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.