumstances involved.
Section 1.513 -1(d)(3) the regulations states that, determining whether activities contribute importantly the accomplishment exempt purpose, the size and extent the activities involved considered relation the nature and extent the exempt
function which they purport serve. Thus, where income realized exempt organization from activities which are art
related the performance its exempt functions, but whi are conducted larger scale than reasonably necessary for
performance such functions, the gross income attributable that portion the activities excess the needs exem functions
constitutes gross income from the conduct unrel ated trade business. Such income not derived from the production
distribution goods the performance services, which contribute importantly the accomplishment any exempt purpos
the organization.
Section 1.513 -1(d)(4)(i) the egulations states that gross income derived from charges for the performance exempt functions does
not constitute gross income from the conduct unrelated trade business.
Section 1.513 -1(d)(4)(i), Example (1) the regulations described organi zation that operated school train children the
performing arts. The organization derived gross income from admission charges for the performances. The students participati
performances before audiences was important part their training. Since the income realized from the performances derived from
activities, which contributed importantly the accomplishment the organizations purposes, did not constitute gross ncome from
unrelated trade business.
Section 1.513 -1(d)(4)(iii) the regulations states that facility necessary the conduct exempt functions may also employed commercial endeavor. such cases, the mere fact the use the asset facility exempt functions does not; itse make the
JW1559-007121
income from the commercial endeavor gross income from unrelated trade business. The test, instead, whether the activities
productive the income question contribute importantly the accomplishment exempt purposes.
Section 1.514(b) -1(b)(1)(i) the regulations states that the extent that the use any property substantially related (aside from
the need the organization for income funds the use makes the profits derived) the exercise the performan
organization charitable, educational other purpose function constituting its basis for exemption under section 501, such
property shall not treated debt -financed property. See section 1.513 for principles applicable determining whether there substantial relationship the exempt purpose the organization.
Section 1.514(b) -1(b)(1)(ii) the regulations states that substantially all any property used manner described
subdivision (i) this subparagraph, such property shall not treated debt -financed property. general, the preceding sentence
which
shall apply percent more the use such property devoted the organizations exempt purpose. The extent
property used for exempt purpose shall determined the basis all the facts and circumstances. These may include (where
appropriate) -a. comparison the portion time such property used for exempt purposes with the total time such property used, comparison the por tion such property that used for exempt purposes with the portion the property that used for all
purposes, Both the comparisons described (a) and (b) this subdivision.
Rev. Rul. -310, 1959 C.B. 146, holds that nonprofit corp oration organized for the purpose establishing, maintaining and
operating public swimming pool, playground and other recreational facilities for the children and other residents comm unity
exempt from federal income tax under section 501(c)(3) the Code. The organization question operated community consisting
principally low -income groups who are unable pay the cost privately sponsored recreation facilities. The income derived from
charges for admission the pool was minor amount.
Rev. Rul. -105, 1973 C.B. 264, held that the sales particular line merchandise should considered separately determine
their relatedness the exempt purpose. The ruling first held that the sale museum folk art repro ductions works from the
museums own collection and reproductions artistic works from the collections other art museums, well metal, wood and
ceramic copies American folk art objects from its own collection and similar copies art obje cts from other collections art
works not constitute unrelated trade business. The sale these items contributed importantly the achievement folk art
museums exempt educational purposes making works art familiar broader segm ent the public, thereby enhancing the
publics understanding and appreciation art. contrast, the ruling then held that sales scientific books and souvenir
items relating the city where the museum located, constitute unrelated trade business.
Rev. Rul. -360, 1979 C.B. 236, held that the operation health club exempt organization constituted unrelated trade
business within the meaning section 513 the Code. found that the operation the health club was parate from and
addition the organizations general physical fitness program, and, also, that the commercially comparable annual dues ees
charged for the health club memberships and for use the health club facilities were sufficiently high
restrict use health club
facilities limited number members the community. Isabel Peters Commissioner, (1953) T.C. 55, the Tax Court held that providing convenient swimming and recreation facilities
for all persons residing the rticular school district and especially those who could not afford acquire and maintain such
facilities was charitable defined under section 501(c)(3) since promoted the social welfare the community.
ANALYSIS
You requested rulings with rega whether activities associated with the community centers that you plan acquire with
construction bond proceeds will produce unrelated business taxable income (UBIT) defined section 512(a) the Internal
Revenue Code (Code). Generally, incom produced debt -financed property treated UBIT unless substantially all its use
substantially related exempt purposes. The information that you provided, including the careful placement and promotion
your
new facilities, types facil ities, services and programs offered, and the manner which you plan operate, clearly show that your
community centers would further your exempt purposes and benefit significant segment the communities. Since substantiall all the use your property substantially related your exempt purposes, your community centers will not treated debt financed property within the meaning section 514(a)(1). Further, except for the retail sales merchandise, the activiti described
herein would also not produce UBIT.
You state that you are exempt from federal tax because you further religious purpose. Section 1.501(c)(3) -1(d)(2) the regulations
states that the term charitable used section 501(c)(3) the Code its generally accepted legal sense. therefore not
construed limited the separate enumeration section 501(c)(3) other tax -exempt purposes, which may fall within the broad
outlines charity developed judicial decisions. the general charity, the promotion the happiness and enjoyment
JW1559-007122
the members the community also charitable purpose:
Some these trusts can supported the ground that they tend promote the health the community, involve form
education; but sufficient that they promote the general happiness the community.
Restatement (Second) Trusts, section 374 (1959); Scott, The Law Trusts section 374.10 (3d ed. 1967).
The principles set forth section 1.513 the regulations apply determining whether the operation your community centers
has substantial relationship your exempt purpose. See section 1.514(b) -1(b)(i) the regulations. the statutory sense, the
relationship must causal and substan tial one. other words, substantially related exempt purpose, the activities
conducted your community centers must contribute importantly the achievement your exempt purposes. Section 1.513 -1(d)(2) the regulations. placing your new centers communities where more households operate below the poverty level and have
You
children under the age 18, you would provide relief the poor the underprivileged and combat community deterioration.
have taken steps make sure that all income levels within the community would aware and make use the programs you
would offer. You would make centers even more accessible linking the programs the existing social -service programs that you
have already established communities. Many the programs that you plan offer, including the faith and family, learning and
sponsored
technology, and visual/theater art well disaster relief and library services and renting space for community gatherings community ganizations, would contribute importantly the accomplishment your educational, religious, and other charitable
purposes.
The term unrelated trade business essentially means any trade business that not substantially related (aside from
the need
the organization for income funds) organizations exempt purpose. Generally, income from the performance exempt
functions does not constitute gross income from the conduct unrelated trade business. See section 1.513 -1(d)(4)(i), Example the regulations. facility that necessary the conduct exempt functions may employed commercial endeav the
activities that produce the income question contribute importantly the accomplishment exempt purposes.
See section 1.513
1(d)(4)(iii) the regulations. For example, you would devote percent your facilities religious and educational pro grams and percent special programs, both which contribute importantly the accomplishment your exe mpt