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Private Foundation Exemption Application: Declaratory Judgments - Notice of final determination

A notice of final determination to which the declaratory judgment procedures apply is a ruling or determination letter sent by certified or registered mail that holds the organization is:

  • Not exempt as an organization described in section 501(c)(3) of the Internal Revenue Code;
  • Not eligible to receive deductible charitable contributions under section 170(c)(2),
  • A private foundation as defined in section 509(a),
  • Not a private operating foundation as defined in section 4942(j)(3),
  • With respect to the initial or continuing classification of a cooperative as an organization described in section 521(b) which is exempt from tax under section 521(a), or
  • Is a public charity described in a part of section 509 or section 170(b)(1)(A) other than the part under which the organization requested classification.


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Page Last Reviewed or Updated: 24-Apr-2014