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Dear Applicant :
This modifies our letter of the
above date in which we stated that you would be treated as an
organization that is not a private foundation until the
expiration of your advance ruling period.
Your exempt status under section
501(a) of the Internal Revenue Code as an organization
described in section 501(c)(3) is still in effect. Based
on the information you submitted, we have determined that you
are not a private foundation within the meaning of section
509(a) of the Code because you are an organization of the type
described in section 509(a)(1) and 170(b)(1)(A)(vi).
Grantors and contributors may rely
on this determination unless the Internal Revenue Service
publishes notice to the contrary. However, if you lose
your section 509(a)(1) status, a grantor or contributor may
not rely on this determination if he or she was in part
responsible for, or was aware of, the act or failure to act,
or the substantial or material change on the part of the
organization that resulted in your loss of such status, or if
he or she acquired knowledge that the Internal Revenue Service
had given notice that you would no longer be classified as a
section 509(a)(1) organization.
As of January 1, 1984, you are
liable for taxes under the Federal Insurance Contributions Act
(social security taxes) on remuneration of $100 or more you
pay to each of your employees during a calendar year.
You are not liable for the tax imposed under the Federal
Unemployment Tax Act (FUTA).
You are required to file Form 990
only if your gross receipts each year are normally more that
$25,000. For guidance in determining whether your gross
receipts are "normally" more than $25,000, see the
instructions for Form 990. If a return is required, it
must be filed by the 15th day of th fifth month after the end
of your annual accounting period. A penalty of $10 a day
is charged when a return is filed late, unless there is
reasonable cause for the delay. However, the maximum
penalty charged cannot exceed $5,000 or 5 percent of your
gross receipts for the year, whichever is less. This
penalty may also be charged if a return is not complete, so
please be sure your return is complete before you file it.
If we have indicated in the heading
of this letter that an addendum applies, the addendum enclosed
is an integral part of this letter.
Letter 1050 (DO/CG)
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