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Rules Governing Practice before IRS

Exempt Organizations Public Disclosure - Disclosure of Final Letters Denying or Revoking Exempt Status

What public disclosure requirements apply to final letters from the IRS that deny or revoke an organization's tax-exempt status?

Sometimes, an organization's application for recognition of tax-exempt status is denied, or its exempt status is revoked after an examination.  Internal Revenue Code section 6110 requires the IRS to publish final letters that revoke or deny an organization's exempt status, but with taxpayer identifying information deleted.  Upon written request, the IRS will also provide a copy of the background file with taxpayer identifying information deleted.  The background file includes a copy of the ruling request or application for exempt status and all supporting documents.

The regulations ask taxpayers to help the IRS comply with these requirements by submitting a statement of proposed deletions with the ruling request or application.  Organizations should submit the following with their request or application:

  1. A statement indicating that no deletions need be made except names, addresses, and taxpayer identifying numbers, or
  2. A statement of proposed deletions, citing the statutory basis for each one, and a copy of the ruling request or application (and supporting documents, submitted with or subsequent to the application) on which it indicates, in brackets, each deletion requested.