Complete IRS Production 18

Obtained by Judicial Watch, Inc.
via FOIA
From:
Lerner Lois G
Sent:
Wednesday, September 15, 2010 11:26 AM
To:
Kall Jason C
Cc:
Downing Nanette M; Choi Robert S
Subject:
FW: EO Tax Journal 2010-130
Flag Status:
Flagged
More fuel for the potential c4 project fire
Lois G. Lerner
Director, Exempt Organizations
From: paul streckfus [mailto:pstreckfus@gmail.com]
Sent: Wednesday, September 15, 2010 12:20 PM
To: paul streckfus
Subject: EO Tax Journal 2010 -130
From the Desk of Paul Streckfus,
Editor, EO Tax Journal
Email Update 2010-130 (Wednesday, September 15, 2010)
Copyright 2010 Paul Streckfus
Yesterday, I asked, Is 501(c)(4) Status Being Abused? I can hardly keep up with the questions and comments this query has
generated. As noted yesterday, some (c)(4)s are being set up to engage in political activity, and donors like them because they remain
anonymous. Some commenters are saying, Why should we care?, others say these organizations come and go with such rapidity t hat
the IRS would be wasting its time to track the m down, others say (c)(3) filing requirements should be imposed on (c)(4)s, and so it
goes.
Former IRSer Conrad Rosenberg seems to be taking a leave them alone view:
I have come, sadly, to the conclusion that attempts at revocation of these blatantl y political organizations accomplish little, if
anything, other than perhaps a bit of i n terrorem effect on some other (usually much smaller) organizations that may be contemplating
similar behavior. The big ones are like balloons -- squeeze them in one pl ace, and they just pop out somewhere else, largely unscathed
and undaunted. The government expends enormous effort to win one of these cases (on very rare occasion), with little real -world
consequence. The skein of interlocking educational organizations woven by the fabulously rich and hugely influential Koch brothers
to foster their own financial interests by political means ought to be Exhibit One. Their creations operate with complete imp unity, and
I doubt that potential revocation of tax exemption ent ers into their calculations at all. That's particularly true where deductibility of
contributions, as with (c)(4)s, is not an issue. Bust one, if you dare, and they'll just finance another with a different nam
e. I feel for the
IRS's dilemma, especially in this wildly polarized election year.
A number of individuals said the requirements for (c)(4)s to file the Form 1024 or the Form 990 are a bit of a muddle. My
understanding is that (c)(4)s need not file a Form 1024, but generally the IRS won't accept a F orm 990 without a Form 1024 being
filed. The result is that attorneys can create new (c)(4)s every year to exist for a short time and never file a 1024 or 990. However, the
IRS can claim the organization is subject to tax (assuming it becomes aware of its existence) and then the organization must prove it is
exempt (by essentially filing the information required by Form 1024 and maybe 990). Not being sure of the correctness of my
JW1559-019009
Obtained by Judicial Watch, Inc. via FOIA
understanding, I went to the only person who may know more about EO tax law th an Bruce Hopkins, and got this response from Marc
Owens:
You are sort of close. It's not quite accurate to state that a (c)(4) need not file a Form 1024. A (c)(4) is not subject t o IRC 508,
hence it is not required to file an application for tax -exempt status within a particular period of time after its formation. Such an
organization is subject, however, to Treas. Reg. Section 1.501(a) -1(a)(2) and (3) which set forth the general requirement that in order
to be exempt, an organization must file an a pplication, but for which no particular time period is specified. Once a would -be (c)(4) is
formed and it has completed one fiscal year of life, and assuming that it had revenue during the fiscal year, it is required
to file a tax
return.
There is no exemption from the return filing requirement for would -be (c)(4)s and failing to file anything is flirting with serious
issues. Obviously, few, if any, organizations elect to file a Form 1120 and so file a Form 990 as an alternative and because
it comports
with the intended tax -exempt status. When such a Form 990 arrives in Ogden, it goes unpostable, i.e., there is no pre -existing master
file account to which to post receipt of the return.
Master file accounts for tax exempts are created by Cin cinnati when an application is filed, hence no prior application, no master
ocessing
file account and no place for Ogden to record receipt of the subsequent 990. Such unpostable returns are kicked out of the pr
system and sent to a resolution unit that anal yzes the problem (there are many reasons a return might be unpostable, such as a typo in
an EIN). The processing unit might create a dummy master file account to which to post the return, it might correspond with
the
filing organization to ascertain the correct return to be filed, or it might refer the matter to TE/GE where it would be assigned to an
agent to analyze, essentially instigating the process you describe.
My query today: So where are we? Should the IRS ignore the whole mess? Or should the IR S be concerned with the integrity of the
tax exemption system?
I think the IRS needs to keep track of new (c)(4)s as they appear. Im assuming most political ads identify who is bringing t
hem to
you. Thats true of the ones Ive seen. When the IRS can not identify on its master file a new organization engaged in politicking, it
should send a letter of inquiry, saying Who are you? What is your claimed tax status? In other words, what Im saying is th at the
IRS needs to be more pro -active, and not await th e filing of a Form 1024 or 990. I recognize that most of these (c)(4)s may have little
income if they spend what they take in, but the EO function has never been about generating revenue. If (c)(4) status is bein g abused,
the IRS needs to take action. If t he IRS does not have the tools to get at the problems, then we need for Congress to step in and
strengthen the filing requirements.
My biggest concern is that these political (c)(4)s are operating in tandem with (c)(3)s so that donors can claim 170 deduc tions. Here
the IRS needs to have an aggressive audit program in coordination with the Income Tax Division so that 170 deductions are
disallowed if a (c)(3) is being used as a conduit to a (c)(4).
Ive probably raised new issues, and Ive said nothing ab out section 527. Anyone who wants to fill in some of the blanks, please do
so.
______________________________________
JW1559-019010
From:
Spellmann Don R
Sent:
Friday, February 24, 2012 11:06 AM
To:
Cook Janine
Subject:
Draft of Advocacy Org Guide Sheet
Attachments:
Advocacy Org Guidesheet 11-3-2011.doc
Janine,
Just FYI, I advised Lois not to distribute this today, and she is perfectly fine with that.
David and I gave it a quick read. It's
nowhere near ready for prime time. It's a good start, but needs corrections, additions, changes all over.
particular needs fixing. The development questions are good, but not complete.
We'll get a working group together with EO to work on this.
The law in
Please let me know if you have questions/concerns,etc.
Don
From: Paz Holly O [mailto:Holly.O.Paz@irs.gov ]
Sent: Friday, February 24, 2012 11:09 AM
To: Spellmann Don R
Cc: Lerner Lois G; Kindell Judith E
Subject: FW: Draft of Advocacy Org Guide Sheet
Don,
Here is the document for review.
Thanks,
Holly
From: Goehausen Hilary
Sent: Monday, November 21, 2011 9:45 AM
To: Ardoin Elizabeth A; Elliot -Moore Donna
Cc: Seto Michael C
Subject: Draft of Advocacy Org Guide Sheet
Hi Liz and Donna,
Attached please find a draft c opy of the guidesheet we have been putting together on advocacy organizations. I hope you
find it helpful for your cases.
Thanks,
Hilary
Hilary Goehausen
Tax Law Specialist
Exempt Organizations
Technical Group 1
1111 Constitution Ave., NW
Washington, D.C. 20224
p: 202.283.8915
JW1559-019011
f: 202.283.8937
Hilary.Goehausen@irs.gov
JW1559-019012
(b)(5)/db
JW1559-019013
(b)(5)/db
JW1559-019014
(b)(5)/db
JW1559-019015
(b)(5)/db
JW1559-019016
(b)(5)/db
JW1559-019017
(b)(5)/db
JW1559-019018
(b)(5)/db
JW1559-019019
(b)(5)/db
JW1559-019020
(b)(5)/db
JW1559-019021
(b)(5)/db
JW1559-019022
(b)(5)/db
JW1559-019023
(b)(5)/db
JW1559-019024
From:
Spellmann Don R
Sent:
Wednesday, February 29, 2012 2:01 PM
To:
Cook Janine
Subject:
Age of Draft Advocacy Org Guide Sheet
Attachments:
Hi Janine,
We just wanted you to be aware, in the context of improving communication and collaboration with the
client, how long this draft has been sitting around (note doc date and message below). It already has been used
internally at R&A in DC. I can't remember if Lois told me they already had shared it with Cincinnati or were
just anxious to share it.
Susan, David M and I had a good planning meeting this morning.
We've got a plan for working through
corrections and changes and some good ide as for making it more useful (while sticking as close to their original
format as possible). I'll check in with Holly & Judy in the next day just so they know we're diligently working
through it. Our goal is to send it to them end of next week; earlier s eems nye impossible.
Questions or concerns, please let us know.
Don
To: Spellmann Don R
Don,
Thanks,
Holly
Cc: Seto Michael C
Hi Liz and Donna,
Attached please find a draft copy of the guidesheet we have been putting together on advocacy organizations. I hope you
JW1559-019025
Thanks,
Hilary
Hilary Goehausen
Tax Law Specialist
Technical Group 1
p: 202.283.8915
f: 202.283.8937
JW1559-019026
(b)(5)/db
JW1559-019027
(b)(5)/db
JW1559-019028
(b)(5)/db
JW1559-019029
(b)(5)/db
JW1559-019030
(b)(5)/db
JW1559-019031
(b)(5)/db
JW1559-019032
(b)(5)/db
JW1559-019033
(b)(5)/db
JW1559-019034
(b)(5)/db
JW1559-019035
(b)(5)/db
JW1559-019036
(b)(5)/db
JW1559-019037
(b)(5)/db
JW1559-019038
From:
Thomas Cindy M
Sent:
Thursday, February 23, 2012 2:47 PM
To:
Haley Philip H; Shankling Lonnie; Jefferson-White Beverly J; Lahey Victoria; Lewis
Jovonnie; Brinkley Lynn A; Waddell Jon M; Bowling Steven F; Shafer John H; Bibb
Kenneth B; Angner William J; Berry Daniel W; Esrig Bonnie A; Combs Peggy L
Subject:
Significant Case Report for January 2012
Attachments:
SCR Report Table Jan 2012.doc
Importance:
Low
If you are interested, attached is a summary of the status of significant cases in EO R&A (e.g., foreclosure assistance,
newspaper applications, medical marijuana,
(b)(3); 6103
political advocacy).
From: Seto Michael C
Sent: Wednesday, February 22, 2012 10:33 AM
To: Lerner Lois G; Kindell Judith E; Light Sharon P
Cc: Paz Holly O; Fish David L; Trilli Darla J; Neuhart Paige; Marx Dawn R; Abner Donna J; Thomas Cindy
Subject: Significant Case Report for January 2012
Highlights:
A. Closures
We have no closures for January.
B. Specific Cases
(b)(3); 6103
Exemption application /
(item 6) - We issued the applicant an initial denial of exemption
on 12/15/11. W e will close the case shortly because the applicant has not filed a protest. The closing letter is in
review.
Exemption applications / pooled trust cases (item 8) - We have four pending applications, and each is in different
stages of development. Once development of the cases is done, the initial denials will be drafted.
Before issuing
them to the taxpayers, we will get input from Counsel.
PLR
(b)(3); 6103
. -(item 17) - We have informed the taxpayer that we are proposing t o issue an
adverse PLR. An adverse conference with the taxpayer has been scheduled.
JW1559-019039
EO Technical
Significant Case Report
( January 31, 2012)
21 open SCs
A. Open SCs:
Name of
Org/Group
Group
#/Manager
1.
EIN
(2)
Political Advocacy
Organizations
(1)
(closed)
T1 Steve
Grodnitzky
and
(3)
Received
4/2/2010
Issue
Tax Law
Estimated
Specialist Completion
Date
Whether an organization meets the

Hilary
requirements under section

Goehausen
501(c)(3) and is not involved in
political intervention. Whether
organization is conducting excessive
political activity to deny exemption
under section 501(c)(4)
(2)
(open)
03/31/2011
(Orig)
05/31/2011
(Rev)
07/31/2011
(Rev)
10/30/2011
(Rev)
(Rev)
02/29/2012
(Rev)
05/31/2012
(Rev)
(3)
(open)
Status/Next action
Being Elevated
to TEGE
Commissioner
This Month
No
Developing both a (c)(3) and (c) (4)
cases. Cases were discussed with
Met with
Judy Kindell on 04/06/11.

Director EO on June 29, 2011. Met
with Counsel on 8/10/11 to discuss the
cases; Counsel recommended fu rther
development of the cases by getting
information on the organizations 2010
activities. Counsel gave us directions
on the type of information needed.

Next Action: Organization (1) closed
FTE for failure to respond to
development letter. Organization (2)
received taxpayer response to third

development letter , tls reviewing.
Organization (3) to be closed FTE.
2.
(b)(3)/6103; non-responsive
JW1559-019040
3.
P2 Andy
Megosh
6/08
Whether HMO qualifies under
501(c)(4) of the Code.
Justin Lowe
(Rev)
06/30/2011
(Orig)
08/30/2011
(Rev)
09/30/2011
(Rev)
(Rev)
02/29/2012
(Rev)
LBI and EO agreed to the following

Yes
terms for the agreement:
1. $16.1 million in refund
claims for tax years 2003,
2005, 2006, and 2007;

2. Forgo 2008 tax year refund
claim;
3. Revocation starting in the
2009 calendar year;

4. Forgo one-half of the interest
due on the refunds.

Organization agreed to terms. The
settlement agreement would need

JCTs approval. Received initial
comments from Counsel and are
evaluating them. Director, EO was
briefed on the draft closing
documents on 07/13/11. LB&I
approved the draft documents . POA
approved. Await JCT approval, then
closing agreement
signatures. JCT reviewer has
questions.
Next Action:
Met with JCT on
11/14/11 and awaiting JCT
approval.
4.
P2/ Andy
Megosh
Cincinnati
9/22/06
EOT
11/9/06
Whether HMO qualifies under
501(c)(4) of the Code.
Justin Lowe
06/30/2011
(Orig)
10/31/2011
(Rev)
Yes
TEGE Commissioner and TEGE
Counsel met on August 24, 2010 to
discuss options on this case . Counsel
has indicated that there are litigation
hazards based on prior GCM that
favorably cited the legislative history.
We have received congressional
inquiries on this issue.
JW1559-019041
Next Action: Still awaiting executive
resolution.
5.
6.
JW1559-019042
4
7.
8.
JW1559-019043
9.
10.
JW1559-019044
11.
12.
JW1559-019045
13.
14.
JW1559-019046
8
15.
16.
JW1559-019047
17.
18.
JW1559-019048
10
19.
20.
21.
JW1559-019049
11
B. Closed SCs-
None.
JW1559-019050
From:
Paz Holly O
Sent:
Wednesday, October 12, 2011 5:11 AM
To:
Fish David L; Neuhart Paige; Thomas Cindy M
Subject:
FW: Determ follow-up
Attachments:
EO Determinations August 2011.doc
FYI. I have not yet had the chance to compare what Imraan sent to what we gave him but wanted to pass this along.
From: Khakoo Imraan G
Sent: Monday, October 03, 2011 2:05 PM
To: Paz Holly O
Cc: Lerner Lois G; Letourneau Diane L; Lehman Sue
Subject: FW: Determ follow-up
Attached is our response to Jeff on his questions from the B PR. Please let me know if you have any questions.
you.
Thank
Imraan G. Khakoo
Strategy & Program Planning
TE/GE
202.283.9907
Sent: Tuesday, September 27, 2011 6:39 PM
To: Wallbaum Jeffrey S
Cc: Grant Joseph H; Medina Moises C; Laarz Linda N
Subject: RE: Determ follow -up
Jeff,
Attached is the follow-up information for EP & EO Determinations. Let me know if you have any questions. Thanks for
your patience.
Imraan G. Khakoo
Strategy & Program Planning
TE/GE
202.283.9907
Sent: Wednesday, August 17, 2011 1:04p
To: Wallbaum Jeffrey S
Subject: Re: Determ follow -up
I've asked for a pipeline analysis for ech program as part of the workplan docs. I'm not sure we can compare it to the
beginning of the year but we'll see what we can do.
Also, I don't know if they can substantiate how much time they've spent on these cases but perhaps w e can use webets.
Do you have a deadline?
-------------------------Sent using BlackBerry
JW1559-019051
From: Wallbaum Jeffrey S
Sent: Wednesday, August 17, 2011 12:45 PM
To: Khakoo Imraan G
Subject: Determ follow-up
Good morning. As you'd expect, we need a 'crisper' (Steve's repeated phrasing) explanation of what's going on in
determinations. Steve mentioned EO in the room, but I think we could use a better understanding of both.
For EP, I'd be interested in a better understanding of what's in inventor y (Cycle, special categories like gov plans or 5307),
and also a distribution of age in inventory (not just the avg but # in different age categories).
Probably compare beginning
of year to today. I'd also like a more direct explanation of why closures p er staffyear and hpc are moving in opposite
directions...presumably there's a bunch of time on open cases, but can they back that up?
I'd also like to see a timeline
for implementing the various EPDLS changes that are under discussion.
For EO, why are closures down 10% when staffyears are only down 2%?
open cases, and can they show that?
Like EP, is there a bunch of time applied to
Also, same questions on inventory, what's in it and what's the distribution by
age? It seems surprising that average age hasn't really increased since the beginning of the year despite fewer receipts
to pull the average down and little indication that the older cases they're working have actually closed (hpc and CT don't
indicate a lot of old, time -intensive closures).
Let me know if you think these are the right questions, or if you'd add anything.
What we really need is some kind of
succinct explanation of what's happened so far this year, and where both programs are headed.
Thanks,
Jeffrey S Wallb aum
Program Advisor, DCSE
202/927.0242
JW1559-019052
8/16/2013
TE/GE Strategy & Program Planning
EO Determinations
August 2011
The decrease in EO Determinations' closures and productivity is the result of interconnected
factors, rather than a single factor such as a decrease in direct staff years including:
TEDS shutdowns or slowdowns,
Increase in hours per case, and
Delays caused by the need for guidance on novel and complex issues from EO Technical
and/or Counsel.
TEDS. TEDS impacts closures due to the numerous shutdowns and slowdowns associated with
the system. There were 15 weekdays where th e system was down full -time to users which
resulted in close to 3,700 closures lost. 1 We had not taken these lost closures in our planning
process. In addition, there are other instances where reboots were needed or slowdowns in
performance were noted. For example, a sample of TOPS messages reflect s the following in the
last three months:

Tuesday, 6/28, TEDS had to be rebooted and was down from approx. 10:36 a.m. -12:48
p.m.
Thursday, 6/30, performance issues were reported and a priority ticket was entere d at
approx. 11:13 a.m. and service was restored at approx. 1:01 p.m.
Tuesday, 7/5, performance issues were reported and a priority ticket entered at approx.
12:49 p.m. and service was restored at approx. 3:48 p.m.

Thursday, 7/7, a priority ticket was ente red at approx. 2:42 p.m. and service was restored
at approx. 5:03 p.m.

Wednesday, 8/3, a priority ticket was entered at approx. 10:42 a.m. and service was
restored the next day at approx. 8:06 a.m.
Although each of these events alone is minor, the totali ty of these events impacts closures
because staff is unable to work cases during these periods.

Hours per Case. As the table on page 4 shows, average hours for cases closed as Merit 9 (merit
with taxpayer contact) and Non -merit have both increased from a year ago. In particular, for
Merit 9 closures, hours per case have increased by 0.2 hours for both grade -11 and grade-12
cases. For Non-merit closures, hours per case have increase for grade -11 case by 0.4 hours and
for grade 13 cases by 1.7 hours. Overall, while hours per case for grade -11 and grade-12 cases
have remained level, a verage hours applied to grade-13 cases has increased from 7.0 hours to 8.8
hours, a 24% increase.
Total closures for August FY 2011 are below the August FY 2010 level by o ver 6,900 cases.
This is largely due to a significant decrease in productivity for Non -merit cases; in particular,
closures for grade-11 non-merit cases have decreased by approximately 4,500 cases . Through
August 2011, there are over 22 staff years, over 45,500 hours, accrued on open full -development
This figure was derived using the closures through August divided by the number of working days in the year
where TEDS was operating, 211 days (226 working days through August 15 days lost due to teds), to attain a
closures per day figure for the fiscal year.
JW1559-019053
8/16/2013
cases. Using the average hours for Non -merit cases through August, 6.0 hpc, this time applied
would equate to approximately 7,600 cases.

Cases Awaiting Guidance . In order to free up Technical staff to work aging Private Letter
Rulings and Technical Advice Memorandums, EO has made an effort in recent fiscal years to
enable EO Determinations to work more complex cases rather than transfer these cases to EO
Technical. To do this, EO Technical and Counsel ha ve worked to provide EO Determinations
with tools to help them understand how to work such cases (e.g., training, template development
letters, and template denials). However, even these tools cannot answer all of the questions that
may arise in processing these complex cases and formal guidance (such as Program Manager
Technical Advice from Counsel) is needed in some areas. Such guidance takes time to develop
and thus impacts closures. For example, EO Determinations currently has 155 applications from
advocacy organizations that it cannot close without guidance from EO Technical.

Open Inventory (see charts on page 4) . While open inventory has increased by over 5,000 cases
since the beginning of the fiscal year, the percentage of cases over 120 days old through August
2011 has increased slightly by one percentage point. 2 The average age of inventory, at 112 days,
has improved by 14 days from the FY 2010 level but continues to be skewed by the relatively
small number of cases that are extremely aged . For example, one percent of the total cases are
over two years old with the oldest case being 4,274 days old.
Other Analyses. We also think it is important to look at the productivity of experienced and
inexperienced staff to see what impact that is havi ng on closures and productivity . EO is
working to prepare such an analysis but it requires pulling data on an employee -by-employee
basis and is thus a time -intensive effort.
In addition, although we try to anticipate the number and type of receipts in EO Determinations,
because these factors are controlled by the applicants, we can never truly match our expectations
regarding receipt numbers and case complexity with reality. EO currently has more grade 12 and
13 cases in inventory than it has grade 12 and 13 specialists. As a result , the average number of
days a case awaits assignment is 50 days for a grade 11 case but is 71 days for a grade 13 case.
Moreover, because the higher graded cases are more complex, they take longer to work once
assigned.
Steps to Address the Decrease in Closures . EO is taking a numbe r of short- and long-term
measures to address the decrease in closures in Determinations. Specifically:

Cases are being worked by a group in DC in an effort to meet the closure projections f or
this fiscal year (even this effort was somewhat delayed by TEDS issues as the DC
specialists had difficulty getting access to the system to view the cases designated to be
worked in DC),
In light of the grade mismatch issue, EO is in the process of rev iewing the case
assignment guide matrix used to set case grades to determine if cases are being graded
appropriately. EO Determinations was also granted the ability to make internal
promotions to grades 12 and 13.

2
Using the demarcation of over 120 days is the closest to EO Determinations cycle time through August of 105
days.
JW1559-019054
8/16/2013
EO is reviewing the criteria for transf erring cases to EO Technical to determine whether
it is more efficient to work certain cases in DC or to work them in Determinations with
EO Technical/Counsel assistance.
EO is looking at better ways for managers to oversee employees' caseloads and
encourage movement; as part of this effort, EO Determinations will draw on EO Exam's
recent experience working with this issue .
JW1559-019055
Closure
Type
Merit6
Merit9
August FY 2010 & August FY 2011

August FY
August FY
Closure
Case
Statistics
% Change
2010
Type
Grade
2011
Cases
.0
.0
#DIV/0! NonMerit
9
Percent of Total
.0%
.0%
#DIV/0!
Average Hours
0.0
0.0
#DIV/0!
17,695
16,426
-7.2%
11
Cases
Percent of Total
30.3%
31.9%
5.3%
Average Hours
0.5
0.5
6.4%
2,092
1,814
-13.3%
12
Cases
Percent of Total
3.6%
3.5%
-1.7%
Average Hours
0.6
0.6
5.0%
13
Cases
102
59
-42.2%
Percent of Total
.2%
.1%
-34.4%
0.7
0.9
25.3%
Average Hours
Cases
19,889
18,299
-8.0%
Total
Percent of Total
34.0%
35.5%
4.3%
0.5
0.5
6.1%
Average Hours
Cases
9
3.0
.0
-100.0% Total
.0%
.0%
-100.0%
Percent of Total
Average Hours
5.7
0.0
-100.0%
11
Cases
9,130
8,766
-4.0%
15.6%
17.0%
8.9%
Percent of Total
Average Hours
2.2
2.4
8.8%
Cases
2,919
3,056
4.7%
12
Percent of Total
5.0%
5.9%
18.7%
Average Hours
3.0
3.2
5.5%
13
26
25
-3.8%
Cases
Percent of Total
.0%
.0%
9.0%
Average Hours
3.4
2.2
-34.6%
12,078
11,847
-1.9%
Total
Cases
Percent of Total
20.7%
23.0%
11.2%
Average Hours
2.4
2.6
8.2%
8/16/2013
August FY 2010 & August FY 2011
August FY August FY
Case
Statistics
% Change
2010
Grade
2011
Cases
3
4
33.3%
Percent of Total
.0%
.0%
51.2%
Average Hours
8.6
1.0
-88.4%
11
Cases
16,874
12,391
-26.6%
Percent of Total
28.9%
24.0%
-16.7%
Average Hours
4.5
4.9
10.3%
12
Cases
7,129
6,623
-7.1%
Percent of Total
12.2%
12.8%
5.3%
Average Hours
7.0
6.9
-2.3%
13
Cases
2,488
2,391
-3.9%
Percent of Total
4.3%
4.6%
9.0%
Average Hours
7.3
9.0
22.9%
Total
Cases
26,494
21,409
-19.2%
Percent of Total
45.3%
41.5%
-8.4%
Average Hours
5.4
6.0
10.3%
9
Cases
6
4
-33.3%
Percent of Total
.0%
.0%
-24.4%
Average Hours
7.2
1.0
-86.0%
Cases
43,699
37,583
-14.0%
11
Percent of Total
74.7%
72.9%
-2.5%
Average Hours
2.4
2.4
1.1%
12
Cases
12,140
11,493
-5.3%
Percent of Total
20.8%
22.3%
7.4%
Average Hours
4.9
4.9
-1.0%
13
Cases
2,616
2,475
-5.4%
Percent of Total
4.5%
4.8%
7.3%
Average Hours
7.0
8.8
24.4%
Total
Cases
58,461
51,555
-11.8%
Percent of Total
100.0%
100.0%
0.0%
Average Hours
3.1
3.3
4.6%
JW1559-019056
8/16/2013
Percentage of Open EO Determination Cases by Form and Age
September 2010 Data (Estimated)
100%
3%
3%
3%
3%
5%
3%
11%
11%
10%
16%
17%
15%
11%
12%
11%
90%
14%
80%
% of Cases
70%
60%
15%
24%
50%
12%
14%
14%
40%
11%
30%
20%
8%
43%
40%
40%
11%
10%
13%
0%
Total (15,570)
0-60 days
Form 1023 (14,191)

61-90 days
91-120 days
121-180 days
Form 1024 (1,148)

181-270 days
271-365 days
Other Forms (231)
> 365 days
Percentage of Open EO Determination Cases by Form and Age
August 2011 Data
100%
4%
5%
4%
5%
11%
11%
6%
4%
90%
80%
% of Cases
10%
14%
15%
60%
10%
10%
50%
13%
70%
18%
6%
18%
6%
11%
15%
14%
40%
19%
30%
20%
57%
43%
9%
41%
8%
10%
13%
0%
Form 1023 (18,068)
Total (20,629)
0-60 days
61-90 days
91-120 days
121-180 days
Form 1024 (2,419)

181-270 days
271-365 days
Other Forms (142)
> 365 days
JW1559-019057
From:
Park Nalee
Sent:
Friday, October 14, 2011 7:23 AM
To:
Fish David L; McNaughton Mackenzie P
Subject:
RE: The Fun Just Keeps on Coming!
My notes doesn't say whether Lois wanted specific IRM references, but it makes sense to
(b)(5)/DP
Also, Lois wanted to mention the group ruling/exemption procedure (and the IRM excerpt Cindy
provided below touches on it).
NaLee
202.283.9453
From: Fish David L
Sent: Friday, October 14, 2011 7:47 AM
To: Park Nalee; McNaughton Mackenzie P
Subject: FW: The Fun Just Keeps on Coming!
Is this what Lois was getting at?
From: Paz Holly O
Sent: Thursday, October 13, 2011 3:40 PM
To: Fish David L
From: Thomas Cindy M
Sent: Wednesday, October 12, 2011 10:51 PM
To: Paz Holly O
Subject: RE: The Fun Just Keeps on Coming!
Holly -- the best information I have regarding the process is in the pending IRM 7.20.2, which is currently being negotiated
with National NTEU. The excerpt below was taken from the pending IRM (see attached). If you need additional
information, please let me know. Thanks.
b5/dp
JW1559-019058
b5/dp
(b)(5) DP
b5/dp
JW1559-019059
b5/dp
From: Paz Holly O
To: Thomas Cindy M
OK it sounds like all we are looking for from Determs is cites to IRMs that give a good description of our internal
processing.
From: Fish David L
To: Paz Holly O
Subject: RE: The Fun Just Keeps on Coming!
I think it was IRM's describing our internal processing. We will be getting the SOI numbers.
From: Paz Holly O
To: Fish David L
Importance: High
I was late to this meeting so not sure why Nan reached out to Cindy.
W ouldn't we use SOI data for 1d? As far as
describe the process, won't NaLee or Mackenzie be doing that?
Sent: Wednesday, October 12, 2011 8:05 AM
To: Downing Nanette M
Cc: Hubert Linda K; Paz Holly O
Importance: High
JW1559-019060
Nan,
Holly will need to get the analysts to provide numbers.
Regarding the part of the question: Describe the process by which an entity is granted tax -exempt
status.
I'm don't know what this is getting at, specifically regarding the term "process." Are we being asked
to describe the entire process a case goes through, such as applications are sent to the Cincinnati
Submission Processing Center in Covington, Kentucky, where user fee payments are processed,
cases scanned into the Tax Exempt Determination System (TEDS), etc.
OR
Applicants complete Form 1023 or Form 1024 depending on the subsection being
requested. Determination specialists review the application package and make a recommendat ion as
to whether the organization meets the requirements under the Code section requested, based on the
information submitted with the application package or after securing additional information. Managers
review the specialists' recommendations and, if they agree, approve the cases.
-----Original Message ----From: Downing Nanette M
Sent: Tuesday, October 11, 2011 2:00 PM
To: Thomas Cindy M
Cc: Hubert Linda K
Importance: High
Cindy
On a phone with a bunch of folks going over this response. We need to get with you on part of question 1 d.
Linda will be contacting
you. You may be hearing more from R&A folks on other pieces of this.
-----Original Message ----From: Lerner Lois G
Sent: Friday, October 07, 201 1 4:49 PM
To: Downing Nanette M; Paz Holly O; Fish David L; Musselman Bryan L; Light Sharon P; Kindell Judith E; Urban Joseph J;
McNaughton Mackenzie P
Cc: Grant Joseph H; Letourneau Diane L; Jackson Marshalle C; Dinkins Celestine M
Subject: The Fun Just K eeps on Coming!
Importance: High
Attached is a request from House Ways and Means.

and due October 20.
It is pretty extensive
I'd like to have a meeting on it sometime Tuesday.
Diane/Tina/Celeste --my schedule is a mess, but let's see what we can do --Bryan probably doesn't need to be at the meeting.
others--get as many as possible, but if everyone can't make it, we'll do the best we can to get started.
As to the
Thanks
Lois G. Lerner
Director of Exempt Organizations
-----Original Message ----From: Jackson Marshalle C
Sent: Friday, October 07, 2011 3:54 PM
To: Lerner Lois G; Paz Holly O
Cc: Letourneau Diane L; Jackson Marshalle C
Subject: Emailing: Ways and Means Subcommittee on Oversight 10_07_11.pdf
JW1559-019061
The message is ready to be sent with the follo wing file or link attachments:
Ways and Means Subcommittee on Oversight 10_07_11.pdf
Note: To protect against computer viruses, e -mail programs may prevent sending or receiving certain types of file attachments.
Check
your e-mail security settings to d etermine how attachments are handled.
JW1559-019062
From:
Sent:
Tuesday, October 18, 2011 10:49 PM
To:
Park Nalee; Kindell Judith E; Fish David L; Megosh Andy; Salins Mary J; Urban Joseph J;
Cc:
Clarke Stephen M; Hubert Linda K; Paz Holly O
Subject:
Updated Boustany draft
Attachments:
Boustany v3.DOC
Light Sharon P; Lerner Lois G
Hi All,
NaLee and I have scrubbed the draft again and attached is the new version (without attached Exhibits) for collective
review and comments. We're stll waiting for some input as indicated in the attached draft, but I thought it was worthwhile
to recirculate so that folks could get a jump on reviewing the revised sections.
Thanks,
Mackenzie
Mackenzie P. McNaughton
Tax Law Specialist
Internal Revenue Service
TE/GE, Exempt Organizations
Rulings and Agreements (Technical), Group 4
SE:T:EO:RA:T:4
Phone: 202-283-9484
Fax: 202-283-9462
JW1559-019063
(b)(5)/DP
JW1559-019064
(b)(5)/DP
JW1559-019065
(b)(5)/DP
JW1559-019066
(b)(5)/DP
JW1559-019067
(b)(5)/DP
JW1559-019068
(b)(5)/DP
JW1559-019069
(b)(5)/DP
JW1559-019070
(b)(5)/DP
JW1559-019071
(b)(5)/DP
JW1559-019072
(b)(5)/DP
JW1559-019073
(b)(5)/DP
JW1559-019074
(b)(5)/DP
JW1559-019075
(b)(5)/DP
JW1559-019076
(b)(5)/DP
JW1559-019077
(b)(5)/DP
JW1559-019078
(b)(5)/DP
JW1559-019079
From:
Fish David L
Sent:
Thursday, October 20, 2011 8:13 AM
To:
Megosh Andy
Subject:
FW: case inquiry
Attachments:
OtherDocument[1].tif; Form1024[1].tif
Importance:
High
From: Paz Holly O
Sent: Thursday, October 20, 2011 7:17 AM
To: Fish David L; Lowe Justin
Subject: FW: case inquiry
Importance: High
From: Paz Holly O
Sent: Wednesday, July 20, 2011 5:27 PM
To: Lerner Lois G; Kindell Judith E
Subject: FW: case inquiry
Importance: High
Haven't had a chance to open this yet but here is
From: Angner William J
Sent: Wednesday, July 20, 2011 5:26 PM
To: Paz Holly O
Subject: case inquiry
Importance: High
Brenda Melahn wanted me to follow -up her voicemail to you with a copy of the initial application from
Inc.
Bill Angner
Mgr Group 7827
SE:T:EO:RA:D:2:7827
513-263-3717 phone
513-263-4488 fax
JW1559-019080
JW1559-019081
JW1559-019082
JW1559-019083
JW1559-019084
JW1559-019085
JW1559-019086
6103
JW1559-019087
6103
JW1559-019088
6103
JW1559-019089
6103
JW1559-019090
6103
JW1559-019091
6103
JW1559-019092
6103
JW1559-019093
6103
JW1559-019094
6103
JW1559-019095
6103
JW1559-019096
6103
JW1559-019097
6103
JW1559-019098
6103
JW1559-019099
6103
JW1559-019100
6103
JW1559-019101
6103
JW1559-019102
6103
JW1559-019103
6103
JW1559-019104
6103
JW1559-019105
6103
JW1559-019106
6103
JW1559-019107
6103
JW1559-019108
6103
JW1559-019109
6103
JW1559-019110
6103
JW1559-019111
6103
JW1559-019112
6103
JW1559-019113
6103
JW1559-019114
6103
JW1559-019115
6103
JW1559-019116
6103
JW1559-019117
6103
JW1559-019118
6103
JW1559-019119
6103
JW1559-019120
6103
JW1559-019121
6103
JW1559-019122
6103
JW1559-019123
6103
JW1559-019124
6103
JW1559-019125
6103
JW1559-019126
6103
JW1559-019127
6103
JW1559-019128
6103
JW1559-019129
6103
JW1559-019130
6103
JW1559-019131
6103
JW1559-019132
6103
JW1559-019133
6103
JW1559-019134
6103
JW1559-019135
6103
JW1559-019136
6103
JW1559-019137
6103
JW1559-019138
6103
JW1559-019139
6103
JW1559-019140
6103
JW1559-019141
6103
JW1559-019142
6103
JW1559-019143
6103
JW1559-019144
From:
Fish David L
Sent:
Thursday, October 20, 2011 8:13 AM
To:
Megosh Andy
Subject:
FW: referrals
Attachments:
1128035.pdf; 1128032.pdf; 1128034.pdf
Importance:
High
From: Paz Holly O
Sent: Thursday, October 20, 2011 6:54 AM
To: Fish David L
Cc: Lowe Justin
Subject: FW: referrals
Importance: High
The list of
6103
orgs that need to receive the revocation letters is below.
There is one addition to that list -
(we learned about it later because it was approved by Determs in April 2011 when we thought these cases were
being centralized in DC). I will forward you the
61...
file by separate email.
From: Paz Holly O
Sent: Thursday, July 21, 2011 10:00 AM
To: Downing Nanette M
Subject: referrals
Importance: High
Nan,
The five organizations listed below were mistakenly referred to the ROO when they should have been sen t to
Classification. These five organizations are substantially similar to three organizations whose applications for
501(c)(4) status were recently denied by EO Technical. I have attached the three denials letters so Exam can
see the rationale for the t hree denials. I would appreciate it if you could ensure that the administrative files on
these five organizations that we mistakenly sent to the ROO get to Classification. I apologize for the
inconvenience. I will remind the EO Technical staff of the co rrect process for referring matters to Exam.
Thank you for your assistance,
Holly
From: Buller Siri
Sent: Thursday, May 26, 2011 3:43 PM
To: Kall Jason C
Cc: Cowen Debra F; Smith Danny D
Subject: Referral to ROO
Hi Jason,
JW1559-019145
I hope youre well. Im writing you to refer a number of organizations to Review of Operations. I hope this is the correct
protocol, but please let me know if I should write someone else or follow a different procedure.
Recently, we denied the 1024 applications of three state chapters of
6103
W e denied the applications on the basis that their primary activity confers a private benefit to a political
party. In the course of reviewing these applications, we learned t hat Determinations had already approved the 1024
applications of several other state chapters and the national organization.
These are the organizations that we are
referring. I have attached the proposed denial letters, which later became final.
names and EINs of the referred organizations are below.
The organizations did not protest. The
I also have the administrative files from some of the organizations, which I will fax or email if you think they would be
helpful.
Thank you so much! Please let me know if you need anything else.
Siri
Siri Buller
Tax Law Specialist
Technical Group 1
P: 202.283.9483
F: 202.283.9462
JW1559-019146
JW1559-019147
JW1559-019148
JW1559-019149
JW1559-019150
JW1559-019151
JW1559-019152
JW1559-019153
JW1559-019154
JW1559-019155
JW1559-019156
JW1559-019157
JW1559-019158
JW1559-019159
JW1559-019160
JW1559-019161
JW1559-019162
JW1559-019163
JW1559-019164
JW1559-019165
JW1559-019166
JW1559-019167
JW1559-019168
JW1559-019169
JW1559-019170
JW1559-019171
JW1559-019172
JW1559-019173
From:
Park Nalee
Sent:
Thursday, October 20, 2011 4:43 PM
To:
Lerner Lois G; McNaughton Mackenzie P; Fish David L; Urban Joseph J
Cc:
Light Sharon P; Letourneau Diane L; Jackson Marshalle C; Megosh Andy; Salins Mary J
Subject:
RE: Boustany Letter
Attachments:
Boustany v5 10-20-2011.DOC
Lois,
This is the latest draft, which includes your comments/revisions from yesterday's brief review before you headed out to
meet Nikole. I think we got through 2(g)(i), and I've tracked the changes so you can see the difference from the draft you
handed to Nikole. I'll bring "clean" (e.g. no tracking marks) printed copies tomorrow morning.
NaLee
202.283.9453
From: Lerner Lois G
Sent: Thursday, October 20, 201 1 5:05 PM
To: Park Nalee; McNaughton Mackenzie P; Fish David L
Cc: Light Sharon P; Letourneau Diane L; Jackson Marshalle C
Subject: Boustany Letter
Importance: High
Need to finish going over this Friday as I am out next week --we can do call in if
needed. However, I don't have a copy because I gave mine to Nikole and I believe Nalee took
the other one. Can we try for 11:30 and let me know if we need a call in? Will need a copy-thanks
Lois G. Lerner
JW1559-019174
(b)(5)/DP
JW1559-019175
(b)(5)/DP
JW1559-019176
(b)(5)/DP
JW1559-019177
(b)(5)/DP
JW1559-019178
(b)(5)/DP
JW1559-019179
(b)(5)/DP
JW1559-019180
(b)(5)/DP
JW1559-019181
(b)(5)/DP
JW1559-019182
(b)(5)/DP
JW1559-019183
(b)(5)/DP
JW1559-019184
(b)(5)/DP
JW1559-019185
(b)(5)/DP
JW1559-019186
(b)(5)/DP
JW1559-019187
(b)(5)/DP
JW1559-019188
(b)(5)/DP
JW1559-019189
(b)(5)/DP
JW1559-019190
From:
Park Nalee
Sent:
Thursday, November 17, 2011 11:59 AM
To:
Fish David L
Cc:
Salins Mary J; McNaughton Mackenzie P
Subject:
RE: Chairman Boustany's Oct. 6th letter
Attachments:
Boustany v9 11-14-2011 final.DOC
Attached is the electronic version of the final draft (with exhibits) Lois gave to Joseph Grant to sign on Monday (before
Sarah's Tuesday hearing). However, whether it actually went out is yet to be confirmed - Mary Jo, do you know?
NaLee
202.283.9453
From: Fish David L
Sent: Thursday, November 17, 2011 12:42 PM
To: Salins Mary J; Park Nalee; McNaughton Mackenzie P
Subject: FW: Chairman Boustany's Oct. 6th letter
From: Williams Floyd L
To: Lerner Lois G; Fish David L; Flax Nikole C
We're pretty close on this one, aren't we?
From: Safavian, Jennifer [ mailto:Jennifer.Safavian@mail.house.gov ]
To: Williams Floyd L
Subject: Chairman Boustany's Oct. 6th letter
Floyd,
Could you please provide me with the status of a response to Chairman Bo ustany's Oct. 6th letter requesting
information on the tax -exempt sector? Thank you.
JW1559-019191
(b)(5)/DP
JW1559-019192
(b)(5)/DP
JW1559-019193
(b)(5)/DP
JW1559-019194
(b)(5)/DP
JW1559-019195
(b)(5)/DP
JW1559-019196
(b)(5)/DP
JW1559-019197
(b)(5)/DP
JW1559-019198
(b)(5)/DP
JW1559-019199
(b)(5)/DP
JW1559-019200
(b)(5)/DP
JW1559-019201
(b)(5)/DP
JW1559-019202
(b)(5)/DP
JW1559-019203
(b)(5)/DP
JW1559-019204
(b)(5)/DP
JW1559-019205
(b)(5)/DP
JW1559-019206
(b)(5)/DP
JW1559-019207
(b)(5)/DP
JW1559-019208
(b)(5)/DP
JW1559-019209
(b)(5)/DP
JW1559-019210
From:
Salins Mary J
Sent:
Monday, November 21, 2011 10:41 AM
To:
Lerner Lois G
Cc:
Letourneau Diane L; White Shirley A; Fish David L
Subject:
FW: Chairman Boustany's Oct. 6th letter
Attachments:
We delivered the Boustany letter to Floyd on Friday, and Floyd delivered it to Chairman
Boustany that afternoon. Attached is the electronic version of the letter as finally
sent. We have a copy with Joseph Grant's signature for the office.
Mary Jo Salins
(202) 283-8791
Sent: Friday, November 18, 2011 5:37 PM
To: Salins Mary J; Grant Joseph H
Cc: Urban Joseph J; Park Nalee; McNaughton Mackenzie P; Fish David L
Subject: RE: Chairman Boustany's Oct. 6th letter
FYI--I delivered it at 2pm.
From: Salins Mary J
Sent: Friday, November 18, 2011 8:36 AM
To: Williams Floyd L; Grant Joseph H
Joseph Grant had a few additional changes, and we incorporated your
cleanups. Attached is an electronic copy of the final letter. We had hoped to have the
signed letter ready for Joseph to bring over this morning when he is at 1111, but we did
not get it ready in time.
However, we will deliver the signed letter to you this morning, so that you can deliver it
to Chairman Boustany.
Thanks.
Mary Jo Salins
Acting Manager, EO Guidance
SE:T:EO:RA:G
IRS TE/GE Exempt Organizations Rulings & Agreements
phone (202) 283 -8791
fax (202) 283-9462
mary.j.salins@irs.gov
JW1559-019211
To: Grant Joseph H; Fish David L
Cc: Urban Joseph J; Salins Mary J; Park Nalee
Just a very few "cleanups."
From: Fish David L
Here is the latest draft of the letter. If you have any changes, let us know ASAP. When it
is signed, we will deliver to you to deliver to Boustany.
From: Fish David L
To: Salins Mary J; Park Nalee; McNaug hton Mackenzie P
Subject: FW: Chairman Boustany's O ct. 6th letter
Floyd,
Could you please provide me with the status of a response to Chairman Boustany's Oct. 6th letter requesting
JW1559-019212
(b)(5)/DP
JW1559-019213
(b)(5)/DP
JW1559-019214
(b)(5)/DP
JW1559-019215
(b)(5)/DP
JW1559-019216
(b)(5)/DP
JW1559-019217
(b)(5)/DP
JW1559-019218
(b)(5)/DP
JW1559-019219
(b)(5)/DP
JW1559-019220
(b)(5)/DP
JW1559-019221
(b)(5)/DP
JW1559-019222
(b)(5)/DP
JW1559-019223
(b)(5)/DP
JW1559-019224
(b)(5)/DP
JW1559-019225
(b)(5)/DP
JW1559-019226
(b)(5)/DP
JW1559-019227
(b)(5)/DP
JW1559-019228
(b)(5)/DP
JW1559-019229
(b)(5)/DP
JW1559-019230
(b)(5)/DP
JW1559-019231
From:
Park Nalee
Sent:
Tuesday, December 13, 2011 8:28 AM
To:
Lerner Lois G
Cc:
Letourneau Diane L; Fish David L; Jackson Marshalle C
Subject:
RE: Tax-Exempt Call with Ways and Means Oversight
Attachments:
Yes, I can be there on Friday. Attached is an e-copy. I can bring printed copies with the exhibits.
NaLee
202.283.9453
From: Lerner Lois G
Sent: Monday, December 12, 2011 6:52 PM
To: Park Nalee
Cc: Letourneau Diane L; Fish David L; Jackson Marshalle C
Subject: FW: Tax-Exempt Call with Ways and Means Oversight
Importance: High
We are having either a call or a meeting with his staff on Friday --would you like to attend? I'll
need a copy of the final letter --do we have one?
Lois G. Lerner
From: Flax Nikole C
To: Lerner Lois G; Williams Floyd L
Cc: Letourneau Diane L
Subject: Re: Tax-Exempt Call with Ways and Means Oversight
Sure - Bring who you want/need.
From: Lerner Lois G
To: Williams Floyd L; Flax Nikole C
Subject: RE: Tax-Exempt Call with Ways and Means Oversight
I can do it--are we going up there? Nikole--do you mind if I bring Nalee Park --she did a huge
amount of work on the response so thought she might like to hear the discussion.
Lois G. Lerner
JW1559-019232
To: Flax Nikole C; Lerner Lois G
Lois, let me know and I will set it up.
From: Flax Nikole C
To: Williams Floyd L; Lerner Lois G
Subject: RE: Tax-Exempt Call wi th Ways and Means Oversight
fine for me
To: Lerner Lois G; Flax Nikole C
Subject: Tax-Exempt Call with Ways and Means Oversight
1:30 Friday?
JW1559-019233
(b)(5)/DP
JW1559-019234
(b)(5)/DP
JW1559-019235
(b)(5)/DP
JW1559-019236
(b)(5)/DP
JW1559-019237
(b)(5)/DP
JW1559-019238
(b)(5)/DP
JW1559-019239
(b)(5)/DP
JW1559-019240
(b)(5)/DP
JW1559-019241
(b)(5)/DP
JW1559-019242
(b)(5)/DP
JW1559-019243
(b)(5)/DP
JW1559-019244
(b)(5)/DP
JW1559-019245
(b)(5)/DP
JW1559-019246
(b)(5)/DP
JW1559-019247
(b)(5)/DP
JW1559-019248
(b)(5)/DP
JW1559-019249
(b)(5)/DP
JW1559-019250
(b)(5)/DP
JW1559-019251
(b)(5)/DP
JW1559-019252
From:
Fish David L
Sent:
To:
Urban Joseph J
Subject:
Re: RE Request for Briefing on section 501(c)(4) Application Process
Attachments:
Flag_logo- (b)(3...-url-web.jpg
(b)(3); 6103
. That's what we do when
. Closed
(b)(3); 6103
(b)(...
From: Urban Joseph J
Sent: Friday, February 17, 2012 12:00 PM
To: Fish David L
Subject: RE: RE Request for Briefing on section 501(c)(4) Application Process
So what is
(b)(3);...
(b)(3...
From: Fish David L
To: Urban Joseph J
Cc: Paz Holly O; Miller Thomas J
Subject: Re: RE Request for Briefing on section 501(c)(4) Application Process
(b)(...
To: Grant Joseph H; Lerner Lois G; Fish David L
Cc: Marks Nancy J; Lowe Justin; Kindell Judith E; Light Sharon P; Paz Holly O; Medina Moises C
Subject: RE Request for Briefing on section 501(c) (4) Application Process
FYI, the House Committee on Oversight and Government Reform chaired by Congressman Issa.
Urbana Ohio. Recently, there was an article in the
in the
(b)(3); 6103
Rep. Jordan is from
, which reprinted an arti cle
(b)(3); 6103
about delays in processing (c)(4) applications concerning Tea Party and Liberty groups, and the
questions being asked. The author is the

the processing of the
site. Also, yesterday, the
(b)(3); 6103
(b)(3); 6103
(b)(3); 6103
, and discussed a specific complaint about
(b)(3); 6103
. The article was also published on the
web
issued a press release in which it said it would refuse to comply with a
document request on its ow n application. I am including both articles below.
**********************************************************************************************
(b)(3); 6103
(b)(3); 6103
JW1559-019253
(b)(3); 6103
**********************************************************************************************
(b)(3); 6103
(b)(3)\6103
(b)(3); 6103
(b)(3); 6103
JW1559-019254
(b)(3); 6103
JW1559-019255
(b)(3); 6103
JW1559-019256
(b)(3); 6103
JW1559-019257
(b)(3); 6103
To: Miller Steven T; Davis Jonathan M (Wash DC); Flax Nikole C; Grant Joseph H; Lerner Lois G; Urban Joseph J; Fish
David L
Cc: Keith Frank; Norton William G Jr; Landes Scott S
Subject: Request for Briefing on section 501(c)(4) Application Process
I just received a call from Kristina Moore, Senior Counsel to House Committee on Oversight and
Government Reform. She wants a briefing on the section 501(c)(4) determination process. This
request is prompted by a concern that was brought to the attention of Rep. Jim Jordan, who is Chair
of the Subcommittee on Regulatory Affairs, Stimulus, and Government Spending. The specific
concern involved an organization that applied for exemption about one and one -half years ago and
only just recently heard anything about the status of its application. When it did finally hear from us,
we apparently asked some fairly detailed questions and gave the organization a short deadline to
respond.
Kristina would like to understand why this should take so long and wants to know more, in general,
about the determination process.
I want to be as responsive as possible here and would like to be able to get back to her next week.
think Lois and her team are probably the key people here. Can I get some times to offer her a
briefing next week?
JW1559-019258
(b)(3); 6103
JW1559-019259
From:
Miller Thomas J
Sent:
Friday, February 17, 2012 12:02 PM
To:
Fish David L
Subject:
RE: RE Request for Briefing on section 501(c)(4) Application Process
(b)(3)\6103
6103
Just asking.
Thomas J. Miller
Technical Advisor
Exempt Organizations Rulings & Agreements
Phone: 202-283-9472
Fax: 202-283-8937
From: Fish David L
To: Urban Joseph J
Cc: Paz Holly O; Miller Thomas J
Subject: Re: RE Request for Briefing on section 501(c)(4) Application Process
6103
To: Grant Joseph H; Lerner Lois G; Fish David L
Cc: Marks Nancy J; Lowe Justin; Kindell Judith E; Light Sharon P; Paz Holly O; Medina Moises C
Subject: RE Request for Briefing on section 501(c)(4) Application Process
FYI, the House Committee on Oversight and Government Reform chaired by Congressman Issa . Rep. Jordan is from
Urbana Ohio. Recently, there was an article in the

in the
(b)(3); 6103
, which reprinted an article
(b)(3); 6103
about delays in processing (c)(4) applications concerning Tea Party and Liberty groups, and the
questions being asked. The author is the

the processing of the
site. Also, yesterday, the
(b)(3); 6103
(b)(3); 6103
(b)(3); 6103
, and discussed a specific complaint about
(b)(3); 6103
web
. The article was also published on the

issued a press release in which it said it would refuse to comply with a
document request on its own application. I am including both articles below.
************************************************************** ********************************
(b)(3); 6103
JW1559-019260
(b)(3); 6103
(b)(3); 6103
(b)(3); 6103
(b)(3); 6103
JW1559-019261
(b)(3); 6103
JW1559-019262
(b)(3); 6103
JW1559-019263
(b)(3); 6103
JW1559-019264
(b)(3); 6103
David L
request is prompted by a concern that was brought to the attention of Rep. Jim Jordan, wh o is Chair
only just recently heard anything about the status of it s application. When it did finally hear from us,
respond.
briefing next week?
JW1559-019265
(b)(3); 6103
JW1559-019266
From:
Miller Thomas J
Sent:
To:
Fish David L
Subject:
RE: Request for Briefing on section 501(c)(4) Application Process
I suspected as much. Odd thing is that the applicants complaining raises issue of whether itd primary
activity/purpose is political intervention. (b)(3)... redux, only angrier.
Thomas J. Miller
Technical Advisor
Exempt Organizations Rulings & Agreements
Phone: 202-283-9472
Fax: 202-283-8937
From: Fish David L
To: Miller Thomas J
Subject: Fw: Request for Briefing on section 501(c)(4) Application Process
Here is what is really going on.
From: Paz Holly O
To: Megosh Andy; Fish David L; Park Nalee; Lowe Justin
Subject: RE: Request for Briefing on section 501(c)(4) Application Process
Lois would like someone here to look at the questions asked and see if we think they were needed but more than that
what she wants is a write-up that explains why those type of questions need to be asked of c4 orgs that express that they
plan to engage in some form of advocacy. She needs this by Wednesday morning as she is getting pressure to meet with
the Rep next week. Please assign someone. Thanks!
From: Megosh Andy
To: Paz Holly O; Fish David L; Park Nalee; Lowe Justin
Holly, David,
DO you want us to look at the development questions to determine if we think they are onerous and/or what information
we're trying to gather and why?
Andy
From: Paz Holly O
To: Fish David L; Megosh Andy; Park Nalee; Lowe Justin
JW1559-019267
We just got asked. Looks like Lois is going to have to meet with the Congressman.
From: Fish David L
To: Megosh Andy; Park Nalee; Lowe Justin
Cc: Paz Holly O
Is someone looking at the questions yet? We'll get asked soon.
From: Keith Frank
To: Williams Floyd L; Miller Steven T; Davis Jonathan M (Wash DC); Flax Nikole C; Grant Joseph H; Lerner Lois G; Urban
Joseph J; Fish David L
Cc: Norton William G Jr; Landes Scott S; Lemons Terry L; Eldridge Michelle L
Subject: RE: Request for Briefing on section 501(c)(4) Applicati on Process
Rep. Jordan is from Ohio. I would bet that this is the organization he has heard about.
(b)(3); 6103
(...
JW1559-019268
(b)(3); 6103
(...
JW1559-019269
(b)(3); 6103
David L
of the Subcommittee on Regulatory Affairs, Stimulus, and Government S pending. The specific
we apparently asked some fairl y detailed questions and gave the organization a short deadline to
respond.
briefing next week?
JW1559-019270
From:
Daly Richard M
Sent:
Tuesday, February 21, 2012 11:44 AM
To:
Urban Joseph J; Fish David L
Subject:
FW: 6103 organization meeting with Rep. Jordan today
Media contact regarding Advocacy case (22.1 KB)
Attachments:
High
Importance:
Looks like the thing Floyd was inquiring about.
From: Zarin Roberta B
Sent: Tuesday, February 21, 2012 11:22 AM
To: Lerner Lois G; Light Sharon P; Kindell Judith E; Paz Holly O
Cc: Eldridge Michelle L; Cressman William M; Daly Richard M; Hall Eric; Cressman William M
Subject: FW:
6103
organization meeting with Rep. Jordan today
Importance: High
see the email request below and the attached email traffic from late last week.
Can someone in EO help please?
Bobby Zarin, Director
Communications and Liaison
Tax Exempt and Government Entities
202-283-8868
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
6103
Importance: High
Bobbi - Congressman Jim Jordan will be addressing a group this evening that is wondering what has become of its
application for tax exempt status. The group appears to be politically active and vocal. See below. Is there any chance of
getting some talking points or commen ts before close-of-business, so that we can prep Congressman Jordan? W e do not
have a disclosure authorization, so any talking points would have to be generic, focused on the bigger picture outlined
below.
Let me know. Thanks,
Eric Hall
Legislative Affairs
(202) 622-4057
From: Nielson Jacqueline R
To: Hall Eric; Esrig Bonnie A
Subject: 6103 organization meeting with Rep. Jordan today
JW1559-019271
Help! An organization in
- applied for exempt status in Sept., 2010 and has not gotten
6103
their determination yet. Per the news report below, IRS has requested substantial additional information from them, and it
sounds like they feel they are being singled out due to their beliefs. Per the article, there have been allegations of similar
incidents by groups in other states. Susan Ohl, a staff member of Rep. Jim Jordan's, called this morning and said he has
been invited to address this group this evening, and she is hoping to get an update. W e don't have a disclosure
authorization from the group, although I expect she could get one.
(b)(5) DP
Thanks for your help and advice. Jackie N.
From: Jenkins Jennifer A
To: *Media Relations
Cc: Kerns Chris D; Cressman William M; Nielson Jacqueline R
Subject:
6103
6103
6103
JW1559-019272
6103
JW1559-019273
6103
JW1559-019274
Image not available for this document
JW1559-019275
From:
Urban Joseph J
Sent:
Thursday, February 23, 2012 6:58 AM
To:
Fish David L
Subject:
FW:: Tea Party appliation
Importance:
High
From: Lerner Lois G
Sent: Wednesday, February 22, 2012 7:06 PM
To: Zarin Roberta B; Paz Holly O; Urban Joseph J; Kindell Judith E
Cc: Marx Dawn R; Light Sharon P
Subject: RE: Tea Party appliation
Importance: High
OK--so for my afternoon meeting, I think I will also need to have numbers in the pipeline of all
advocacy matters and status --that is, are any getting screened or all going to full
development? Also, is there any history on similarly situated organization s? Rather than
email--let's talk at the 10:30 meeting in the morning -Judy, not sure you are here tomorrow -if you have info to share and need a call in number, let
Dawn know.
Lois G. Lerner
To: Lerner Lois G; Paz Holly O; Urban Joseph J
Cc: Marx Dawn R
Subject: Tea Party appliation
Application for exempt status (Note this article has links to two letters written by EPEO staffers)
Congressional investigations sought over IRS assault on tea party groups
The Daily Caller via Yahoo! News On Tuesday Jamie Radtke, a Republican U.S. Senate candidate from Virginia, asked
California Republican Rep. Darrell Issa to investigate what she said was unfair treatment of tea party groups by the
Internal Revenue Service. Issa chairs the House Committee on Oversight and Government Reform.
http://news.yahoo.com/congressional -investigations-sought-over-irs-assault-tea-party-065323989.html
http://israelmatzav.blogspot.com/2012/02/z -street-wins-one-against-obamas-irs.html
JW1559-019276
202-283-8868
JW1559-019277
From:
Lerner Lois G
Sent:
Thursday, March 01, 2012 9:13 AM
To:
Fish David L
Cc:
Paz Holly O
Subject:
Document1 (4).doc
Attachments:
Document1 (4).doc
Importance:
High
We will be giving this to Floyd so he can get back to a Congressman's office.
Steve also
suggested sending them a copy of the regs (so that they could see that there are long standing rules here).
So, can you
attach a copy of the reg to this and send it back so I can send the package to Floyd --sorry I'm inept
JW1559-019278
(b)(5)/DP
JW1559-019279
(b)(5)/DP
non-agency
JW1559-019280
From:
Lerner Lois G
Sent:
To:
Fish David L
Subject:
RE: Are all advocacy cases assigned to one group?
That's actually a good response --so we have consistent manager, but cases are dispersed all
around--no "task force" (-:
Lois G. Lerner
From: Fish David L
Sent: Thursday, March 01, 2012 10:45 AM
To: Lerner Lois G
Subject: FW: Are all advocacy cases assigned to one group?
Steve Bowling is responsible for all the cases but he did not have enough Grade 1 3's to work them all.
To: Fish David L
Subject: RE: Are all advocacy cases assigned to one group?
No. We have a representative from almost every group on a team, but the cases are being controlled through one group.
From: Fish David L
To: Thomas Cindy M
Cc: Lowe Justin; Megosh Andy
Subject: Are all advocacy cases assigned to on e group?
Importance: High
Lois needs to know.
JW1559-019281
From:
Lerner Lois G
Sent:
Thursday, March 01, 2012 12:00 PM
To:
Paz Holly O; Fish David L
Subject:
FW: 501c4 status/Cincinatti task force
I know there is a proposed denial in Counsel, but these should all be going out through
Cincy. Also, we should discuss the proposed denial once we get it back.
Lois G. Lerner
From: Lerner Lois G
Sent: Thursday, March 01, 2012 12:58 PM
To: Flax Nikole C; Miller Steven T; Eldridge Michelle L
Cc: Davis Jonathan M (Wash DC)
Subject: RE: 501c4 status/Cincinatti task force
The only time they cam e up here was the initial look at a few cases to help develop guidance
for the Cincy folks
Lois G. Lerner
From: Flax Nikole C
To: Lerner Lois G; Miller Steven T; Eldridge Michelle L
Subject: Re: 501c4 status/Cincinatti task force
Steve, I checked out the question you had and the language is correct.
From: Lerner Lois G
To: Lerner Lois G; Flax Nikole C; Miller Steven T; Eldridge Michelle L
Bobby got an inquiry from someone in media relations asking if w e are responding to the
allegation. I thought we got the OK to use this yesterday --just checking to be sure --can we
give it out?
Lois G. Lerner
JW1559-019282
From: Lerner Lois G
Correct. See my edit--wordy, but maybe a little clearer
Lois G. Lerner
Director of Exemp t Organizations
From: Flax Nikole C
To: Miller Steven T; Lerner Lois G; Eldridge Michelle L
Subject: FW: 501c4 status/Cincinatti task force
Does the following work? Lois, you need to make sure the 2nd sentence is accurate.
I think
.
(b)(5)/DP
(b)(5)/DP
From: Lerner Lois G
To: Flax Nikole C
What can I say-Lois G. Lerner
To: Zarin Roberta B; Eldridge Michelle L
Cc: Patterson Dean J; Williams Grant
This reporter is asking us to specifically confir m whether there is an IRS Cincinnati task force
dedicated to looking at 501c4s political activity and sending these organizations questionnaires.
Sara L. Eguren
IRS Media Relations
JW1559-019283
From: Janie Lorber [ mailto:JanieLorber@rollcall.com ]
To: Eguren Sara L
Subject: 501c4 status/Cincinatti task force
Sara,
Thanks very much for your time just now.
I hear that the IRS Exempt Organizations Division has set up a task force to address concerns about 501c4 organizations that
are acting more like political parties than social welfare organizations. My understanding is that that task force is based i n
Cincinnati and has been in operation for just about two months. I'm told that this committee has issued a series of requests
for additional information to organizations applying for 501c4 status.
Can you confirm this information? Further detail would also be greatly appreciated. My deadline is noon tomorrow. I can be
reached at 202 650 6834
Thank you,
Janie
-Janie Lorber
Reporter
CQ Roll Call
202 650 6834 (O)
339 206 5812 (C)
janielorber@rollcall.com
www.rollcall.com
---------------------------------------------It may also contain personal
This e-mail may contain confidential material. If you are not an intended recipient, please notify the sender and delete all copies.
views which are not the views of CQ Roll Call o r its owner, The Economist Group. We may monitor e -mail to and from our network. For company information go to
http://legal.economistgroup.com .
JW1559-019284
From:
Lerner Lois G
Sent:
To:
Zarin Roberta B; Thomas Cindy M; Paz Holly O; Fish David L
Cc:
Combs Peggy L; Bowling Steven F; Marx Dawn R; Eldridge Michelle L
Subject:
Re: Voicemail message from reporter
Yes--let's get that message out to Cincy and DC. David please handle. I am at doctors Lois G. Lerner -------------------------Sent from my BlackBerry Wireless Handheld
------Original Message -----From: Roberta Zarin
To: Cindy M Westcott
To: Holly Paz
To: David L Fish
Cc: Combs Peggy L
Cc: Bowling Steven F
Cc: Paige Harrell
Cc: Dawn Marx
Cc: Lois Call in Number
Cc: Eldridge Michelle L
Subject: RE: Voicemail message from reporter
Sent: Mar 1, 2012 3:51 PM
Thanks. The reporter has been leaving messages with various employees.
Remember--only media relations should be responding to inquiries from the press.
202-283-8868
_____
To: Paz Holly O; Fish David L; Zarin Roberta B
Cc: Combs Peggy L; Bowling Steven F; Neuhart Paige; Marx Dawn R
Subject: FW: Voicemail message from reporter
Importance: High
You may want to read this....
_____
From: Bowling Steven F
JW1559-019285
To: Thomas Cindy M
Cc: Combs Peggy L
Subject: FW: Voicemail message from reporter
Importance: High
Cindy,
Joseph received a voicemail from a reporter with "Roll Call" in Washington
which he forwarded to me for my review. The caller wanted him to confirm
that a task force exists to investigate non -profit organizations applying
for c(4) or c(3) and are involved in political activity.
Even though she didn't leave a call back number, I'm copy ing Peggy if it is
decided to alert media relations.
STEVEN F. BOWLING
Manager, EO Group 7822
Exempt Organizations Determinations
550 Main Street, Room 4 -504
Cincinnati, OH 45202
Tel (513) 263-3704
Fax (513) 263-4540
_____
From: Herr Joseph R
To: Bowling Steven F
Cc: Seok Stephen D; Bibb Kenneth B
Subject: Voicemail message from reporter
Steve,
I forwarded the voicemail message from the reporter. The reporter is Janie
Lorber from Roll Call. She wa nts to know if I am on a task force looking at
non-profits involved in political activity. She did not leave a telephone
number with her message. I went ahead and looked up the number for Roll
Call; it is (202) 650 -6500.
Joseph
Joseph R. Herr
JW1559-019286
Revenue Agent Group 7821
Exempt Organizations Determinations
(513) 263-3725
(513) 263-4513 fax
JW1559-019287
From:
Lerner Lois G
Sent:
Tuesday, November 01, 2011 4:33 PM
To:
Flax Nikole C
Subject:
Congressional v8 11-01-2011 clean.DOC
Attachments:
Boustany v8 11-01-2011 clean.DOC
Here is the latest draft --they are incorporating my comments re OTSA stuff and changing to
reflect is coming from Joseph. otherwise, we are done, so please let me know where STM
wants changes.
JW1559-019288
(b)(5)/DP
JW1559-019289
(b)(5)/DP
JW1559-019290
(b)(5)/DP
JW1559-019291
(b)(5)/DP
JW1559-019292
(b)(5)/DP
JW1559-019293
(b)(5)/DP
JW1559-019294
(b)(5)/DP
JW1559-019295
(b)(5)/DP
JW1559-019296
(b)(5)/DP
JW1559-019297
(b)(5)/DP
JW1559-019298
(b)(5)/DP
JW1559-019299
(b)(5)/DP
JW1559-019300
(b)(5)/DP
JW1559-019301
(b)(5)/DP
JW1559-019302
(b)(5)/DP
JW1559-019303
(b)(5)/DP
JW1559-019304
(b)(5)/DP
JW1559-019305
From:
Lerner Lois G
Sent:
Saturday, December 10, 2011 2:17 PM
To:
Williams Floyd L; Flax Nikole C; Letourneau Diane L
Cc:
Fish David L
Subject:
Re: Boustany Tax-Exempts Letter
I"ll check Mon morn. I am here early part of Xmas week
Lois G. Lerner-------------------------Sent from my BlackBerry Wireless Handheld
Sent: Saturday, December 10, 2011 01:59 PM
To: Lerner Lois G; Flax Nikole C; Letourneau Diane L
Cc: Fish David L
Subject: Re: Boustany Tax -Exempts Letter
They'd probably prefer in person but if phone would be better for you, I expect we could swing it. Or, I could try week
before Christmas if t hat works better?
Floyd Williams-------------------------Sent from my BlackBerry Wireless Handheld
From: Lerner Lois G
Sent: Friday, December 09, 2011 07:20 PM
To: Flax Nikole C; Williams Floyd L; Letourneau Diane L
Cc: Fish David L
Can't tell you until Mon Morning. Is this in person or by phone? Diane please look at calendar and see what is doable
From: Flax Nikole C
Cc: Fish David L
Subject: RE: Boustany Tax -Exempts Letter
need to see what works for EO
Cc: Fish David L
Subject: RE: Boustany Tax-Exempts Letter
JW1559-019306
OK, if you all will let me know best times, I will set it up with Jen.
From: Flax Nikole C
Cc: Fish David L
I am around -
Cc: Fish David L
Subject: Boustany Tax-Exempts Letter
Are you available sometime next week for followup on tax -exempts letter? Jennifer Acuna is
asking. Let me know.
JW1559-019307
From:
Flax Nikole C
Sent:
Monday, December 12, 2011 9:00 AM
To:
Williams Floyd L; Lerner Lois G
Subject:
Re: tax exempts letter
I will let lois suggest some times and will let you know which ones work for me.
Sent: Monday, December 12, 2011 09:51 AM
Subject: FW: tax exempts letter
They are apparently very anxious. Do you think we could do a phone call early this week?
From: Acuna, Jennifer [mailto:Jennifer.Acuna@mail.house.gov ]
Sent: Monday, December 12, 2011 9:30 AM
Subject: Re: tax exempts letter
Would it be easier to schedule a call? It would be great to get the ball rolling with the follow -up items.
From: Floyd Williams <floyd.williams@irs.gov >
Date: Mon, 12 Dec 2011 09:13:40 -0500
To: WAMR WAMR <jennifer.acuna@mail.house.gov >
Subject: RE: tax exempts letter
The tax exempt group is moving to new office space this week so it is really tight for them.
do something on Monday or Tuesday on the week of the 19th?
Can we
Subject: Re: tax exempts letter
A meeting would be great to review the response and chat about follow -up inquiries. Are you available on Monday or
Tuesday morning?
From: Floyd Williams <floyd.williams@irs.gov >
Date: Fri, 9 Dec 2011 15:38:43 -0500
To: WAMR WAMR <jennifer.acuna@mail.house.gov >
Subject: RE: tax exempts letter
You can follow up with me. Do you want to shoot me an e mail regarding areas you want to follow up
on? Do you want a meeting? I think the principals on information in the letter are Lois Lerner (Chief,
Exempt Organizations) and Nikole. Let me know.
JW1559-019308
Subject: tax exempts letter
Hi Floyd,
Who is the right person to contact about follow -up inquiries to the Boustany tax -exempts letter response we received a
couple of weeks ago?
Thanks!
Jen
JW1559-019309
From:
Lerner Lois G
Sent:
Monday, December 12, 2011 4:42 PM
To:
Williams Floyd L; Flax Nikole C
Cc:
Letourneau Diane L
Subject:
RE: Tax-Exempt Call with Ways and Means Oversight
You're right--we are in the midst of a move. I'm good with a call, but will leave it to Nikole's
discretion.
Lois G. Lerner
Actually, I was going to set up a confe rence call because I thought you were in midst a move. I think
we could get away with a call but if the consensus is to do it in person, I'm sure we could do that. Let
me know your preference.
From: Lerner Lois G
To: Williams Floyd L; Flax Nikole C
I can do it--are we going up there? Nikole--do you mind if I bring Nalee Park --she did a huge
amount of work on the response so thought she might like to hear the discussion.
Lois G. Lerner
To: Flax Nikole C; Lerne r Lois G
Lois, let me know and I will set it up.
From: Flax Nikole C
JW1559-019310
fine for me
Subject: Tax-Exempt Call with Ways and Means Oversight
1:30 Friday?
JW1559-019311
From:
Williams Floyd L
Sent:
Friday, December 16, 2011 8:36 AM
To:
Flax Nikole C
Subject:
FW: Boustany Tax-Exempts Letter
Attachments:
Final_Response_Boustany.pdf
Sent: Tuesday, December 13, 2011 9:23 AM
To: Lerner Lois G; Flax Nikole C; Letourneau Diane L; Fish David L; Jackson Marshalle C
Subject: FW: Boustany Tax-Exempts Letter
Here's the signed response.
From: Rodriguez Christinne
Sent: Tuesday, December 13, 2011 8:10 AM
To: Williams Floyd L; Ortez Cumbuka I
Hi, Floyd.
I believe this is the one y ou are asking for.
Christinne
To: Ortez Cumbuka I; Rodriguez Christinne
Subject: Fw: Boustany Tax -Exempts Letter
Can you send me final version in the morning?
From: Lerner Lois G
To: Letourneau Diane L; Williams Floyd L; Flax Nikole C
Cc: Fish David L; Jackson Marshalle C
Do we have a copy of the final letter?
Lois G. Lerner
JW1559-019312
From: Letourneau Diane L
To: Williams Floyd L; Lerner Lois G; Flax Nikole C
Cc: Fish David L; Jackson Marshalle C
Lois has the following times available:
Monday, Dec 19 -- 10 - 2:30
Tuesday, Dec 20 -- 10:30 - 2
Wednesday, Dec 21 -- 10 -11:30 and 2 - 4
Let me know what works for everyone and I'll block her calendar.
Thanks,
Diane
202-283-8861
Sent: Saturday, December 10, 2011 2:00 PM
To: Lerner Lois G; Flax Nikole C; Letourneau Diane L
Cc: Fish David L
They'd probably prefer in person but if p hone would be better for you, I expect we could swing it. Or, I could try week
before Christmas if that works better?
From: Lerner Lois G
To: Flax Nikole C; Williams Floyd L; Letourneau Diane L
Cc: Fish David L
Can't tell you until Mon Morning. Is this in person or by phone? Diane please look at calendar and see what is doable
From: Flax Nikole C
Cc: Fish David L
need to see what works for EO
JW1559-019313
Cc: Fish David L
OK, if you all will let me know bes t times, I will set it up with Jen.
From: Flax Nikole C
Cc: Fish David L
I am around -
Cc: Fish David L
Subject: Boustany Tax-Exempts Letter
Are you available sometime next week for followup on tax -exempts letter? Jennifer Acuna is
asking. Let me know.
JW1559-019314
D E P A R TM E N T O F TH E TR E A S U R Y
IN T E R N A L R E V E N U E S E R V IC E
W A S H IN G T O N , D .C . 2 0 2 2 4
C O M M IS S IO N E R
TA X E X E M P T A N D
G O V E R N M E N T E N T IT IE S
D IV IS IO N
N ovem ber 18, 2011
The H onorable C harles Boustany, Jr., M D

C hairm an
Subcom m ittee on O versight
C om m ittee on W ays and M eans
U.S. H ouse ofR epresentatives
W ashington, DC 20515
D ear M r. C hairm an:
Iam responding to your letterto C om m issioner Shulm an dated O ctober 6, 2011,
requesting inform ation aboutthe tax-exem pt sector. W e appreciate your interest and
supportfor the IR S efforts in the adm inistration ofthe exem ptorganizations tax law .
R eports ofthe IRS data you requested are created and published by our Statistics of
Incom e (SO l) D ivision. SO l publishes a w ide range oftables, articles, and data that
describe and m easure elem ents ofthe U .S. tax system and are available to the public at
http://w w w .irs.gov/taxstats/index.htm l. U nless otherw ise indicated, SO ldata i ~ current
through FY 2010 and is generally based on valid statistical sam ples.
Also, unless otherw ise stated, any data com piled from the annualfilings ofForm 990
returns and supplem entary schedules orform s w illbe provided only for the 2008 tax
year, the m ostrecentyear in w hich allvoluntarily reported inform ation has been
processed.
1) O verview ofthe Tax-Exem pt S ector

a) P rovide a detailed breakdow n ofthe num ber ofactive tax-exem pt
organizations in good standing w ith the IRS, broken dow n by type (e.g.,
501(c){4),501(c){10.
Enclosed as Exhibit 1(a)-1 is Table 25: Tax-Exem pt O rganizations and N onexem pt
C haritable Trusts, Fiscal Years 2007-2010 from the 2010 IRS Data Book. The FY 2010
totals do nottake into accountorganizations autom atically revoked underInternal
R evenue C ode section 6033U) beginning in June 2011, organizations thatterm inated or
w hose tax-exem pt status w as revoked through the exam ination process during
FY 2011, or new organizations recognized as tax-exem pt in FY 2011. D ata Book
inform ation is updated annually, w ith the FY 2011 inform ation expected in M arch 2012.
JW1559-019315
b) Provide a detailed breakdow n ofthe IRS Tax Exem ptand G overnm ent
Entities D ivision's budgetfor 2008 through 2011. Specify the totalnum ber
ofem ployees dedicated to tax-exem pt organization w ork and how these
resources are allocated across the division.
Pursuantto clarification from Legislative Affairs thatthis question is intended to reflect
the TE/G E budgetfor FY 2008 - FY 2011 and the staffing inform ation for only the
EO division, we offerthe following inform ation. The enclosed Exhibit 1(b)-1 provides a
breakdow n ofTE/G E budgetdata for FY 2008 - FY 2011. Exhibit1(b)-2 provides
EO staffing inform ation as ofthe lastday ofeach fiscalyear.
c) H ow m any tax-exem ptorganizations have been audited since 2008?

Provide a breakdow n ofallaudits opened for each type oftax-exem pt
entity, the issues identified for audit, and the currentstatus ofsuch audits.
W hatw as the average length ofa tax-exem pt auditduring this period?
O ursystem s track exam ination inform ation by return ratherthan by organization, and
inform ation is entered into the system atthe tim e each return is closed. Enclosed as
Exhibit 1(c)-1 is IRS FY 2008, FY 2009 and FY 2010 Data Book Table 13: R eturns of
Tax-Exem ptO rganizations, Em ployee Plans, G overnm ent Entities, and Tax-Exem pt
Bonds Exam ined, by Type ofReturn. According to the Table 13 data, IRS TE/G E,
EO exam ined the follow ing num bers oftax-exem pt organization returns and related
taxable returns during FY 2008 - FY 2010:
FY 2008: 7,861
FY 2009: 10,187
FY 2010: 11,449
W ith respectto the issues identified for audit, the enclosed Exhibit 1(c)-2 contains a list
ofallthe PrincipalIssue C odes (PIC codes) used forclosed exam inations involving tax
exem ptorganizations for FY 2008 - FY 2011. The InternalR evenue M anualproVisions
governing the use ofPIC codes are located atsection 4.75.16.9.1 There are 96 PIC
codes for agents to use as partofthe process ofclosing a case. PIC codes are
designed to proVide historical data to create a m odelto distinguish com pliantfrom non
com pliant returns. In no-change cases, agents are instructed to selectthe PIC code
thatcaptures the issues on which the agentspenttim e during the exam ination. In a
change case, the agentis instructed to selectthe PIC code thatcaptures the issue or
issues resulting in the change. Agents m ay choose up to four PIC codes, and ifm ore
than one PIC code is chosen, the agent is to listthem in orderofpriority, beginning with
the m ostim portant. In both the no-change and change cases, the determ ination of
w hich PIC codes are applicable to a particular case is a judgm ent m ade by the agent.
I The Internal Revenue M
anual is available athttp://www .irs.govlinnlindex.htm l.
JW1559-019316
3
The enclosed Exhibit 1(c)-2 shows the ten m ostfrequently em ployed PIC codes:
42: D elinquent 940/941 Returns

83: Em ploym ent Tax - O ther Issues
39: D elinquent 990/990-EZ Returns
21: O perationalTest
34: O ther
78: Em ploym entTax - W orkerClassification Issues
65: Claim for Refund
5: D elinquent Filing ofReturn (O ther)
57: G am ing - PullTabs
79: Em ploym entTax - 1099 Issues
The average length oftim e for com pleting exam ination returns thatwere closed in
FY 2011 is 210 days.
d) H ow m any new tax-exem ptorganizations did the IRS recognize in each of

the lastthree years forw hich data is available? Provide a breakdow n ofall
new applications fortax-exem ptstatus by organization type and yearfor
those years. D escribe the process by w hich an entity is granted tax
exem ptstatus. W hatis the IRS procedure for conducting periodic review s
ofan organization's tax-exem pteligibility?
Enclosed as Exhibits 1(d)-1 is Table 24: Closures ofApplications forTax-Exem pt
Status, by O rganization Type and Internal Revenue Code Section, for FY 2008 through
FY 2010 from the 2008,2009 and 2010 IRS Data Book. The inform ation in Table 24 for
each fiscal year is tracked atthe end ofthe determ ination process; thatis,the
inform ation reflects the num berofcases closed in each fiscalyear, notthe num berof
applications received.
Process for IRS Tax-Exem pt Recognition
W ith regard to recognition fortax-exem pt status, enclosed foryourgeneralreference as
Exhibit 1(d)-2 is IRS Publication 557, Tax-Exem pt Status for YourO rganization. M ost
organizations seeking recognition ofexem ption from federal incom e tax m ustuse
specific applications form s prescribed by the IRS; prim arily, Form 1023,Application for
R ecognition ofExem ption U nderSection 501 (c)(3) ofthe Internal Revenue Code, and
Form 1024, Application for Recognition UnderSection 501(a). Som e organizations do
nothave to use specific application form s and apply for tax-exem ptstatus by letterto
the address shown on Form 8718, User Fee for Exem ptO rganization Determ ination
Letter Request. A copy ofthe organization docum entshould be enclosed and the letter
should be signed by an officer ofthe applicantorganization. Allapplications for
exem ption are sentto EO Determ inations, headquartered in Cincinnati, O hio.
Ifan application forexem ption does notcontain the required inform ation, itm ay be
returned with a letterofexplanation without being considered on its m erits.
JW1559-019317
4
Alternatively, ifthe application is substantially com plete, the IRS m ay retain the
application and requestadditional inform ation as needed. Ifan application for
exem ption raises issues on qualification for exem ption orfoundation status for which no
published precedentexists orforwhich nonuniform ity m ay exist, EO Determ inations will
referthe application to EO Technical in W ashington, D.C.
Ifthe IRS receives inform ation sufficiently establishing thatan organization m eets the
requirem ents for exem ption from federal incom e tax, the IRS willissue a determ ination
letter recognizing the organization's exem pt status and providing its public charity
classification, ifapplicable. A proposed adverse determ ination letterwill be issued to an
organization that has notprovided sufficiently detailed inform ation to establish thatit
qualifies forexem ption orifthe inform ation provided establishes thatitdoes notqualify
for exem ption.
The IR S also grants group exem ptions to organizations thathave orplan to have
related organizations thatare very sim ilarto each other. G roups oforganizations with
group exem ptletters have a "head" orm ain organization, referred to as a central
organization. To qualify for a group exem ption, the centralorganization and its
subordinates m ustbe affiliated with the centralorganization, subjectto the central
organization's generalsupervision orcontrol, and exem ptunderthe sam e paragraph of
section 501 (c), through notnecessarily the paragraph underwhich the central
organization is exem pt.
A centralorganization seeking a group exem ption requestfollows the sam e application
form at as a single organization - itsends its Form 1023 orForm 1024 application
exem ption to the IRS. Upon receiptofan application Form 1023 or 1024 and a request
forgroup exem ption, the IRS firstdeterm ines w hether the centralorganization and the
existing subordinates qualify fortax exem ption. O nce the IRS grants the exem ption, the
centralorganization is responsible for: (1) ensuring that its current subordinates
continue to qualify to be exem pt; (2) verifying thatany new subordinates are exem pt;
and (3) updating the IRS on an annual basis ofnew subordinates, subordinates no
longer to be included, and subordinates thathave changed their nam es oraddresses.
Enclosed for your additional reference as Exhibit 1(d)-3 is IRS PUblication 4573, G roup
Exem ptions, TE/G E Division.
In term s offollow -up and as a regular partofits annualworkplan, the Review of
O perations (R O O ) perform s follow-up com pliance reviews ofa statisticalsam ple of
organizations thatw ere granted tax-exem pt status in the past3-5 years. Based upon
results ofreviews, organizations m ay be referred forexam ination where appropriate.
In addition to the statisticalsam ple, RO O perform s com pliance reviews on organizations
thathave recently gone through the determ ination process, including organizations that
are recognized as tax-exem pt because their applications m eetallthe legalrequirem ents
fortax-exem pt status, butthe agenthas concerns aboutfuture activities ofthe
organization so follow up is appropriate.
JW1559-019318
2) C om pliance
a) Provide a detailed explanation ofhow the IRS is using the new inform ation
obtained from the new Form 990 to im prove currentenforcem ent efforts
and future com pliance.
W e undertook a com prehensive redesign ofForm 990, Return ofO rganization Exem pt
from Incom e Tax, thatw as effective beginning with tax year 2008. O ne elem entofthe
redesign w as to provide a structured form atfor reporting inform ation - both the
additionalinform ation being requested and the inform ation thatprevious versions ofthe
form had required w ithout specifying the form at to be used. By providing thatstructure,
the inform ation reported on the Form 990 is m ore readily com parable, which enables us
to use data analytic techniques to identify areas ofpotential noncom pliance. The
redesigned Form 990 also offers the taxpayer a better understanding ofw hat
inform ation to provide and the public with a m ore accurate picture ofan organization's
activities.
As organizations have had an opportunity to transition into and provide inform ation
using the new reporting requirem ents, we are now developing and testing risk m odels to
im prove ourexam ination case selection process. Forinstance, such risk m odels
include analyzing issues related to: com pliance practices ofself-declared section
501 (c)(4), section 501(c)(5) and section 501(c)(6) organizations; unrelated business
incom e and filings ofForm 990-T; and governance, particularly com position ofboards.
This effortis in line w ith TE/G E's w ider strategy ofusing data-driven tools to targethigh
risk areas.
b) Provide a detailed explanation ofhow the redesigned Form 990 increased

transparency
The redesigned Form 990 proVides a structure for providing inform ation thatm akes it
m ore readily com parable across differentorganizations. By adopting the form atofa
core form with a series ofschedules, the redesigned Form allows the public, press and
others to m ore easily locate the inform ation they are interested in. The redesigned core
form also allow s an organization to describe its exem ptaccom plishm ents and m ission
up frontand provides m ore opportunities throughoutthe form forthe organization to
explain its activities.
Forthe 2010 Form 990, exam ples ofourefforts to refine the Form to increase
transparency include changes to the following Schedules:
Schedule C, PoliticalC am paign and Lobbying Activities:
Instructions for PartII-A clarify thatthis Partneeds to be com pleted by all
Form 990 filers forwhich the 501 (h) lobbying expenditure election was
valid and in effectduring the 2010 tax year, w hetheror notthe
organization engaged in lobbying activities during thattax year.
JW1559-019319
6
Schedule F, Statem entofActivities O utside the United States: Schedule F and
its instructions w ere revised to:
C larify thatthe num berofindependent contractors in a foreign region
should be reported, along with the num ber ofem ployees and agents in
thatregion.
R equire reporting ofthe total book value ofinvestm ents in a foreign
region.
C larify how to reporttotalnum ber offoreign offices, agents, em ployees
and independent contractors.
C larify thattypes ofindirectexpenditures for foreign activity thatdo not
have to be reported ifthey are notseparately tracked include expenses for
listing study abroad program s on a schoolwebsite orin a papercatalog.
C larify thatforeign program related investm ents are reportable in P art" of
Schedule F.
PartII instructions state thata filer should reportnotonly grants and other
assistance to foreign organizations orentities, butalso to U.S.
organizations or entities forforeign activity.
P arts" and III instructions clarify thatorganizations using the accrual
m ethod ofaccounting that m ake foreign grants to be paid in future years
should reportthe grants' presentvalue in P art" and reportany accruals of
additional value in future years.
Parts IIand III instructions clarify thatthe filing organization should report
foreign grants regardless ofthe source ofthe grantfunds (w hether
restricted or unrestricted) orw hether the filing organization selected the
grantee.
A new PartIV requires reporting ofw hether the organization engaged in
foreign activities thatrequire filing ofother IRS form s.
Schedule R, Related O rganizations:
N ew colum n (g) in P art" asks w hether each related tax-exem pt
organization is a section 512(b)(13) controlled entity ofthe filing
organization.
N ew colum n (k) in Part III asks for the filing organization's percentage
ow nership interest in each related partnership.
N ew colum n (d) in PartV asks how the organization determ ined the
am ountofeach type ofrelated party transaction reported in PartV.
Instructions provide exam ples to illustrate how the filing organization can
controlor be controlled by m ultiple persons, and how m ultiple nonprofit
organizations can be directly and indirectly related to one another.
JW1559-019320
c) H ave taxpayers expressed concerns to the IRS regarding the com pliance
burden associated w ith the redesigned Form 990? Ifso, describe the
prim ary com pliance issues identified by taxpayers and w hatthe IRS has
done, or plans to do,to address taxpayer concerns.
The IRS extensively redesigned Form 990 fortax year 2008 to prom ote tax com pliance
and increase transparency. The redesign was a com prehensive, collaborative process
thatincluded m eetings with taxpayer groups and feedback from the EO sector
(including the public, state charity regulators, the m edia, and policym akers) during
conferences and speeches. 'Also, based on feedback from the over800 form alpublic
com m ents on drafts ofthe 2008 Form 990, schedules, and instructions,the IRS
recognized thatthe transition from the old to the redesigned Form 990 would change
the w ay som e organizations capture and track data forthem to com plete the Form .
Thus, to help allfilers becom e fam iliarwith the Form ,w e released two drafts ofthe 2008
Form 990 in the year and a halfpriorto publication ofthe final Form , along with m ultiple
educationalresources on how the Form had changed and tips forcom pleting it. To give
sm alland m id-sized organizations with fewer legal, accounting, and adm inistrative
resources m ore tim e to adaptto the reporting transitions, we also im plem ented a 3-year
phase-in period raising the assetand gross receipts thresholds for Form 990 filing by
ten-fold (from $100,000 in gross receipts and $250,000 in assets to $1 m illion and $2.5
m illion, respectively) fortax year 2008, by five-fold fortax year 2009 ($500,000 and
$1.25 m illion), and ending at$200,000 and $500,000 fortax years 2010 and later. The
transition period allowed hundreds ofthousands ofsm aller and m id-sized organizations
thatwould have been required to file the Form 990 fortax years 2008 and 2009 to file
the shorter Form 990-EZ forone orboth ofthose years. This transition period also gave
organizations tim e to progressively enable their internalsystem s to respond to the new
requirem ents.
I
The m ajor redesign ofthe Form 990 is com plete. The IRS redesigned the Form to
m ake itm ore stream lined and betterorganized. W e elim inated unstructured
attachm ents, replacing them with structured schedules to prom ote uniform ity and
reduce am biguity over how to report supplem entalinform ation. W e also added m any
tools to the instructions, including a G lossary, Appendices, exam ples and illustrations,
and a sequencing list, to help filers com plete the Form m ore easily.
The IRS continues to refine the Form , schedules, and instructions based on public
com m ent. W e have m ade clarifications, corrected errors, and added exam ples to m ake
the Form easierto understand and com plete. As recently as June 2,2011, w e
requested public com m enton 11 transitional issues and frequently asked questions
involving the redesigned Form 990 in Announcem ent 2011-36. W e have received just
over 100 com m ents in response to Announcem ent 2011-36, which we are in the
process ofanalyzing. Any changes in response to the com m ents willbe m ade as
appropriate. W e willdo so on an ongoing basis to m inim ize any potentialburdens
w here consistentwith ourobjectives to increase com pliance and transparency.
JW1559-019321
8
In response to the Affordable Care Act (ACA), the IRS added a new PartV, Section B to
the 2010 Form 990, Schedule H (Hospitals) to gather inform ation related to new
requirem ents fortax-exem pt hospitalfacilities and to related policies and practices.
Further, in response to m eetings with EO stakeholders thatm ore tim e w as needed for
the hospitalcom m unity to fam iliarize itselfwith the new questions and to adjusttheir
system s to gatherthe inform ation needed as wellas public com m ents on am biguities in
the questions, the IRS issued Announcem ent 2011-37 thatm ade the entire PartV,
Section B optionalforthe 2010 tax year. The IRS continues to solicit and review public
com m ents on Schedule H revisions and im plem entation ofthe AC A requirem ents for
tax-exem pt hospitals.
W e have posted on ourwebsite, IRS.gov/eo, m any audio, visual, and written tools to
assistfilers in understanding and com pleting the Form 990 and schedules. W e also
speak atdozens ofconferences, sem inars, and webinars throughoutthe yearto reach
thousands ofrepresentatives oftax-exem pt organizations and answ er their questions
about Form 990 preparation. W e willalso continue to acceptcom m ents through the
IR S Form 990 com m entm ailbox.
d) Is the IRS contem plating any additionalchanges to Form 990 to further

com pliance goals? Ifso, describe the planned m odifications and their
estim ated effecton com pliance.
W hile the m ajor redesign is com plete, we continue to refine the Form 990, schedules,
and instructions in response to public com m ent received inform ally and through our
com m ent m ailbox and requestforclarification. See response to question 2(c), above,
for a description ofthe IR S's ongoing efforts to solicitand respond to pUblic com m enton
the Form 990. In addition, the IRS Exem pt O rganizations (EO ) division seeks and
coordinates inputfrom its various operating units, including EO Rulings and
Agreem ents, EO Exam inations, and EO Determ inations in considering changes to the
Form 990, schedules, and instructions. EO also consults with its C hiefC ounsel's office
in considering and drafting such changes.
e) H ow is the IRS using the related organization inform ation from the
Schedule R? W hattype ofcom pliance problem s is this schedule designed
to curb? Is the inform ation reported on the Schedule helpfulin im proving
com pliance? Ifnot,are further changes to the schedule contem plated? If
so, please describe the planned m odifications and theirestim ated effecton
com pliance.
The redesigned Form 990 fortax years beginning in 2008 provides m ore
com prehensive inform ation aboutan organization than the priorForm 990 in allareas,
including the organization's activities, the com pensation ofits officers and key
em ployees, and relationships with other entities. For instance, the Schedule R is
designed to increase transparency by proViding a m ore com plete picture ofthe filing
organization's structure, relationships with related organizations, types oftransactions
with related organizations, and involvem ent in jointventures with non-exem ptentities.
JW1559-019322
9
This disclosure also serves our com pliance purposes, as itm ay suggest potential
inurem ent, private benefit, ornon-exem pt activity.
W e are using this new inform ation, including inform ation on the related organizations
reported in Schedule R.to design adaptable risk m odels to allow us to identify
organizations with higher potentialfor noncom pliance. W e plan to use these tools to
identify organizations thatwe m ay contactthrough specific com pliance projects and
through our regular exam ination program . Forinstance, we m ay look atcom pensation
from related organizations as partofour determ ination w hetherthe com pensation of
certain officers, directors, and key em ployees is reasonable.
No changes to the Schedule R are presently underway, butwe m ay m ake m odifications
to the Schedule R and/orinstructions based on com m ents subm itted in response to
.Announcem ent 2011-36.
f) Has the IRS identified any specific governance issues based on the
additionalinform ation provided on the redesigned Form 990? Ifso,
provide a detailed description ofthe new issues identified.
Based on feedback from the regulated com m unity, w e have learned thatexem pt
organizations'governing boards have becom e m ore involved in Form 990 preparation
and review since the Form 990 was redesigned and questions were added in PartVI
(G overnance) on governance policies and board review ofthe Form 990. Sim ilarly, w e
have learned ofgreateradoption ofsound risk m anagem entpolicies by exem pt
organizations'governing boards in response to PartVI questions.
W e also have learned thatgoverning boards ofexem ptorganizations are m aking
greaterefforts to add independent board m em bers, and to m ore carefully scrutinize
transactions with board m em bers to ensure that such transactions do notcom prom ise
their independence.
In 2010, w e initiated a long-term study on the intersection ofgovernance practices and
tax com pliance. To gatherdata,we began using a checksheet, enclosed as
Exhibit2(f)-1, atthe end ofevery exam ination ofa return associated with a section
501(c)(3) organization. W e are using the checksheet data to better understand how the
com position ofgoverning bodies and generalgovernance practices im pacttax
com pliance. In addition, we are using responses to Form 990 to continue developing
and testing risk m odels to im prove ourexam ination case selection process. As w e
com pile sufficient inform ation, we plan to work with our research function to analyze
long-term data and publicly reportthe findings.
JW1559-019323
10
g) The IRS recently revoked the tax-exem ptstatus ofthousands of

organizations across the country for failure to file tax returns as partofthe
autom atic revocation program .
i) W hatis the currentstatus ofthis program ?
Pursuantto the Pension Protection Actof2006, Pub. L.N o.1 09-280, 120 Stat. 780,
section 1223 (2006) (Pension Protection Act), the IRS is im plem enting the revocation,
w hich occurs by operation oflaw, ofthe tax-exem ptstatus ofany organization thatfails
to file a required annual return orForm 990-N e-Postcard forthree consecutive years.
In June 2011, the IRS firstsentnotices to and published the nam es ofapproxim ately
275,000 organizations whose tax-exem pt status was autom atically revoked because
they did notfile legally required annual reports forthree consecutive years. The IRS
believes the vastm ajority ofthese organizations are defunct, butalso announced
specialsteps to help any eXisting organizations to apply for reinstatem ent oftheir tax
exem ptstatus. As ofO ctober 7,2011, around 385,000 organizations have been
autom atically revoked. As ofO ctober 14,2011, about5,500 organizations have applied
for reinstatem ent.
The IRS continues to send notices, rem inding organizations oftheirfiling reqUirem ents,
and publishes the nam es ofadditionalorganizations whose exem ptstatus has been
autom atically revoked every m onth. The IRS already is processing applications from
those organizations that requestreinstatem ent oftheirtax-exem ptstatus (the only
adm inistrative rem edy allowed undersection 6033(j)(2)). The IRS recognizes thatm any
sm allorganizations were disproportionately affected by the law change, and is
adm inistering a transition reliefprogram for certain sm alltax-exem ptorganizations that
w ere m ade subjectto the new Form 990-N e-Postcard filing requirem ent by the Pension
Protection Act. The organizations eligible forthe transition reliefprogram pay a reduced
userfee with their application. Ifthe application is approved for m eeting the
requirem ents for exem ption, they autom atically regain their tax-exem pt status retroactive
to the date ofrevocation.
ii) H ow m any taxpayers reinstated theirtax-exem ptstatus using the

procedures in Revenue Procedures 2011-8,2011-36,and 2011-43?
iii) H ow m any taxpayers are currently in the process ofbeing reinstated?
O n June 8, 2011, the sam e day we published the firstAuto-Revocation List(List) on
IRS.gov, we also published severalpieces ofguidance to proVide organizations on the
Listwith inform ation regarding reinstatem ent oftheirtax-exem pt status. Transition relief
w as offered to certain sm allorganizations under Notice 2011-43. The transition relief
included a reduced userfee offered in Rev. Proc. 2011-36 and, ifthe organization's
application forexem ption was approved, retroactive reinstatem ent. Allother
organizations on the Listthatapplied for reinstatem ent oftax-exem pt status are
reqUired to pay the userfee provided in Rev. Proc. 2011-8.
JW1559-019324
11
In response to questions 2(g)(ii) and (iii)above, as ofO ctober 14,2011, the IRS has
received about 5,500 applications seeking reinstatem ent and closed about2,000
(includes approvals and a sm allnum ber ofapplications thatwere withdrawn orclosed
forfailure to provide inform ation substantiating exem ption). About 1,550 ofthe
applications were approved for reinstatem ent underthe transition reliefproVided in
Notice 2011-43 (and Rev. Proc. 2011-36), and the rem ainder cam e in with the regular
userfees provided in Rev. Proc. 2011-8.
iv) W hatis the average length oftim e for the processing ofa
reinstatem ent request?
W e do nottrack reinstatem ent requests separately from other requests for
determ inations. The average length oftim e for processing alltypes ofEO
D eterm inations cases was 104 days for FY 2011.
v) Is the IRS planning to issue any further guidance related to the

autom atic revocation program ?
The IRS continues to send notices to organizations to rem ind them oftheirfiling
responsibilities. In addition, the IRS continues to update its custom er outreach and
educationalm aterials to offerongoing inform alguidance and address new issues
relating to the autom atic revocation program , such as updating applicable FAQ s on the
IRS w ebsite (www .irs.gov).
3) U nrelated Business Incom e

a} In 2009,the C ongressional Research Service estim ated thatrevenues from
tax-exem ptorganizations w ere $1.4 trillion and the value ofassets held by
tax-exem ptorganizations totaled $2.6 trillion.2 Provide IRS data regarding
the revenue and assets oftax-exem ptorganizations for 2008,2009, and
2010.
The SO lDivision publishes the balance sheetand incom e statem ent item s for
sections 501 (c)(3)-(9) tax-exem ptorganizations only, based on inform ation received on
Form s 990 and 990-EZ. The m ostrecent SO ldata is from tax year 2008. Allfigures
are based on statistically valid sam ples, and m oney am ounts are in thousands of
dollars. Enclosed as Exhibits 3(a)-1 and 3(a)-2 are Table 3: Form 990-R eturns of
501 (c)(3-(9) O rganizations: Balance Sheetand Incom e Statem ent Item s, by Code
Section, Tax Year 2008, and Table 4: Form 990-EZ Returns of501 (c)(3)-(9)
O rganizations: Selected Item s, by Code Section, Tax Year2008.
SeeAn O verview ofthe Nonprofit and Charitable Sector, CongressionalResearch Service (Nov.17,2009).
JW1559-019325
12
b) H ow does the IRS identify unrelated business taxable incom e issues for
audit? Provide a breakdow n ofthe totalnum beroftax-exem ptaudits
opened by the IRS in 2009 and 2010 thatinvolved unrelated business
taxable incom e issues.
The IR S identifies unrelated business taxable incom e (U BTI) issues foraudit in tw o
m ain w ays:
By using Form 990 data to develop data analytics and risk m odels from the
reported inform ation, including unrelated business incom e; and
Through the strategic planning w orking group, w hich looks atdata analytics
trends in exam and applications for exem ption, new spaper articles, w ebsites, and
other public inform ation to identify potential areas ofnoncom pliance and
develops projects to address such noncom pliance.
As ofO ctober 19,2011, oursystem s show 874 closed returns w ith atleastone U BTI
PIC code for FY 2009, and 1,028 returns had atleastone UBTI PIC code for FY 2010.
Lim itations in PIC code data are discussed in the response to question 1(c). See
enclosed Exhibit 1(c)-2, w hich contains a listofallthe Principal Issue C odes (PIC
codes) used for closed exam inations to identify issues involving tax-exem pt
organizations for fiscalyears 2008 - 2011.
c) Provide the follow ing figures concerning all501(c) organizations for the
2009 and 2010 tax year, identifying each type separately.
i) H ow m any organizations reported unrelated business taxable incom e
and incom e exem ptfrom the unrelated business incom e tax?
ii) H ow m any organizations reported both unrelated business taxable and

incom e exem ptfrom the unrelated business incom e tax?
In response to questions 3(c)(i) and (ii) above, the SO l D ivision publishes inform ation on
unrelated business incom e attributed to tax-exem pt organizations based on inform ation
received on Form 990-T. The m ostrecent SO ldata is from tax year 2008. The
inform ation requested is show n on SO lTable 1: N um berofR eturns, G ross U nrelated
Business Incom e (U BI), TotalD eductions, U nrelated Business Taxable Incom e (Less
D eficit), U nrelated Business Taxable Incom e, and TotalTax, by Type ofTax-Exem pt
O rganization, Tax Year2008, and is enclosed as Exhibit3(c)(i)-1.
iii) W hatis the totalam ountoftax-exem ptroyalty incom e, and tax-exem pt

rental incom e reported? W hatis the average am ountofthose sources
ofincom e am ong the entities thatreported receiving atleastsom e such
incom e?
Although notpublished in an annualSO ltable or IRS Data Book, saldoes track
inform ation relating to royalty incom e reported on Form 990 and rental incom e reported
JW1559-019326
13
on Form 990 and Form 990-EZ. Please note thatForm 9 9 0 - ~ Z does notask for
inform ation on royalty incom e. Attached as Exhibit 3(c)(iii)-1 is the follow ing SO ldata:
R oyalty Incom e R eported by 501(c)(3)-(9) O rganizations on Form 990, Tax Year 2008.
and N etR ental Incom e R eported by 501(c)(3)-(9) O rganizations on Form s 990 and
990-PF, Tax Year 2008.
iv) W hatare the m ostcom m on tax-exem pt organization errors related to

reporting trade or business incom e?
As noted in the response to question 1(c), PIC codes are used to provide historicaldata
to create a m odelto distinguish com pliantfrom non-com pliant returns. The specific PIC
codes that relate to UBTI are listed in the order offrequency on the enclosed
Exhibit 1(c)-2, w hich lists allused PIC codes for closed exam inations involving tax
exem ptorganizations forfiscal years 2008 - 2011. The specific PIC codes that
describe U BTI issues are:
33:
35:
36:
37:
38:
U nrelated Trade ofBusiness (O ther)

UBI - Expense Allocation Issues
U B I- N O L Adjustm ent
U B I-Incom e from C ontrolled C orp. underIR C 512(b)(13)
UBI- O ther
v) D escribe IRS procedures for review ing returns by tax-exem pt

organizations that report unrelated business taxable incom e.
W hen agents are assigned any return for a full-scope audit, they look atallissues on
the return, including unrelated business taxable incom e (U BTI). The Internal R evenue
M anualcontains procedures for conducting exam inations involving U BTI issues.
See, e.g., IRM 4.76.2.8, enclosed as Exhibit 3(c)(v)-1.
4) A udits
a) W hat percentage ofthe Tax Exem ptand G overnm ent Entities D ivision's
budgetis allocated tow ards audits and exam inations?
Pursuantto clarification from Legislative Affairs thatthe question is intended to reflect
only the EO budget in FY 2011,60.27 percentofEO 's budget is allocated tow ards
audits and exam inations.
b) E xplain how the IRS review s allegations ofexcessive politicalcam paign

activity by tax-exem pt organizations.
All referrals from W hatever source that alleges that a tax-exem pt organization is in
potentialnoncom pliance w ith the tax law, including politicalcam paign intervention, are
sentto EO Exam inations' C lassification in D allas, Texas. C lassification staffreview s
each allegation to determ ine w hether the referralfalls under EO Exam ination's
JW1559-019327
14
jurisdiction. Ifitdoes, Classification staffinitiates "case building", which includes pulling
transcripts ofForm 990 and perform ing other research as appropriate to allow the IRS
to m ake a decision based on a "reasonable beliefstandard" thatfurther action is
w arranted. Ifitis notan EO case, the referralis forwarded to the appropriate IRS
O perating Division to be worked through theirreferralprocess.
AllEO Exam ination referrals are entered into a database fortracking purposes. N otall
referrals entered into the database willbe selected for exam ination.
Procedures existto ensure that no single individual m akes case selection
determ inations when sensitive issues are potentially involved. Allreferrals involving
politicalactivities are sentto an EO referralcom m ittee m ade up ofexperienced, career
civil servantExam m anagers. Ifthe referralcom m ittee determ ines thatthere is
exam ination potential,the referralis assigned to a field group. W hen a referralis
received by a field group forexam ination, the G roup M anagergenerally reviews the
case and assigns itto an agentwith the appropriate levelofexperience.
c) W hatissues does the IRS prioritize w hen conducting audits oftax-exem pt

organizations, or review ing the returns ofsuch organizations?
O urstrategic planning process influences how we focus ourExam ination resources.
The process includes reviewing Form 990 data, Exam trending data, D eterm inations
trending data, inputfrom other IRS functional areas, referrals from the public, news
m edia, and otherpublic inform ation. As also described in the response to question 3(b),
ourstrategic planning working group uses data from the Form 990 returns to review
data analytics trends and develop risk m odels to identify potentialareas of
noncom pliance. This allows the IRS to determ ine how to allocate resources and to
develop projects thatfocus on areas where we see a need to gather m ore inform ation.
This also allows us to determ ine types ofoutreach warranted to assisttax-exem pt
organizations in theircom pliance efforts. Enclosed as Exhibit4(c)-1 is a copy ofthe
m ostrecently published EO workplan (FY 2011), which lists som e ofthe projects
initiated through ourstrategic planning working group.
d) The redesigned Form 990 requires additionalinform ation on related and

subsidiary organizations. Has the new inform ation prom pted an auditor
been ofassistance during the course ofan audit? Ifso, please describe
the m anner in w hich the inform ation has been used.
See the response to question 2(e) regarding related organization inform ation.
5) C urrentTax-Exem ptEnforcem ent Initiatives

a) In addition to the H ospitals and U niversities projects (referenced in
sections (c) and (d,are there any tax-exem ptcom pliance projects thatthe
IRS is currently undertaking? Does the IRS have plans to launch any such
JW1559-019328
15
projects in the upcom ing year? Ifso, please describe the anticipated
com pliance project.
Each yearthe EO Division puts outits workplan that includes accom plishm ents from the
previous fiscalyear and com pliance priorities for the upcom ing fiscalyear, and also
provides updated statistics. Enclosed as Exhibit4(c)-1 is a copy ofthe m ostrecently
published EO workplan (FY 2011). Som e ofthe workplan highlights include the
following:
Filing dem ographics and statistical inform ation on the redesigned 2008 Form 990
Im plem entation ofthe AC A legislation
Colleges and Universities study and related exam inations projectthatasked
questions relating to theirexecutive com pensation, endowm ents, and unrelated
business incom e
International-focused tax enforcem ent efforts, such as the G ifts-in-Kind
exam ination project, thatexplore whether charitable assets ofexem pt
organizations are being diverted internationally for non-charitable purposes
N on-filer Initiatives to help taxpayers com ply with their voluntary filing obligations
and to im prove enforcem ent
b) Excise Taxes/Penalties
i) H ow m any disqualified persons ororganization m anagers w ere subject
to penalties under IRC 4958 forviolating the excess benefit rules
betw een 2006 and 20101
ii) H ow m any donor advised funds orsupporting organizations w ere
subjectto the excess benefitrules ofIRC 4958 betw een 2006 and
2010? Have any ofthese organizations losttheirt a x ~ e x e m p t status?
iii) H ow m any tax-exem ptorganizations have been subjectto the excise tax
under IR C 4911 betw een 2006 and 2010 for failure to com ply w ith the
lobbying rules?
In response to questions 5(b)(i) - (iii) above, allsupporting organizations and donor
advised funds, as w ellas any disqualified persons and organization m anagers, are
subjectto the various rules and applicable excise taxes underC hapter 41 (including
section 4911) and C hapter 42 (including section 4958).
O urautom ated exam inations system s track excise tax returns oforganizations or
individuals w ho w ere found to have violated C hapters 41 or 42 filed as a result of
exam inations. H ow ever, our exam inations system s only capture the aggregate of
C hapter 41 and C hapter 42 excise tax assessm ents and do notseparately break dow n
the different types ofexcise taxes described w ithin the subsections ofC hapter41 and
C hapter 42. Thus, our autom ated exam inations system does notseparately track or
reportsections 4911 or4958 assessm entdata.
JW1559-019329
16
In addition to Exam ination data,the SO lDivision analyzes data from estim ates based
on statistically valid sam ples ofexcise tax returns (Form s 4720) filed voluntarily, notas
a resultofan exam ination. Although the SO lDivision provides som e data on C hapters
41 and 42 excise taxes, they also do notdifferentiate orseparate the data further
am ong the various types oftaxes within each chapter. The SO lestim ates, based on
self-initiated Form s 4720 filed during a particular calendar year, m ay include C hapter41
orC hapter42 violations occurring in various tax years.
Enclosed as Exhibit 5(b)1 - 5 is SO lTable 1: Excise Taxes Reported by Charities,
Private Foundations, and Split-InterestTrusts ofForm 4720 forcalendaryears
2006 - 2010. During this tim e period, SO lestim ates that Form 4720 filers self
assessed approxim ately $1,440,203 in section 4911 excise taxes and $1,322,811 in
section 4958 excise taxes.
iv) H ow m any tax-exem pt organizations has the IRS found to be engaged in
tax shelter transactions betw een 2006 and 2010? Provide a breakdow n
ofthe type oftransaction and the results ofthe audit/investigation .
The IRS O ffice ofTax ShelterAnalysis (O TSA) captures TE/G E-w ide inform ation on tax
shelteractivities thatare subjectto the disclosure requirem ents under section 6011 and
section 6033.
Pursuantto Treasury Regulations section 1.6011-4,a taxable party thathas participated
in a listed transaction m ustfile a Form 8886 to m eetits disclosure requirem ents. O TSA
data show s 68 Listed Transaction Form 8886 Disclosures from 2006 - 2010. The
follow ing table sum m arizes the num berofdisclosures by sheltertype. O TSA's
database does nottrack the results ofthe audit/exam inations.
D escription ofListed Tr.3nsaction

IRC 419A (f)(6) -M ulti Em ployer W elfare Plans
Interm ediary Transactions
Contingent Liabilities
Roth IRAs
IRC 4I2(i) -Retirem entPlans
SC2 -S-Corp Stock Transaction
IRC 419A -Abusive Trustusing Life Insurance Plans
N otionalPrincipal Contracts/Swaps
Total
#of
tE /G E
Disclosures
6
5
26
8
15
6
68
* 3 or few er
Also, pursuantto Treas. Reg'.section 1.6033-5, certain tax-exem pt entities thatare

subjectto section 4965 taxes are required to file Form 8886-T, Disclosure by Tax
JW1559-019330
17
Exem pt Entity Regarding Prohibited Tax ShelterTransaction, to disclose inform ation
with respectto each prohibited tax sheltertransaction to which the entity is a party.
O TSA data shows 42 Listed Transaction Form 8886-T Disclosures from 2006 - 2010.
The following table sum m arizes the num berofdisclosures by sheltertype. O TSA's
database does nottrack the results ofthe audiUexam inations.
#of
TE/G E
D isclosures
Description ofL i ~ t e d Transaction
V EB A W elfare BenefitFund -419A (f)(5)

Retirem ent Plans -412(i)
N otional Principal Contracts and Sw aps
A busive Trusts providing w elfare benefits
U nknow n
*
*
34
4
Total
42
* 3 or few er
Further, beginning in 2008, the redesigned Form 990 expands the questions relating to
tax shelter reporting. The Form asks w hether an organization w as a party to orw ere
notified by a taxable entity thatthey w ere a party to a prohibited party transaction, and
w hether Form 8886-T w as filed, unlike in previous years. In tax year 2008,87
organizations indicated they w ere a party to orw ere notified by a taxable entity thatthey
w ere a party to a prohibited party transaction on their Form 990. O fthese 87
organizations, 28 reported filing a Form 8886-1.
c) H ospitals
i) D escribe the IR S's current plans to com ply w ith the new requirem ent in
IR C 4959 to review , at least once every three years, the com m unity
benefit activities ofeach hospital organization that is subject to the
requirem ents under IRC 501(r).
The IR S form ed and trained a dedicated group to conduct the com m unity benefit
activities review ofeach hospitalorganization that is subjectto the requirem ents under
section 501(r). This group w as form ed in O ctober 2010, and review s started in M arch
2011. Approxim ately one third ofthe required hospital review s w illbe conducted each
year.
ii) W hat steps are the IR S taking to com ply w ith the requirem ent under IR e
9007(e) of Pub. L.111-148, Patient Protection and A ffordable C are A ct,
to subm it an annual report to C ongress, including the W ays and M eans
C om m ittee, regarding the level ofcharity care provided by all hospitals
(taxable, charitable, and governm ent)?
The IR S is coordinating w ith the D epartm ent ofTreasury (Treasury) and H ealth and
H um an Services (H H S) to develop and gatherthe inform ation necessary for the report
JW1559-019331
19
all exam inations looked at both issues regardless o f w hy the entity w as selected . A s
noted, m any o f these exam inations are still ongoing and w e w ill be reporting o u r
findings in the final report.
I hope this inform ation is helpful. If you have any questions, please contact m e o r have
yo u r staff contact M ary Jo S alins at (202) 283-8791.
S incerely,
J sep
~.
. G ra nt
ting C o m m issio n e r
T a x E xem pt & G o ve rn m e n t E ntities
E n clo su re s
JW1559-019332
From:
Miller Steven T
Sent:
To:
Flax Nikole C
Subject:
Re: Request for Briefing on section 501(c)(4) Application Process
Let me know if its a taxpayer I should know about. And let's discuss eo cycle time at bpr this week.
From: Flax Nikole C
To: Grant Joseph H; Williams Floyd L; Miller Steven T; Davis Jonathan M (Wash DC); Lerner Lois G; Urban Joseph J; Fish
David L
Lets coordinate schedules so that I can attend as well. Thanks
From: Grant Joseph H
To: Williams Floyd L; Miller Steven T; Davis Jonathan M (Wash DC); Flax Nikole C; Lerne r Lois G; Urban Joseph J; Fish
David L
Subject: Re: Request for Briefing on section 501(c)(4) Application Process
Floyd,
We are looking in to it. We need to look at the file before heading up to the H ill. Lois will come to you with some times
for next week or early the following week.
Joseph
-------------------------Sent from my BlackBerry Wireless Handheld
David L
request is prompted by a concern that was brought to the attention of Rep. Jim Jordan, wh o is Chair
JW1559-019333
only just recently heard anything about the status of it s application. When it did finally hear from us,
respond.
briefing next week?
JW1559-019334
From:
Miller Steven T
Sent:
To:
Flax Nikole C
Subject:
Fw: Request for Briefing on section 501(c)(4) Application Process
Attachments:
Flag_logo
(b)(3); ...
url-web.jpg
Will the emails never stop? See who tp is. Thx.
To: Keith Frank; Williams Floyd L; Miller Steven T; Davis Jonathan M (Wash DC); Flax Nikole C
(b)(3); 6103
JW1559-019335
(b)(3); 6103
JW1559-019336
(b)(3); 6103
JW1559-019337
(b)(3); 6103
JW1559-019338
(b)(3); 6103
From: Keith Frank
Joseph J; Fish David L
Rep. Jordan is from Ohio. I would bet that this is th e organization he has heard about.
(b)(3); 6103
JW1559-019339
(b)(3); 6103
JW1559-019340
(b)(3); 6103
David L
concern involved an organization th at applied for exemption about one and one -half years ago and
we apparently asked some fairly detailed questions and gave the organization a short dea dline to
respond.
briefing next week?
JW1559-019341
(b)(3); 6103
JW1559-019342
From:
Flax Nikole C
Sent:
Tuesday, February 21, 2012 4:30 PM
To:
Williams Floyd L
Subject:
FW:
Importance:
High
(b)(3)...
Floyd We need to wait and just convey the info on Friday.
From: Lerner Lois G
Sent: Tuesday, February 21, 2012 5:21 PM
To: Flax Nikole C
Subject: FW:
(b)(3...
Importance: High
fyi
Lois G. Lerner
From: Lerner Lois G
To: Zarin Roberta B; Paz Holly O
Cc: Thomas Cindy M
Subject: RE:
(b)(3)...
Importance: High
We are handling this at a higher level--Nikole Flax and I are supposed to go talk to
Congressman on Friday. No one else should be doing anything. Bobby can you let the leg
affairs and media relations folks know. Holly--I need a complete timeline since it came in the
door please.
Lois G. Lerner
To: Paz Holly O; Lerner Lois G
Subject: FW:
(b)(3...
Importance: High
JW1559-019343
202-283-8868
To: Paz Holly O
Cc: Light Sharon P; Zarin Roberta B; Nielson Jacqueline R; Hall Regeina D
Subject: FW:
(b)(3...
Importance: High
Holly,
Please read Jackie's email directly below.
How do you want to handle this?
NOTE: This case was assigned to Joseph Herr on 2/6/2012. It has a control date from 9/2010.
To: Zarin Roberta B; Thomas Cindy M
Cc: Hall Eric
Subject: FW:
(b)(3...
Importance: High
I do have the privacy release from the
, EIN
(b)(3); 6103
have authorized release of information to Congressman Jordan.
(b)(3); 6103
re: their Form 1024. They
In the release they say their application has been
assigned to RA Ron Bell in EO. Should I call Ron for an update? He may be able to provide the list of questions he has
asked the group to answer. If we could also give him just a couple of talking points, that might be helpful, e.g. we review
each application for completeness, etc. Thanks! Jackie N., Governmental Liaison, 614 -280-8739
Subject: FW:
(b)(3);...
Importance: High
202-283-8868
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
(b)(3...
Importance: High
JW1559-019344

getting some talking points or comments before close -of-business, so that we can prep Congressman Jordan? W e do not
below.
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
(b)(3...
organization meeting with Rep. Jordan to day
(b)(3); 6103
Help! An organization in (b)(3)... their determination yet. Per the news report below, IRS has requested substantial additional information from them, and it
(b)(5) DP
6...
61...
Subject: Clip:
(b)(3); 6103
(b)(3); 6103
JW1559-019345
(b)(3); 6103
JW1559-019346
(b)(3); 6103
JW1559-019347
From:
Hall Eric
Sent:
Wednesday, February 22, 2012 7:51 AM
To:
Williams Floyd L; Flax Nikole C
Cc:
Norton William G Jr
Subject:
RE: Talking points for meeting with Rep. Jordan today
Below is the statement TEGE provided. I have confirmed that the statement was received by Congressman Jordan's staff
last night at 5:05 pm.
Eric
Upon receipt, exemption applications accompanied by the required user fee are initially separated into four categories:
(1) those that can be approved immediately based on the information submitted, (2) those that need minor additional
information to be resolved, (3) those that are submitted on obsolete forms or do not include the items specified on the
Procedural Checklist (at http://www.irs.gov/pub/irs -tege/f1023_procedural_checklist_0606.pdf), and (4) those that
require development.
If an application fa lls within one of the first three categories, the applicant will receive either its determination letter or a
request for additional information, via phone, fax, or letter, within approximately 90 days of the date the application
was submitted.
Applications falling within the fourth category must be assigned to an EO agent for further development. Due to staffing
levels, applications falling into this category cannot always immediately be assigned . These applications can experience
some wait time befo re assignment to an agent. The number of applications awaiting assignment to EO agents has
increased due, in part, to the influx of applications from large organizations seeking to have their exempt status
retroactively reinstated after being automatica lly revoked pursuant to the Pension Protection Act of 2006 for failure to
file annual information returns/notices for three consecutive years.
Once a case is assigned to an EO agent, the agent must consider the type of organization and the rules applicabl e to that
type of organization. Because exemption from federal income tax is a valuable subsidy, the Internal Revenue Code and
accompanying Treasury Regulations impose detailed requirements for qualification for exemption as various types of
entities. EO agents often have to ask the applicant organizations questions and ask for related documents to determine
whether they satisfy these requirements.
For example, under the Code, organizations exempt under section 501(c)(3) (what we commonly refer to as charities)
are absolutely forbidden from intervening in political campaigns. In contrast, organizations exempt under sections
501(c)(4), 501(c)(5) and 501(c)(6) can intervene in political campaigns within limits. It is thus important that EO agents
look at the materials used and activities conducted by organizations seeking exemption under sections 501(c)(4),
501(c)(5) and 501(c)(6) to make sure campaign intervention will be within the legal limits. This review often involves a
back and forth question a nd answer process between the IRS and the applicant.
-----Original Message ----From: Williams Floyd L
To: Flax Nikole C; Hall Eric
Cc: Norton William G Jr
Subject: Re: Talking points for meeting with Rep. Jor dan today
JW1559-019348
Eric, please follow up.
------Original Message -----From: Nikole Flax
To: Floyd Williams
Subject: Fw: Talking points for meeting with Rep. Jordan today
Sent: Feb 21, 2012 10:30 PM
Floyd - can you find out in the am if we sent anything? Thanks ------Original Message-----From: Lerner Lois G
To: Flax Nikole C
Subject: RE: Talking points for meeting with Rep. Jordan today
Sent: Feb 21, 2012 7:24 PM
I sent it to you after it went to media and leg affairs --I'm guessing he got it
Lois G. Lerner
_____
From: Flax Nikole C
To: Lerner Lois G
Subject: RE: Talking points for meetin g with Rep. Jordan today
lets just wait until friday
_____
From: Lerner Lois G
To: Flax Nikole C
He' is meeting with a different , similarly situated org than the one he has
the release on(the one we'll be talking to him about Friday) tonight and
wanted our general process to tell them about
Lois G. Lerner
_____
From: Flax Nikole C
JW1559-019349
To: Lerner Lois G
I am confused. What meeting is today? Why don't we just convey the info
Friday?
_____
From: Lerner Lois G
To: Flax Nikole C
Subject: FW: Talking points for meeting with Rep. Jordan today
Importance: High
Thought you'd want to see this --apparently his staff asked for something
general to use as talking point --the Rep is speaking to the org tonight
Lois G. Lerner
_____
To: Hall Eric; Nielson Jacqueline R
Cc: Lerner Lois G; Paz Holly O; Eldridge Michelle L; Williams Floyd L;
------Original Message Truncated ------
JW1559-019350
From:
Flax Nikole C
Sent:
To:
Lerner Lois G
Subject:
Re: Congressional
Ok sure.
From: Lerner Lois G
To: Flax Nikole C
Cc: Marx Dawn R
Subject: Congressional
I am over at 1111 tomorrow for BPR. If you have time afterwards, can we chat a bit about
Friday--if they manage to se the meeting. I just wanted to let you know where we stand and
what I am pulling together for the meeting.
Lois G. Lerner
JW1559-019351
From:
Flax Nikole C
Sent:
To:
Miller Steven T
Cc:
Barre Catherine M
Subject:
Re: 501(c)(4) Meeting
I am not sure I will be back from the PT appt, but should be close. Sorry, this is the one I can't change (and I need it). I
will work something out.
From: Miller Steven T
To: Flax Nikole C
Cc: Barre Catherine M
Subject: Re: 501(c)(4) Meeting
Let's try 1130 tomorrow --my core erb will not be 1 hour.
To: Flax Nikole C
Subject: Re: 501(c)(4) Meeting
Ok but think I have a meeting then
From: Flax Nikole C
To: Miller Steven T
Subject: Fw: 501(c)(4) Meeting
Lois and I were going to talk after the bpr tomorrow. JD thought you may want to join. Want me to set something up?
We are short on options for times to meet before friday.
Subject: Fw: 501(c)(4) Meeting
2pm Friday. Lois, who else besides you?
JW1559-019352
From: Moore, Kristina [ mailto:Kristina.Moore@mail.house.gov]
Cc: Eichinger, Kevin < Kevin.Eichinger@mail.house.gov >; Millspaw, Tegan <Tegan.Millspaw@mail.house.gov >
Subject: RE: 501(c)(4) Meeting
Lets lock it in for 2 on Friday. I have copied the other staff who will also be attending.
Do you how many people will be
coming from your side?
From: Williams Floyd L [mailto:Floyd.Williams@irs.gov ]
To: Moore, Kristina
Subject: 501(c)(4) Meeting
This Friday afternoon. Maybe 2pm or later?
JW1559-019353
From:
Lerner Lois G
Sent:
Monday, February 27, 2012 9:56 AM
To:
Flax Nikole C
Subject:
FW: Draft of Advocacy Org Guide Sheet
Attachments:
Importance:
High
Here is the piece we worked up to provide guidance for Cincy on advocacy. Counsel is
looking it over to be sure they are comfortable, but thought you should see what we have in
terms of a comfort level to let this out. Mr.. Fish and I don't see any way w e can withhold--no
thresholds, so we would be better off putting it on the web. Let me know as soon as you can
what the thinking is.
Lois G. Lerner
From: Paz Holly O
To: Spellmann Don R
Don,
Thanks,
Holly
Cc: Seto Michael C
Hi Liz and Donna,
Attached please find a d raft copy of the guidesheet we have been putting together on advocacy organizations. I hope you
Thanks,
Hilary
Hilary Goehausen
Tax Law Specialist
JW1559-019354
Technical Group 1
p: 202.283.8915
f: 202.283.8937
JW1559-019355
(b)(5)/db
JW1559-019356
(b)(5)/db
JW1559-019357
(b)(5)/db
JW1559-019358
(b)(5)/db
JW1559-019359
(b)(5)/db
JW1559-019360
(b)(5)/db
JW1559-019361
(b)(5)/db
JW1559-019362
(b)(5)/db
JW1559-019363
(b)(5)/db
JW1559-019364
(b)(5)/db
JW1559-019365
(b)(5)/db
JW1559-019366
(b)(5)/db
JW1559-019367
From:
Lerner Lois G
Sent:
To:
Flax Nikole C
Subject:
RE: Question from organization applying for exempt status
when
Lois G. Lerner
From: Flax Nikole C
To: Lerner Lois G
Subject: RE: Question from organization applying for exempt status
Steve had some issues with the guidelines too so we should talk.
From: Lerner Lois G
To: Flax Nikole C
Subject: FW: Question from organization applying for exempt status
The sooner the better that we have a standard response. I am working to get the guidelines to
Cincy oked by Counsel so we can post on the web too. One of the biggest reasons that folks
are revved up is they don't have information
Lois G. Lerner
From: Lerner Lois G
To: Grant Joseph H
Just FYI
Lois G. Lerner
To: Lerner Lois G; Nielson Jacqueline R
Cc: Paz Holly O; Eldridge Michelle L
JW1559-019368
Lois, thank you very much.
From: Lerner Lois G
To: Nielson Jacqueline R; Williams Floyd L
This is a very sensitive area and Floyd just accompanied me to the Hill last week to discuss
with some folks there. I feel more comfortable if he is in the loop on these requests so we are
being consistent. We have put something together for media relati ons to use when press
come in--let me make sure it has been blessed and then I think it might be the best thing to
send on. I'll get back to you later today
Lois G. Lerner
From: Paz Holly O
To: Lerner Lois G
Subject: Fw: Question from organization applying for exempt status
-------------------------Sent from my BlackBerry Wireless Device
To: Paz Holly O
Holly, I just talked to Sarah Arbes in Senator Mitch McConnell's office.
They are asking if the questions in the attached
notice are ones we commonly ask organizations applying for exempt status under 501(c)(4). This case is similar to the
one you worked on last week for Rep. Jordan. If you're in today, I can call and give you a little more explanation about
this. Thanks. Jackie Nielson, GL, OH and KY, 614 -280-8739
From: Arbes, Sarah (McConnell) [ mailto:Sarah_Arbes@mcconnell.senate.gov ]
To: Nielson Jacqueline R
Attached are the questions we discussed. W ithout getting into the specifics of the individual case, we were hoping you
could tell us whether these are standard questions for organizations applying for 501(c)(4) status
Thank you for your help!
Sarah
Sarah Arbes
JW1559-019369
U.S. Senator Mitch McConnell
317 Russell Senate Office Building
Washington, DC 20510
(202) 224-2541
sarah_arbes@mcconnell.senate.gov
Sign up for Senator McConnell's e-newsletter
From: Nielson Jacqueline R [ mailto:Jacqueline.R.Nielson@irs.gov ]
To: Arbes, Sarah (McConnell)
Subject: Question from organization applying for exempt status
Hi, Sarah,
Marsha in the Taxpayer Advocate office asked me t o contact you about the organization that applied for exempt status
under IRC 501(c)(4) and has not received their determination yet. If you have an e-mail or letter from that group that I can
share with our Exempt Organization Division, would you please send it to me in reply to this e -mail, or by fax to 614 -2808735, Attn: Jackie Nielson? If they signed a privacy release that you could send me, that would be great. If they didn't
furnish that, I can reply in more general terms.
Thanks, Sarah. Please call if you want to discuss.
Jackie Nielson
IRS Governmental Liaison
Phone (614) 280-8739
Fax (614) 280-8735
JW1559-019370
From:
Flax Nikole C
Sent:
To:
Lerner Lois G
Subject:
FW: Document1
Attachments:
Document1.doc
are we sending a written response to McConnell? if so, from who. I don't have the incoming - did it mention c4 status?
From: Lerner Lois G
To: Flax Nikole C
Subject: Document1
Is this good for you?
JW1559-019371
(b)(5)/DP
JW1559-019372
(b)(5)/DP
JW1559-019373
From:
Flax Nikole C
Sent:
To:
Lerner Lois G
Subject:
RE: Question from organization applying for exempt status
I can't tell what is different from what everyone was good with - I'll compare them and get back to you today. Thanks
From: Lerner Lois G
To: Flax Nikole C
This is the incoming --it is from McConnell's staff. I planned to give the written piece to
Floyd. I wrote it so it could be passed on, but it could also just be used by Floyd to give them
an oral response. The attachment is just a copy of one of the requests for more information to
a c4 org
Lois G. Lerner
Director of E xempt Organizations
From: Paz Holly O
To: Lerner Lois G
email chain below
From: Lerner Lois G
To: Nielson Jacqueline R; Williams Floyd L
This is a very sensitive area and Floyd just accompanied me to the Hill last week to discuss
with some folks there. I feel more comfortable if he is in the loop on these requests so we are
being consistent. We have put something together for media relations to use when press
come in--let me make sure it has been blessed and then I think it might be the best thing to
send on. I'll get back to you later today
Lois G. Lerner
From: Paz Holly O
JW1559-019374
To: Lerner Lois G
Subject: Fw: Question from organization applying for exempt status
To: Paz Holly O
Holly, I just talked to Sarah Arbes in Senator Mitch McConnell's office. They are asking if the questions in the attached
notice are ones we commonly ask organizations app lying for exempt status under 501(c)(4). This case is similar to the
one you worked on last week for Rep. Jordan. If you're in today, I can call and give you a little more explanation about
this. Thanks. Jackie Nielson, GL, OH and KY, 614 -280-8739
From: Arbes, Sarah (McConnell) [ mailto:Sarah_Arbes@mcconnell.senate.gov ]
To: Nielson Jacqueline R
Attached are the questions we discussed. W ithout getting into the specifics of the individual case, we were hoping you
could tell us whether these are standard questions for organizations applying for 501(c)(4) status
Thank you for your help!
Sarah
Sarah Arbes
U.S. Senator Mitch McConnell
317 Russell Senate Office Building
Washington, DC 20510
(202) 224-2541
sarah_arbes@mcconnell.senate.gov
Sign up for Senator McConnell's e-newsletter
From: Nielson Jacqueline R [ mailto:Jacqueline.R.Nielson@irs.gov ]
To: Arbes, Sarah (McConnell)
Subject: Question from organization applying for exempt status
Hi, Sarah,
Marsha in the Taxpayer Advocate office asked me to contact you about the organization that applied for exempt status
under IRC 501(c)(4) and has not received their determination yet.
If you have an e-mail or letter from that group that I can
share with our Exempt Organ ization Division, would you please send it to me in reply to this e -mail, or by fax to 614 -2808735, Attn: Jackie Nielson? If they signed a privacy release that you could send me, that would be great. If they didn't
furnish that, I can reply in more gene ral terms.
Thanks, Sarah. Please call if you want to discuss.
JW1559-019375
Jackie Nielson
IRS Governmental Liaison
Phone (614) 280-8739
Fax (614) 280-8735
JW1559-019376
From:
Flax Nikole C
Sent:
To:
Holton Winonna F
Subject:
Re: 501c4 status/Cincinatti task force
Let's do 11. Tomorrow. Please call it EO update
From: Lerner Lois G
To: Flax Nikole C
Cc: Holton Winonna F
We're suppose to do 502(r) regs at 12, but I am not a major player, so either works.
thinking face to face might work best, so I can go there. Just let me know
I'm
Lois G. Lerner
From: Flax Nikole C
To: Lerner Lois G
Cc: Holton Winonna F
Haven't been able to check yet.
We need to sit down with steve in general. Can you do tomorrow 11:00 -11:45 or 12:45-1:30? We can set up a call.
From: Lerner Lois G
To: Flax Nikole C
I'll check to be sure, but I'm guessing for consistency sake, Cindy has the work g oing to one
group--that would be our regular way of handling a specific issue because you don't have to
reinvent the wheel. In light of the case numbers though, she may not be doing that --I'll get
back at you. Any word on the letter to orgs that haven't provided the requested docs?
Lois G. Lerner
From: Flax Nikole C
To: Lerner Lois G
JW1559-019377
Are there certain folks that would be assigned these cases or is it just a function of t he grade?
From: Lerner Lois G
Lois G. Lerner
From: Flax Nikole C
I think
.
(b)(5)/DP
(b)(5)/db
From: Lerner Lois G
To: Flax Nikole C
JW1559-019378

Sara L. Eguren
IRS Media Relations
From: Janie Lorber [mailto:JanieLorber@rollcall.com ]
To: Eguren Sara L
Sara,
Can you confirm this information? Further detail would also b e greatly appreciated. My deadline is noon tomorrow. I can be
reached at 202 650 6834
Thank you,
Janie
-Janie Lorber
Reporter
CQ Roll Call
202 650 6834 (O)
339 206 5812 (C)
www.rollcall.com
-------------------------------- -------------This e-mail may contain confidential material. If you are not an intended recipient, please notify the sender and delete all copies.
It may also contain personal
views which are not the views of CQ Roll Call or its owner, The Economist Group . We may monitor e -mail to and from our network. For company information go to
JW1559-019379
From:
Flax Nikole C
Sent:
To:
Lerner Lois G
Subject:
RE: 501c4 status/Cincinatti task force
we are all set on this
From: Lerner Lois G
To: Lerner Lois G; Flax Nikole C; Miller Steven T; Eldridge Michelle L
Importance: High
Bobby got an inquiry from someone in media relations asking if we are responding to the
allegation. I thought we got the OK to use this yesterday --just checking to be sure --can we
give it out?
Lois G. Lerner
From: Lerner Lois G
Lois G. Lerner
From: Flax Nikole C
I think
.
(b)(5)/DP
(b)(5)/DP
JW1559-019380
From: Lerner Lois G
To: Flax Nikole C
This reporter is asking us to specifically confirm whether there is an IRS Cincinnati task force
Sara L. Eguren
IRS Media Relations
From: Janie Lorber [ mailto:JanieLorber@rollcall.com ]
To: Eguren Sara L
Sara,
Can you confirm this information? Further detail would also b e greatly appreciated. My deadline is noon tomorrow. I can be
reached at 202 650 6834
Thank you,
Janie
-Janie Lorber
Reporter
CQ Roll Call
202 650 6834 (O)
339 206 5812 (C)
www.rollcall.com
JW1559-019381
---------------------------------------------It may also contain personal
This e-mail may contain confidential material. If you are not an intended recipient, please notify the sender and delete all copies.
views which are not the views of CQ Roll Call o r its owner, The Economist Group. We may monitor e -mail to and from our network. For company information go to
JW1559-019382
From:
Lerner Lois G
Sent:
To:
Ingram Sarah H; Grant Joseph H
Subject:
FW: Ways and Means
Attachments:
"Final" package letter --attachments are only in hard copy, but can send a pack if you need it
Lois G. Lerner
Sent: Monday, November 14, 2011 12:42 PM
To: Lerner Lois G
Subject: FW: Ways and Means
To: Park Nalee
Subject: FW:
Final version -- but I didn't change the name.
From: Park Nalee
To: Letourneau Diane L
Cc: Park Nalee
Subject:
NaLee Park
R&A, EO Guid ance Group 2
TEGE, Washington D.C.
(t) 202.283.9453 | (f) 202.283.9462
JW1559-019383
(b)(5)/DP
JW1559-019384
(b)(5)/DP
JW1559-019385
(b)(5)/DP
JW1559-019386
(b)(5)/DP
JW1559-019387
(b)(5)/DP
JW1559-019388
(b)(5)/DP
JW1559-019389
(b)(5)/DP
JW1559-019390
(b)(5)/DP
JW1559-019391
(b)(5)/DP
JW1559-019392
(b)(5)/DP
JW1559-019393
(b)(5)/DP
JW1559-019394
(b)(5)/DP
JW1559-019395
(b)(5)/DP
JW1559-019396
(b)(5)/DP
JW1559-019397
(b)(5)/DP
JW1559-019398
(b)(5)/DP
JW1559-019399
(b)(5)/DP
JW1559-019400
(b)(5)/DP
JW1559-019401
(b)(5)/DP
JW1559-019402
From:
Williams Floyd L
Sent:
Thursday, November 17, 2011 3:39 PM
To:
Grant Joseph H; Fish David L
Cc:
Urban Joseph J; Salins Mary J; Park Nalee
Subject:
Attachments:
Boustany v9 11-14-2011 fina leg affairsl.DOC
From: Fish David L
From: Fish David L
Floyd,
JW1559-019403
JW1559-019404
(b)(5)/DP
JW1559-019405
(b)(5)/DP
JW1559-019406
(b)(5)/DP
JW1559-019407
(b)(5)/DP
JW1559-019408
(b)(5)/DP
JW1559-019409
(b)(5)/DP
JW1559-019410
(b)(5)/DP
JW1559-019411
(b)(5)/DP
JW1559-019412
(b)(5)/DP
JW1559-019413
(b)(5)/DP
JW1559-019414
(b)(5)/DP
JW1559-019415
(b)(5)/DP
JW1559-019416
(b)(5)/DP
JW1559-019417
(b)(5)/DP
JW1559-019418
(b)(5)/DP
JW1559-019419
(b)(5)/DP
JW1559-019420
(b)(5)/DP
JW1559-019421
(b)(5)/DP
JW1559-019422
(b)(5)/DP
JW1559-019423
From:
Williams Floyd L
Sent:
To:
Lerner Lois G; Flax Nikole C; Grant Joseph H; Miller Steven T; Davis Jonathan M (Wash
Cc:
Keith Frank; Norton William G Jr; Landes Scott S; Barre Catherine M
Subject:
RE: Request for Briefing on section 501(c)(4) Application Process
DC); Urban Joseph J; Fish David L
Thank you. I will venture forward.
From: Lerner Lois G
To: Flax Nikole C; Williams Floyd L; Grant Joseph H; Miller Steven T; Davis Jonathan M (Wash DC); Urban Joseph J; Fish
David L
Cc: Keith Frank; Norton William G Jr; Landes Scott S; Barre Catherine M
I can do Friday afternoon.
Lois G. Lerner
From: Flax Nikole C
To: Williams Floyd L; Grant Joseph H; Miller Steven T; Davis Jonathan M (Wash DC); Lerner Lois G; Urban Joseph J; Fish
David L
Cc: Keith Frank; Norton William G Jr; Landes Scott S; Barre Catherine M
Lois - can we do Friday afternoon?
To: Flax Nikole C; Grant Joseph H; Miller Steven T; Dav is Jonathan M (Wash DC); Lerner Lois G; Urban Joseph J; Fish
David L
Lois/Nikole, can you get back to me with some times that might work? It would be nice to knock this
one out during recess week. Thanks.
From: Flax Nikole C
To: Grant Joseph H; Williams Floyd L; Miller Steven T; Davis Jonathan M (Wash DC); Lerner Lois G; Urban Joseph J; Fish
David L
JW1559-019424
Lets coordinate schedules so that I c an attend as well. Thanks
To: Williams Floyd L; Miller Steven T; Davis Jonathan M (Wash DC); Flax Nikole C; Lerner Lois G; Urban Joseph J; Fish
David L
Subject: Re: Request for Briefing on section 501(c)(4) Application Process
Floyd,
We are looking in to it. We need to look at the file before heading up to the Hill. Lois will come to you with some tim es
for next week or early the following week.
Joseph
-------------------------Sent from my BlackBerry Wireless Handheld
David L
I just received a call from Kristina Moore, Senior Counsel to H ouse Committee on Oversight and
of the Subcommittee on Regula tory Affairs, Stimulus, and Government Spending. The specific
respond.
briefing next week?
JW1559-019425
From:
Spellmann Don R
Sent:
To:
Griffin Kenneth M
Subject:
Counsel review of Draft Advocacy Org Guide Sheet
Attachments:
Hi Ken,
I could use help on this (and a new case #). David & Amy have worked advocacy cases. David helped me
today with a quicky review for Lois (advising her it needed work before release). I'm thinking we'll get 3 weeks
tops to review this. Can we touch base Monday?
Thank you.
Don
To: Spellmann Don R
Don,
Thanks,
Holly
Cc: Seto Michael C
Hi Liz and Donna,
Thanks,
Hilary
Hilary Goehausen
Tax Law Specialist
Technical Group 1
JW1559-019426
p: 202.283.8915
f: 202.283.8937
JW1559-019427
(b)(5)/db
JW1559-019428
(b)(5)/db
JW1559-019429
(b)(5)/db
JW1559-019430
(b)(5)/db
JW1559-019431
(b)(5)/db
JW1559-019432
(b)(5)/db
JW1559-019433
(b)(5)/db
JW1559-019434
(b)(5)/db
JW1559-019435
(b)(5)/db
JW1559-019436
(b)(5)/db
JW1559-019437
(b)(5)/db
JW1559-019438
(b)(5)/db
JW1559-019439
From:
Spellmann Don R
Sent:
To:
Marshall David L
Subject:
FW: Draft of Advocacy Org Guide Sheet
Attachments:
To: Spellmann Don R
Don,
Thanks,
Holly
Cc: Seto Michael C
Subject: Draft of Advocacy Org Guide She et
Hi Liz and Donna,
Thanks,
Hilary
Hilary Goehausen
Tax Law Specialist
Technical Group 1
p: 202.283.8915
f: 202.283.8937
JW1559-019440
(b)(5)/db
JW1559-019441
(b)(5)/db
JW1559-019442
(b)(5)/db
JW1559-019443
(b)(5)/db
JW1559-019444
(b)(5)/db
JW1559-019445
(b)(5)/db
JW1559-019446
(b)(5)/db
JW1559-019447
(b)(5)/db
JW1559-019448
(b)(5)/db
JW1559-019449
(b)(5)/db
JW1559-019450
(b)(5)/db
JW1559-019451
(b)(5)/db
JW1559-019452
From:
Flax Nikole C
Sent:
Sunday, October 23, 2011 7:22 PM
To:
Miller Steven T
Subject:
FW: proposed revocation letters going out
I can fill you in more tomorrow if you don't remember which cases these are.
From: Lerner Lois G
To: Grant Joseph H; Medina Moises C
Cc: Flax Nikole C; Fish David L
Subject: FW: proposed revocation letters going out
Just a heads -up. There was some flap i n the press a few months ago because we denied 3 of
these organizations, but had approved others. The approved ones had been done in
Cincy. So, we are notifying them that we are revoking their determination letters. I don't think
they will be surprised, but the process of R & A doing this --while perfectly legit. --isn't often
used.
Lois G. Lerner
From: Fish David L
To: Lerner Lois G
Cc: Paz Holly O; Lowe Justin; Park Nalee; Megosh Andy
Subject: proposed revocation letters going out
5 of 6
6103
letters going out today. For some reason, we did not have one of the administrative files for one of them
and we're getting it.
We're also checki ng to make sure that none of them have entered the exam stream (we had done exam referrals
previously).
JW1559-019453
From:
Eldridge Michelle L
Sent:
To:
Miller Steven T; Flax Nikole C; Grant Joseph H; Lerner Lois G; Lemons Terry L; Keith Frank
Cc:
Zarin Roberta B
Subject:
Politico: C4 and gift tax related inbound
FYI--We have inbound from Politico that is asking a variety of 501c4 issues, including the expected timing around
decisions on gift tax issue.
While I suspect we won't be offering much if anything up beyond Steve's statement --I wanted to give you a chance to
weigh in on this one. FYI --reporter's deadline is tomorrow.
Questions:
Earlier this year, the IRS halted enforcement of a tax on large contributions to nonprofit advocacy groups to study
the issue. Where does the studying of this issue stand, and do you expect that the IRS will come to any conclusions
before elections in November 2012?
How does the IRS, at this point in time, plan to monitor whether 501c4 / c6 organizations political activity this election
cycle does not conflict with the terms of their 501c4 / c6 status?
Has the IRS received any formal complaints this year that specifically involve the po litical activities of 501c4 or c6
organizations, and if so, who has made the complaints and what organizations do the complaints involve?
Earlier this year, the IRS denied 501c4 status to three organizations it deemed too political in nature:
http://taxprof.typepad.com/taxprof_blog/2011/07/irs -denies.html Has the IRS since taken similar action since then in
regard to other organizations seeking 501c4 status?
JW1559-019454
From:
Flax Nikole C
Sent:
Sunday, November 20, 2011 3:25 PM
To:
Miller Steven T; Davis Jonathan M (Wash DC)
Subject:
just so you are aware the EO letter went out friday
Sent: Sunday, November 20, 2011 9:41 AM
To: Ingram Sarah H; Flax Nikole C
Nikole and Sarah,
My changes were small - only substantive change was to clarify - after meeting with
Treasury (Mark Mazur) and RAS (Rosemary Marcuss) - that IRS (TE/GE) would be
reporting out annually on the data called for in 9007. Treasury still owns the 5 year trend
analysis report in 9007.
I do thank you both for your help and patience throughout the process of preparing the
response.
Joseph
Sent: Friday, November 18, 2011 5:37 PM
To: Salins Mary J; Grant Joseph H
Cc: Urban Joseph J; Park Nalee; McNaug hton Mackenzie P; Fish David L
FYI--I delivered it at 2pm.
From: Salins Mary J
Sent: Friday, November 18, 2011 8:36 AM
To: Williams Floyd L; Grant Joseph H
Joseph Grant had a few additional changes, and we incorporated your
cleanups. Attached is an electronic copy of the final letter. We had hoped to have the
signed letter ready for Joseph to bring over this morning when he is at 1111, but we did
not get it ready in time.
However, we will deliver the signed letter to you this morning, so that you can deliver it to
Boustany.
JW1559-019455
Thanks.
Mary Jo Salins
SE:T:EO:RA:G
IRS TE/GE Exempt Organizations Rulings & Agreements
phone (202) 283 -8791
fax (202) 283-9462
Just a very few "cleanup s."
From: Fish David L
From: Fish David L
Floyd,
JW1559-019456
JW1559-019457
From:
Flax Nikole C
Sent:
Monday, November 21, 2011 6:18 PM
To:
Miller Steven T
Subject:
FW: Any Word
fyi
From: Flax Nikole C
To: Lerner Lois G
Cc: Grant Joseph H
Subject: RE: Any Word
I'll check with Steve tomorrow. I know he was looking at the drat you sent.
From: Lerner Lois G
To: Flax Nikole C
Cc: Grant Joseph H
Subject: Any Word
Importance: High
About where we go from here with the c4 stuff and my work plan? I was asked about the work
plan at Loyola and have several additional speeches coming up --would really like to move in
the direction of putting it out.
Lois G. Lerner
JW1559-019458
From:
Flax Nikole C
Sent:
To:
Miller Steven T
Subject:
RE:
I am getting more info, but I think the figures are of two different things.
The 100+ was the number of all political cases (c3, 4, 5, 6).
The 51 is c4 exams (not limited to political, which is low).
To: Flax Nikole C
Subject:
Ok--lets get our facts together...geez
Number of determs and the ever shrinking number of exams. Also a fuller story on the guide sheet
From: Flax Nikole C
To: Miller Steven T
Subject: Re: 501c4 response for AP
Exams.
Sent: Tuesday, February 28, 201 2 08:15 PM
To: Flax Nikole C
Exams or determs?
From: Flax Nikole C
To: Miller Steven T
Subject: RE: 501c4 response f or AP
I had told them to go ahead. btw, Lois says 51 exams in this area. I will attempt to run down the discrepancy.
JW1559-019459
To: Lerner Lois G; Eldridge Mi chelle L; Lemons Terry L; Davis Jonathan M (Wash DC); Flax Nikole C; Keith Frank
Don't wait on me --Nikole has my vote -I may have lost the train of email here but am fine with "otherwise able to
operate..."
------------ -------------Sent using BlackBerry
From: Lerner Lois G
To: Eldridge Michelle L; Miller Steven T; Lemons Terry L; Davis Jonathan M (Wash DC); Flax Nikole C; Keith Frank;
Lemons Terry L
Cc: Burke Anthony; Patterson Dean J
Subject: RE: 501c4 response for AP
Just FYI--I am having a separate discussion with Nikole on this issue but with different
players. I've asked her to get Steve's OK on the redrafted one below, so I think we need to get
that OK before sending out
Lois G. Lerner
From: Eldridge Michelle L
To: Lerner Lois G; Miller Steven T; Lemons Terry L; Davis Jonathan M (Wash DC); Flax Nikole C; Keith Frank; Lemons
Terry L
Yes--I think that is better. Works for us if it works for you. Thanks --Michelle
From: Lerner Lois G
Lemons Terry L
(b)(5)/DP
I think the point Steve was trying to make is -. You
don't get that unless you add the red language.. I don't think the rest of the paragraph does go
(b)(5)/DP
to this. Is says you can
would you be more comfortable if we say:
(b)(5)/DP
Lois G. Lerner
JW1559-019460
To: Lerner Lois G; Miller Steven T; Lemons Terry L; Davis Jonathan M (Wash DC); Flax Nikole C; Keith Frank; Lemons
Terry L
Any chance that we can delete the language at the end -- and just say:
(b)(5)/DP
I am
concerned that the phrase

is a bit challenging for a
(b)(5)/DP
statement. Given the context of the rest of the paragraph, I think the message gets across without it.
(b)(5)/DP
From: Lerner Lois G
Lemons Terry L
Subject: FW: 501c4 response for AP
Importance: High
Let me know if the addition (in bold red) does what you wa nt. I'd like to share this with doc. on
a Congressional coming in through TAS.
Lois G. Lerner
Sent: Monday, February 27, 2012 06:17 PM
To: Miller Steven T; Davis Jonathan M (Wash DC); Lern er Lois G; Grant Joseph H; Flax Nikole C; Keith Frank; Lemons
Terry L; Zarin Roberta B
Subject: FW: 501c4 response for AP
OK--Here is final I'm using. Edits were incorporated. Thanks. --Michelle
(b)(5)/db
(...
JW1559-019461
(b)(5)/db
JW1559-019462
From:
Flax Nikole C
Sent:
To:
Miller Steven T
Subject:
Re: 501c4 status/Cincinatti task force
That could be the effect bc of grades of cases and specialists, but will check about topic.
To: Flax Nikole C
I should just go to bed...I do question whether we have limited the number of specialists who see these cases. We can
discuss.
From: Flax Nikole C
I think
.
(b)(5)/DP
(b)(5)/db
From: Lerner Lois G
To: Flax Nikole C
Subject: FW: 501c4 status/Cincinatti tas k force
JW1559-019463
Sara L. Eguren
IRS Media Relations
From: Janie Lorber [mailto:JanieLorber@rollcall.com ]
To: Eguren Sara L
Sara,
I hear that the IRS Exempt Organizations Division has set up a t ask force to address concerns about 501c4 organizations that
Can you confirm this information? Further detail would also be greatly appreciated. My deadline is noon tomorrow. I can be
reached at 202 650 6834
Thank you,
Janie
-Janie Lorber
Reporter
CQ Roll Call
202 650 6834 (O)
339 206 5812 (C)
www.rollcall.com
---------------------------------------------This e-mail may contain confidential material. If you are not an intended recipient, please notify the sender and delete all copies. It may a lso contain personal
views which are not the views of CQ Roll Call or its owner, The Economist Group. We may monitor e -mail to and from our network. For company information go to
JW1559-019464
From:
Park Nalee
Sent:
To:
Lerner Lois G; McNaughton Mackenzie P; Fish David L; Urban Joseph J
Cc:
Light Sharon P; Letourneau Diane L; Jackson Marshalle C; Megosh Andy; Salins Mary J
Subject:
RE: Boustany Letter
Attachments:
Follow Up Flag:
Follow up
Flag Status:
Completed
Lois,
This is the latest draft, which includes your comments/revisions from yesterday's brief review before you headed out to
meet Nikole. I think we got through 2(g)(i), and I've tracked the changes so you can see the difference from the draft you
handed to Nikole. I'll bring "clean" (e.g. no tracking marks) printed copies tomorrow morning.
NaLee
202.283.9453
From: Lerner Lois G
Sent: Thursday, October 20, 201 1 5:05 PM
To: Park Nalee; McNaughton Mackenzie P; Fish David L
Cc: Light Sharon P; Letourneau Diane L; Jackson Marshalle C
Subject: Boustany Letter
Importance: High
Need to finish going over this Friday as I am out next week --we can do call in if
needed. However, I don't have a copy because I gave mine to Nikole and I believe Nalee took
the other one. Can we try for 11:30 and let me know if we need a call in? Will need a copy-thanks
Lois G. Lerner
JW1559-019465
(b)(5)/DP
JW1559-019466
(b)(5)/DP
JW1559-019467
(b)(5)/DP
JW1559-019468
(b)(5)/DP
JW1559-019469
(b)(5)/DP
JW1559-019470
(b)(5)/DP
JW1559-019471
(b)(5)/DP
JW1559-019472
(b)(5)/DP
JW1559-019473
(b)(5)/DP
JW1559-019474
(b)(5)/DP
JW1559-019475
(b)(5)/DP
JW1559-019476
(b)(5)/DP
JW1559-019477
(b)(5)/DP
JW1559-019478
(b)(5)/DP
JW1559-019479
(b)(5)/DP
JW1559-019480
(b)(5)/DP
JW1559-019481
From:
Salins Mary J
Sent:
Monday, October 31, 2011 7:32 AM
To:
Park Nalee; McNaughton Mackenzie P
Subject:
W&M request
Attachments:
Boustany v8 10-28-2011 (2).mjs.clean.DOC; what else??? (6.45 KB)
FYI, here is the version I sent forward to Nicole on Friday for weekend reading, which includes the changes from
comments Lois gave us on Friday, that Lois said was ok to forward to her.
We are supposed to get final ready today.
We still have to consider Joe Urban's comments that he gave me late Friday afternoon about response regarding the
Exam referral on political campaign intervention.

Urban's comments).
(Mackenzie, see copy of email sent to Nalee on Friday regarding
And, we have to finalize the tax shelter response.
Anything else we need to finalize that I am forgetting?
Thanks for all your work on this.
mj
Mary Jo Salins
(202) 283-8791
From: Salins Mary J
To: Flax Nikole C
Cc: Fish David L
Subject: FW: the other EO W&M request
I am acting for David Fish as EO Guidance Manager while he is acting as Acting Director of Rulings and Agreements
while Holly Paz is on maternity leave.
Attached is our latest draft of the letter in electronic format.
It has been updated since the version you received from Lois.
We hope to get you a final version by COB Monday.
Mary Jo Salins
TE/GE Exempt Organizations Rulings & Agreements
1750 Penn. Ave., NW, Wash., DC
phone (202) 283 -8791
fax (202) 283 -9462
_________________________________________________________________________________________________
_______________________________________
JW1559-019482
Yes. Let her know it has been updated since I gave it to her and we're still working with expectations
of getting her a final by COB Mon
From: Fish David L
To: Lerner Lois G; Salins Mary J
Subject: Fw: the other EO W&M request
Should we give her latest ver.?
From: Flax Nikole C
To: Fish David L
Subject: the other EO W&M request
Lois handed me a paper copy - do you have an electronic copy of the response that you could send (just the
letter)? Thanks
JW1559-019483
(b)(5)/DP
JW1559-019484
(b)(5)/DP
JW1559-019485
(b)(5)/DP
JW1559-019486
(b)(5)/DP
JW1559-019487
(b)(5)/DP
JW1559-019488
(b)(5)/DP
JW1559-019489
(b)(5)/DP
JW1559-019490
(b)(5)/DP
JW1559-019491
(b)(5)/DP
JW1559-019492
(b)(5)/DP
JW1559-019493
(b)(5)/DP
JW1559-019494
(b)(5)/DP
JW1559-019495
(b)(5)/DP
JW1559-019496
(b)(5)/DP
JW1559-019497
(b)(5)/DP
JW1559-019498
(b)(5)/DP
JW1559-019499
Image not available for this document
JW1559-019500
From:
Park Nalee
Sent:
Monday, October 31, 2011 8:41 AM
To:
Salins Mary J; McNaughton Mackenzie P
Subject:
RE: W&M request
Attachments:
My computer finally works - it's taken 2 hrs!
Anyway, attached are some of the changes I've made to address Joe's and Mary Jo's comments from Friday
- they are
highlighted.
Mary Jo - this e-copy is the same as the printed copy I dropped off a little while ago.
Mackenzie - see what you think about the referral language on page 12.
I looked over one of the Camp letters again, and
I think it touches on similar points. Feel free to change as necessary.
Thanks,
NaLee
202.283.9453
From: Salins Mary J
Sent: Monday, October 31, 2011 8:32 AM
To: Park Nalee; McNaughton Mackenzie P
Subject: W&M request
FYI, here is the version I sent forward to Nicole on Friday for weekend reading, which inc ludes the changes from
comments Lois gave us on Friday, that Lois said was ok to forward to her.
We are supposed to get final ready today.
We still have to consider Joe Urban's comments that he gave me late Friday afternoon about response regarding
Exam referral on political campaign intervention.
Urban's comments).
the
(Mackenzie, see copy of email sent to Nalee on Friday regarding
And, we have to finalize the tax shelter response.
Anything else we need to finalize that I am forgetting?
Thanks for all your work on this.
mj
Mary Jo Salins
(202) 283-8791
From: Salins Mary J
To: Flax Nikole C
JW1559-019501
Cc: Fish David L
Subject: FW: the other EO W&M request
I am acting for David Fish as EO Guidance Manager while he is acting as Acting Director of Rulings and Agreements
while Holly Paz is on maternity leave.
Attached is our latest draft of the letter in electronic format.
It has been updated since the version you received from Lois.
We hope to get you a final version by COB Monday.
Mary Jo Salins
TE/GE Exempt Organizations Rulings & Agreements
1750 Penn. Ave., NW, Wash., DC
phone (202) 283 -8791
fax (202) 283 -9462
_________________________________________________________________________________________________
_______________________________________
Yes. Let her know it has been updated since I gave it to her and we're still working with expectations
of getting her a final by COB Mon
From: Fish David L
To: Lerner Lois G; Salins Mary J
Subject: Fw: the other EO W&M request
Should we give her latest ver.?
From: Flax Nikole C
To: Fish David L
Subject: the other EO W&M request
Lois handed me a paper copy - do you have an electronic copy of the response that you could send (just the
letter)? Thanks
JW1559-019502
(b)(5)/DP
JW1559-019503
(b)(5)/DP
JW1559-019504
(b)(5)/DP
JW1559-019505
(b)(5)/DP
JW1559-019506
(b)(5)/DP
JW1559-019507
(b)(5)/DP
JW1559-019508
(b)(5)/DP
JW1559-019509
(b)(5)/DP
JW1559-019510
(b)(5)/DP
JW1559-019511
(b)(5)/DP
JW1559-019512
(b)(5)/DP
JW1559-019513
(b)(5)/DP
JW1559-019514
(b)(5)/DP
JW1559-019515
(b)(5)/DP
JW1559-019516
(b)(5)/DP
JW1559-019517
(b)(5)/DP
JW1559-019518
From:
Park Nalee
Sent:
Tuesday, November 01, 2011 8:33 AM
To:
Lerner Lois G
Cc:
White Shirley A; Downing Nanette M; Fish David L; Salins Mary J; Urban Joseph J;
Subject:
congressional
Attachments:
Lois,
Attached is an e-copy of the latest congressional draft, including changes to Q.5(b)(iv) re: tax shelter reporting.
W e gave
two printed copies of this same draft with the exhibits to Shirley.
Thanks,
NaLee
NaLee Park
R&A, EO Guidance Group 2
TEGE, Washington D.C.
(t) 202.283.9453 | (f) 202.283.9462
JW1559-019519
(b)(5)/DP
JW1559-019520
(b)(5)/DP
JW1559-019521
(b)(5)/DP
JW1559-019522
(b)(5)/DP
JW1559-019523
(b)(5)/DP
JW1559-019524
(b)(5)/DP
JW1559-019525
(b)(5)/DP
JW1559-019526
(b)(5)/DP
JW1559-019527
(b)(5)/DP
JW1559-019528
(b)(5)/DP
JW1559-019529
(b)(5)/DP
JW1559-019530
(b)(5)/DP
JW1559-019531
(b)(5)/DP
JW1559-019532
(b)(5)/DP
JW1559-019533
(b)(5)/DP
JW1559-019534
(b)(5)/DP
JW1559-019535
(b)(5)/DP
JW1559-019536
From:
Clarke Stephen M
Sent:
To:
Park Nalee
Subject:
RE: Congressional v8 11-01-2011 clean.DOC
Attachments:
Boustany Sch H comments.doc
Follow Up Flag:
Follow up
Flag Status:
Completed
Nalee,
In response to Nicole's request to address the 2010 Sch. H, I'd suggest the following paragraph, which I've also inserted
in the attached document:
(b)(5)/DP; non-responsive
From: Park Nalee
Sent: Thursday, November 03, 2011 9:43 AM
To: Clarke Stephen M
Subject: FW: Congressional v8 11-01-2011 clean.DOC
Here's a copy with Nikole's comments for 2(a) and (b).
Do you think you can also answer her comment to 2(c)?
Thanks!
NaLee
202.283.9453
From: Lerner Lois G
Sent: Thursday, November 03, 2011 8:44 AM
To: Park Nalee; Fish David L
Subject: Fw: Congressional v8 11 -01-2011 clean.DOC
Couldn't pull up mary Jo on Outlook. Please start looking at comments so we can talk when I get in. Thanks
JW1559-019537
From: Flax Nikole C
Sent: Wednesday, November 02, 2011 11:01 PM
To: Lerner Lois G
Subject: FW: Congression al v8 11-01-2011 clean.DOC
Lois - I worked Steve's comments in the comment boxes. His overall comment was whether we can give them a bit more
detail in some places. W e don't have to change much, but if there are places that you see that we could beef up the
responses a bit, we should. Let me know if you have any questions. I think he is fine for Joseph to sign when you guys
are ready. Thanks
From: Lerner Lois G
Sent: Tuesday, November 01, 2011 5:33 PM
To: Flax Nikole C
Subject: Congressional v8 11-01-2011 clean.DOC
Here is the latest draft --they are incorporating my comments re OTSA stuff and changing to
reflect is coming from Joseph. otherwise, we are done, so please let me know where STM
wants changes.
JW1559-019538
(b)(5)/DP
JW1559-019539
(b)(5)/DP
JW1559-019540
(b)(5)/DP
JW1559-019541
(b)(5)/DP
JW1559-019542
(b)(5)/DP
JW1559-019543
(b)(5)/DP
JW1559-019544
(b)(5)/DP
JW1559-019545
(b)(5)/DP
JW1559-019546
(b)(5)/DP
JW1559-019547
(b)(5)/DP
JW1559-019548
(b)(5)/DP
JW1559-019549
(b)(5)/DP
JW1559-019550
(b)(5)/DP
JW1559-019551
(b)(5)/DP
JW1559-019552
(b)(5)/DP
JW1559-019553
(b)(5)/DP
JW1559-019554
(b)(5)/DP
JW1559-019555
From:
Park Nalee
Sent:
To:
Lerner Lois G
Cc:
Letourneau Diane L; Salins Mary J; McNaughton Mackenzie P
Subject:
Boustany congressional
Attachments:
Lois,
Attached is the revised congressional letter. Please note the changes beginning at the bottom of page 10 for questions
2(g)(ii) and (iii) re:
(b)(5)/DP
Also, below is an email draft to Nikole (for you to amend as you please) regarding the latest draft and responding to her
comments.
NaLee
202.283.9453
__________________
Nikole,
Attached is the revised dra ft of the Boustany letter. We've added substantial details to the responses per your/STM's
comments, except for the following:
Page 2, Question 1(c) - Regarding the first comment (identified as [NCF1]) on obtaining FY 2011 numbers:
(b)(5)/DP
Page 13, Q.3(c)(iv) - Regarding comment [NCF6], the PIC code "38:
(b)(5)/DP
Page 16-17, Q. 5(b)(iv) - Regarding comment [NCF9] on obtaining the results of tax shelter
audit/examinations: We reached out to OSP for clarification and confirmation on the ERIS exam results/data
OTSA provided, and there's some discrepancy. We'll need more time with OSP and OTSA to reconcile the data if
Boustany's office pushes on this issue.
(b)(5)/DP
, so I decided to leave this response as is.
I believe this covers all the comments. Please let me know if there are any questions.
JW1559-019556
(b)(5)/DP
JW1559-019557
(b)(5)/DP
JW1559-019558
(b)(5)/DP
JW1559-019559
(b)(5)/DP
JW1559-019560
(b)(5)/DP
JW1559-019561
(b)(5)/DP
JW1559-019562
(b)(5)/DP
JW1559-019563
(b)(5)/DP
JW1559-019564
(b)(5)/DP
JW1559-019565
(b)(5)/DP
JW1559-019566
(b)(5)/DP
JW1559-019567
(b)(5)/DP
JW1559-019568
(b)(5)/DP
JW1559-019569
(b)(5)/DP
JW1559-019570
(b)(5)/DP
JW1559-019571
(b)(5)/DP
JW1559-019572
(b)(5)/DP
JW1559-019573
(b)(5)/DP
JW1559-019574
(b)(5)/DP
JW1559-019575
From:
Park Nalee
Sent:
To:
Salins Mary J
Subject:
RE: Chairman Boustany's Oct. 6th letter
Attachments:
Boustany v9 11-17-2011 final w Legis Aff.DOC
Just in case...if Joseph decides he wants to incorporate Floyd's changes and sign a new draft tomorrow morning before
handing it over to Floyd...
Also, FYI - if you end up needing them: I think I left the extra cover letter paper with the TEGE Commissioner header (for
the first/cover page) on my desk to the left (between the large file cabinet and rest of the desk) with the yellow printer
paper.
NaLee
202.283.9453
From: Fish David L
From: Fish David L
To: Salins Mary J; Park Nalee; McNaughton Mackenzie P
JW1559-019576
Floyd,
JW1559-019577
(b)(5)/DP
JW1559-019578
(b)(5)/DP
JW1559-019579
(b)(5)/DP
JW1559-019580
(b)(5)/DP
JW1559-019581
(b)(5)/DP
JW1559-019582
(b)(5)/DP
JW1559-019583
(b)(5)/DP
JW1559-019584
(b)(5)/DP
JW1559-019585
(b)(5)/DP
JW1559-019586
(b)(5)/DP
JW1559-019587
(b)(5)/DP
JW1559-019588
(b)(5)/DP
JW1559-019589
(b)(5)/DP
JW1559-019590
(b)(5)/DP
JW1559-019591
(b)(5)/DP
JW1559-019592
(b)(5)/DP
JW1559-019593
(b)(5)/DP
JW1559-019594
(b)(5)/DP
JW1559-019595
(b)(5)/DP
JW1559-019596
From:
Sent:
Tuesday, October 18, 2011 11:25 AM
To:
Park Nalee; Urban Joseph J; Fish David L; Hubert Linda K; Light Sharon P; Kindell Judith
Cc:
Letourneau Diane L; Dinkins Celestine M
Subject:
Updated Boustany response
Attachments:
SOI TEGE Royalty+Rent (2).xls; Boustany v2.DOC; PIC Codes All Returns FY 2008-2011
E; Lerner Lois G; Megosh Andy; Kall Jason C; Ghougasian Laurice A; Paz Holly O
10.18.11.xls; Q1.a Don Evans data.xls; Q1.b R. Hall data.xls
For those calling in, attached is the latest draft of the response letter and applicable attachments.
Mackenzie P. McNaughton
Tax Law Specialist
TE/GE, Exempt Organizations
Rulings and Agreements (Technical), Group 4
SE:T:EO:RA:T:4
Phone: 202-283-9484
Fax: 202-283-9462
JW1559-019597
(b)(5)/DP
JW1559-019598
(b)(5)/DP
JW1559-019599
(b)(5)/DP
JW1559-019600
(b)(5)/DP
JW1559-019601
(b)(5)/DP
JW1559-019602
(b)(5)/DP
JW1559-019603
(b)(5)/DP
JW1559-019604
(b)(5)/DP
JW1559-019605
(b)(5)/DP
JW1559-019606
(b)(5)/DP
JW1559-019607
(b)(5)/DP
JW1559-019608
(b)(5)/DP
JW1559-019609
(b)(5)/DP
JW1559-019610
(b)(5)/DP
JW1559-019611
(b)(5)/DP
JW1559-019612
(b)(5)/DP
JW1559-019613
(b)(5)/DP
JW1559-019614
(b)(5)/DP
JW1559-019615
(b)(5)/DP
JW1559-019616
(b)(5)/DP
JW1559-019617
PIC Codes - All Returns Closed FY 2008 - FY 2011
Arranged in Descending Order of Number of Total Occurrences by PIC Code
PIC Description
PIC
42
83
39
21
34
78
65
5
57
79
82
22
95
33
40
19
45
18
2
56
38
80
68
35
24
12
14
54
67
13
48
26
1
92
94
25
6
30
88
36
20
32
27
58
41
47
31
85
90
44
49
23
89
3
17
29
59
81
84
46
4
10
8
61
37
62
Delinquent 940/941 Returns

Employment Tax - Other Issues
Delinquent 990/990-EZ Returns
Operational Test
Other
Employment Tax - Worker Classification Issues
Claim for Refund
Delinquent Filing of Return (Other)
Gaming - Pull Tabs
Employment Tax - 1099 Issues
Employment Tax - Fringe Benefit Issues
Organizational Test
Filing Requirement Issues
UBI
Delinquent 990-T Returns
Package Audit Procedures
Excise Tax - Gaming
Non-Exempt Activities
Business with Non-Members
Gaming - Bingo
UBI - Other
Employment Tax - Backup Withholding
Penalty for Failure to File Return
UBI - Expense Allocation Issues
Non Operating for Exempt Purpose
Inadequate Records
Inurement
Revocation
Excess Benefit Transaction Under IRC 4958
Incomplete Returns
Excise Tax - 4958
Private Foundation Status
Advertising Income
Discrepancy Adjustments
Private Benefit
Political Activities
Discontinued Operations
Self Dealing
Adjustment to a Related Return
UBI - NOL Adjustment
Operating in a Commercial Manner
Tax on Investment Income
Private vs Public Interests
Gaming - Other
Delinquent 990-PF Returns
Excise Tax - Self Dealing
Taxable Expenditures
Revocation - Inurement
Change in Subsection
Delinquent 4720 Returns
Excise Tax - Other
Particular Services for Members
Accounting Method Errors
Deductibility of Contributions/Dues
Legislative Activities
Rental Income from Debt-Financed Property
Investment Income Issues
Employment Tax - Nonresident Alien Issues
FICA Claims
Excise Tax - Failure to Distribute
Donor Advised Funds
Failure to Distribute
Governing Body & Management, Size of Governing Body
Foreign Charitable Activities
UBI - Income from Controlled Corp
Captive Offshore Insurance Issues
# Occurrences
Occurrences
Occurrences
# Occurrences
Total
as PIC 1
as PIC 2
as PIC 3
as PIC 4
Occurrences
7493
3176
2931
2018
1796
2069
2689
1708
294
741
1244
211
227
673
733
927
613
756
1081
320
502
334
115
380
240
446
545
736
408
278
466
349
466
377
145
495
373
334
118
130
124
162
81
77
179
125
99
125
88
60
74
60
38
92
43
55
37
69
77
44
62
64
49
21
16
12
896
1713
544
977
524
540
70
390
648
947
422
1282
456
560
646
559
734
461
192
646
471
458
456
477
511
285
243
26
207
265
146
130
84
144
171
45
120
128
169
151
166
159
161
85
65
89
128
83
22
82
49
77
25
16
73
60
65
39
23
43
26
20
17
8
14
36
225
665
266
449
477
283
26
142
1029
412
278
384
757
498
283
227
127
177
99
347
236
353
263
227
312
231
172
34
118
112
80
126
62
70
166
21
57
53
98
106
94
60
88
100
31
40
26
40
19
43
53
35
60
20
30
17
25
11
5
6
5
3
8
31
19
0
92
310
73
205
317
157
3
76
308
159
114
133
476
134
145
84
61
63
30
76
112
88
329
62
62
46
33
23
37
79
16
31
19
16
96
11
18
12
116
35
33
17
42
41
7
25
17
18
79
17
15
13
41
23
5
12
7
0
1
9
7
1
1
8
6
0
8706
5864
3814
3649
3114
3049
2788
2316
2279
2259
2058
2010
1916
1865
1807
1797
1535
1457
1402
1389
1321
1233
1163
1146
1125
1008
993
819
770
734
708
636
631
607
578
572
568
527
501
422
417
398
372
303
282
279
270
266
208
202
191
185
164
151
151
144
134
119
106
102
100
88
75
68
55
48
JW1559-019618
73 Approved Church Examination

15 Jeopardy Investments
96 8871/8872 Reporting Requirements
28 Public Information Not Reported 501(c)(3)
43 Delinquent 1120-POL
91 Rev. Proc. 75-50
60 Failure to Properly Report Fundraising
66 Lack of Financial Oversight by Governing Body
11 Grassroots Lobbying
75 Unpostable
86 Proxy Tax
9 Excess Business Holdings
77 Employment Tax - Student FICA Issues
53 Chapter 42 - Under Tolerance
63 Foreign Grants
74 Non-Cash Donation Solicitations
93 Tax Shelter Issues
16 IRC 4962 Abatements
70 Penalty for Failure to Make Annual Return Available
55 Gaming - Casino
72 Personal Benefits Contracts
71 Penalty for failure to Make Exemption Application Available
76 Car/Boat Donation Solicitations
7 Discrimination
69 Penalty for Failure to Fully Complete Return
50 Organizational Control - Family Board
64 120 Percent of Economic Life Maturity
51 Process for Determining Executive Compensation - Faulty
87 Health Maintenance Organization - Insurance Tax
blank (or 00)
37
20
27
12
17
8
12
26
20
18
8
25
24
12
4
8
4
14
3
8
4
3
3
5
0
1
2
1
0
0
5
19
11
18
11
11
9
4
11
11
12
7
4
7
7
4
7
2
10
2
2
4
1
2
4
0
0
0
0
21486
1
6
1
10
9
11
8
5
2
4
7
0
0
1
8
8
6
2
4
3
7
3
2
1
4
1
0
0
1
30164
3
0
5
3
2
8
6
0
1
1
7
1
2
2
3
1
3
0
0
2
0
2
4
0
0
1
0
0
0
36437
46
45
44
43
39
38
35
35
34
34
34
33
30
22
22
21
20
18
17
15
13
12
10
88087
Total
41196
41196
41196
41196
164784
Total Returns Closed - FY 2011

11699
11449
10187
7861
Total for 4 Years
41196
JW1559-019619
Curr
Cd
(*)
Curr Subsect
CdStatus COUNT
0
1144511
1
20
0
6
294
0
0
7
4018
10
47
0
11
3438
0
12
19
0
20
7237
0
22
10
0
23
40
0
24
54
0
26
228
0
0
28
185
29
1
0
30
2487
0
0
31
14039
35
19
0
36
5
0
40
13740
0
41
57831
0
42
23244
0
70
158
0
71
1111
0
72
8
0
0
97
5228
99
2971
0
1
157
1
1
20
14
22
1
1
26
1
1
28
7
1
29
6
1
36
69
1
70
1
1
71
3
1
1
97
14
1
4710
2
2
15
2
20
3168
2
21
46
2
2
22
44
23
1
2
26
48
2
28
80
2
29
2
2
32
31
2
2
34
1
36
334
2
40
1
2
42
2
2
70
63
Sum of COUNT (*)

Curr Subsect Cd
Curr Status Cd
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
40
50
60
70
71
80
81
82
90
91
92
93
(blank)
Grand Total
1
20
157
4710
1068044
90805
48812
65320
48296
52687
7425
16053
7
5197
8635
2716
920
13
141
32605
5
28
15
540
45
27
50
109
24
121
35
867
10
11
220
10
948
1
359
408
97
61
1455601
984
JW1559-019620
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
71
72
97
99
1
2
6
7
10
11
12
19
20
21
22
23
24
25
26
28
29
30
31
32
34
40
41
42
70
71
72
97
98
99
1
2
6
7
10
12
20
21
22
23
25
26
28
29
31
32
34
36
356
2139
1068044
540
15
26
26
26
256
184031
6314
1644
41
224
1284
5781
142975
3128
103
1856
71
44
235
3375
64997
319
246953
910
90805
45
19877
492
240
1067
61059
688
167
5827
JW1559-019621
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
40
41
42
70
71
72
97
99
1
2
6
7
20
21
22
24
25
26
28
29
32
34
36
40
42
70
71
72
97
99
1
2
6
10
12
19
20
21
22
23
25
26
28
29
31
32
34
36
40
41
42
70
18
877
4137
17
43744
23
48812
27
4369
148
29
4635
53772
1138
33
2430
115
447
11695
65320
50
14933
341
171
455
13653
945
123
4201
22
940
JW1559-019622
6
6
6
6
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
9
9
9
9
9
9
9
71
72
97
99
1
2
6
10
12
20
21
22
23
24
25
26
28
29
31
32
34
36
41
42
70
71
72
97
99
1
12
20
21
22
25
26
28
29
32
36
42
70
71
97
99
1
2
12
20
21
22
23
2725
12
24775
23
48296
109
10928
333
617
171
14061
353
115
8622
19
794
4487
37
26172
30
52687
1396
165
829
4053
90088
1193
666
68
144
10135
7425
24
13824
144
39
JW1559-019623
9
9
9
9
9
9
9
9
9
9
9
9
9
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
11
11
11
11
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
26
28
29
31
32
36
40
42
70
71
72
97
99
1
2
20
21
22
25
26
28
29
32
36
40
70
71
72
97
99
1
20
36
97
1
2
12
20
21
22
26
28
32
34
36
41
42
70
71
72
97
99
209
538
45
552
1949
10
3929
16
16053
347
54
16
979
9820
400
646
34
266
1752
5197
121
1437
16
15
38
312
96
447
1456
JW1559-019624
13
13
13
13
13
13
13
13
13
13
13
13
13
13
13
13
14
14
14
14
14
14
14
14
14
14
14
14
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
16
16
16
16
16
16
16
16
1
2
6
12
20
21
22
26
28
32
36
42
70
71
72
97
1
20
21
26
28
29
36
40
42
70
71
97
1
2
12
20
22
26
28
31
36
40
42
70
71
72
97
99
1
2
20
22
28
36
70
97
8635
35
1023
22
12
11
1150
26
257
3002
2716
756
1242
4182
95
277
547
920
1286
105
19
167
43
179
16
684
13
11
JW1559-019625
17
17
17
17
17
17
17
17
17
17
17
18
18
18
18
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
20
20
20
20
20
20
20
20
21
21
22
22
22
23
23
24
24
24
24
1
20
21
26
28
32
70
71
72
97
99
1
20
28
36
1
2
11
12
20
21
22
26
28
29
31
32
36
42
70
71
97
99
1
20
21
22
26
70
71
97
1
71
36
71
97
1
36
1
20
36
42
141
609
267
32605
624
79
124
427
12778
57
11
1294
206
8254
137
23
28
JW1559-019626
25
25
25
25
25
25
25
25
25
25
25
26
26
26
27
27
27
28
40
40
40
40
40
40
40
40
50
50
50
50
50
50
60
60
60
70
70
70
71
80
80
80
80
80
80
80
80
80
80
80
80
80
1
20
21
25
26
32
36
42
70
71
97
1
36
97
1
36
97
36
1
2
20
22
36
70
71
97
1
20
22
70
71
97
1
28
71
20
36
97
1
1
2
12
20
21
22
26
31
36
40
41
42
70
867
1419
47
29
197
10
11
220
16
10
44
23
12
948
32
1600
10
66
34
16
20
JW1559-019627
80
80
81
82
82
82
82
82
82
82
82
82
82
82
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
91
91
91
91
91
91
91
91
91
91
91
91
92
92
92
92
71
97
1
1
12
20
23
24
26
30
34
41
42
97
1
6
7
10
11
12
19
20
21
22
23
24
26
30
34
36
40
41
42
70
71
99
1
12
20
21
22
28
36
40
41
70
71
99
1
12
18
20
89
227
11
1664
26262
359
11
11
17
121536
17
84246
3736
25
408
1673
1135
300
97
6133
2452
JW1559-019628
92
92
92
92
92
92
92
92
93
93
93
93
93
93
93
93
21
22
24
26
36
40
41
42
1
11
12
20
21
22
26
97
144
10
11
61
2366
2631
77
JW1559-019629
6
294
15
3
1
5
2
7
4018
26
2
1
10
47
11
3438
12
19
26
1
26
256
1
1
32
11
332
4049
11
87
11
121536
1673
6133
2366
3483
132059
17
JW1559-019630
JW1559-019631
JW1559-019632
JW1559-019633
JW1559-019634
JW1559-019635
JW1559-019636
JW1559-019637
JW1559-019638
JW1559-019639
18
19
20
7237
14
3168
184031
19877
4369
14933
10928
1396
13824
347
3
1437
1023
756
1286
11
609
3
624
137
1419
21
46
6314
492
148
341
333
165
144
54
16
22
2
22
10
44
1644
240
29
171
617
829
39
16
15
12
105
79
1
124
16
44
2
1600
17
1
23
1664
84246
1135
2452
2631
361223
10
66
3736
300
144
6
12360
3987
JW1559-019640
JW1559-019641
JW1559-019642
JW1559-019643
JW1559-019644
JW1559-019645
JW1559-019646
JW1559-019647
JW1559-019648
JW1559-019649
23
40
24
54
25
1
41
3
224
1284
3
6
1
4
5
2
1
2
1
3
26
228
1
48
5781
1067
4635
455
171
4053
209
979
28
185
80
142975
61059
53772
13653
14061
90088
538
9820
38
9
1242
19
4182
12778
7
427
1
34
1
1
1
4
91
288
1307
19428
403216
JW1559-019650
JW1559-019651
JW1559-019652
JW1559-019653
JW1559-019654
JW1559-019655
JW1559-019656
JW1559-019657
JW1559-019658
JW1559-019659
29
1
6
2
3128
688
1138
945
353
1193
3
400
30
2487
31
14039
103
6
3
5
2
32
34
31
1856
167
33
123
115
3
45
5
11
95
57
11
26262
1
1
8009
2493
14163
2409
26286
JW1559-019660
JW1559-019661
JW1559-019662
JW1559-019663
JW1559-019664
JW1559-019665
JW1559-019666
JW1559-019667
JW1559-019668
JW1559-019669
35
19
36
5
69
334
5827
2430
4201
8622
666
1
646
6
312
1150
277
167
6
40
13740
1
71
4
1
2
41
57831
44
4
2
4
2
1
1
2
1
1294
42
23244
235
18
22
19
1
47
3
19
16
1
6
2
3
1
7
1
5
1
10
25
26088
13840
57908
11
23625
JW1559-019670
JW1559-019671
JW1559-019672
JW1559-019673
JW1559-019674
JW1559-019675
JW1559-019676
JW1559-019677
JW1559-019678
JW1559-019679
70
158
1
63
3375
877
115
940
794
68
552
34
71
1111
3
356
64997
4137
447
2725
4487
144
1949
266
96
26
2
43
1
1
447
257
4
179
16
9
4
1
1
72
8
1
319
17
5
12
37
10
1
3
4
97
5228
14
2139
246953
43744
11695
24775
26172
10135
3929
1752
1456
3002
547
684
267
206
8
2
8254
23
29
197
98
9
5
1
23
12
20
89
227
1
1
77
7192
81869
434
391332
JW1559-019680
JW1559-019681
JW1559-019682
JW1559-019683
JW1559-019684
JW1559-019685
JW1559-019686
JW1559-019687
JW1559-019688
JW1559-019689
99 (blank)
2971
1144511
8
910
23
3
23
30
3
16
5
1
5
1
3
1
2
4005
1144511
Grand Total
1280943
273
11050
1733237
229126
127677
128711
115168
161440
28725
30383
21
9161
14192
9827
3437
42
1041
10
56481
184
30
2580
15
14
254
84
16
3059
27963
210003
3533
8863
5149
4202711
JW1559-019690
SOI-Masterfile
SOI-Databook
RICS-Entity Table
SOI Tax Stats - Exempt Organizations: IRS Master File Data

http://www.irs.gov/taxstats/charitablestats/article/0,,id=97186,00.html
These are summary numbers from the regions at the bottom of the website
SOI-Filings Data Exempt_Organization_Status_Code
subsection
1
2
12
25 Total
Subsection Code Description

0
20 .
19 .
39
Instrumentalities (government agencies)

501(c)(1)
1
149 .
.
.
149
Title holding corporations (single parent)
501(c)(2)
2
4,710
15 .
.
4,725
501(c)(3)
3 1,064,843
543
255
1,277 1,066,918
Charitable organizations
Civic leagues, social welfare
501(c)(4)
4
90,238
46
8
3
90,295
Labor unions, agricultural organizations
501(c)(5)
5
48,808
27 .
6
48,841
501(c)(6)
6
65,100
50
5
1
65,156
Business leagues
Social clubs
501(c)(7)
7
48,068
110
3
4
48,185
Fraternal beneficiary societies (providing insurance benefits)
501(c)(8)
8
52,387 .
3
5
52,395
501(c)(9)
9
7,314
24
4.
7,342
Voluntary employees beneficiary associations
Fraternal organizations (no insurance benefits)
501(c)(10)
10
15,963
3.
3
15,969
Teachers retirement fund association
501(c)(11)
11
7.
.
.
7
501(c)(12)
12
5,175
121
5.
5,301
Electric & water cooperatives
Cemetery associations
501(c)(13)
13
8,577
35
2.
8,614
Credit unions
501(c)(14)
14
2,726 .
.
.
2,726
Small insurance companies
501(c)(15)
15
914
3
1.
918
501(c)(16)
16
13
1.
.
14
Crop financing corporations

Supplemental unemployment compensation trust
501(c)(17)
17
137 .
.
.
137
Employee funded pension trust
501(c)(18)
18
2.
.
.
2
War veterans organization

501(c)(19)
19
32,233
4
1.
32,238
501(c)(20)
20
6.
.
.
6
Prepaid legal services

Black lung trusts
501(c)(21)
21
28 .
.
.
28
Multiemployer pension plans

501(c)(22)
501(c)(23)
23
3.
.
.
3
Pre-1880 veterans association

ERISA section 4049 trust
501(c)(24)
24
1.
.
.
1
Title holding corporation or trust (multi-parent)

501(c)(25)
25
867 .
.
1
868
501(c)(26)
26
10 .
.
.
10
State-sponsored high-risk health insurance organization

State-sponsored workers' compensation reinsurance
501(c)(27)
27
10 .
.
.
10
National Railroad Retirement

501(c)(28)
Apostolic organization
501(d)
40
218
1.
.
219
501(e)
50
11 .
.
.
11
Cooperative hospital service organization - treated as 501(c)(3)
Cooperative service organization of operating educational organization501(f)
- treated as 501(c)(3)
60
1.
.
.
1
Child care under 501(k) - treated as 501(c)(3)
501(k)
501(n)
71
1.
.
.
1
Charitable risk pool - treated as 501(c)(3)
Farmers' cooperative (exempt)
521
Qualified state-sponsored tuition program
529
81
1.
.
.
1
527
82
4.
11 .
15
Political organization
Split-interest trust
4947(a)(2)
90
356 .
120,330 .
120,686
NECT filing 990

4947(a)(1)
91
407 .
1,655 .
2,062
4947(a)(1)
92
97 .
6,042 .
6,139
NECT filing 990-PF

Farmers' cooperative
0
Total
1,449,405
983
128,344
1,300 1,580,032
IRS Data Book
Table 25
http://www.irs.gov/taxstats/article/0,,id=207455,00.html
2010
168
7,239
1,280,739
139,129
63,012
92,331
79,718
63,391
11,749
18,310
6,996
12,266
3,570
1,812
423
39,709
1,125
218
34
14
1,960,203
JW1559-019691
irs.gov/taxstats/article/0,,id=207455,00.html
RICS-Entity Table
1
2
6
7
Curr Subsect Cd
0
20
294 4,018
1
157
2
4,710 15
26
3 1,068,044 540 15
4
90,805 45
3
2
5
48,812 27
1
1
65,320 50
5
6
7
48,296 109
2
8
52,687
7,425 24
9
10
16,053
3
11
7
5,197 121
12
13
8,635 35
1
14
2,716
15
920
3
13
1
16
17
141
18
2
19
32,605
4
5
20
21
28
22
3
23
24
1
25
867
10
26
27
11
28
40
220
1
10
50
60
1
70
1
71
80
948
6
81
1
5
82
90
359
11
2
91
408
97
92
93
61
(blank)
Grand Total
1,455,601 984 332 4,049
10
11
47 3,438
26
1
26
1
1
12 18 19
19
20
7,237
14
3,168
5 184,031
19,877
4,369
1 14,933
10,928
1,396
13,824
347
3
1,437
1,023
756
1,286
11
609
3
624
137
256
9
5
3
3
4
5
2
1
1
1,419
21
46
6,314
492
148
341
333
165
144
54
16
22
2
22 23 24
25
10 40 54
1
44 1
1,644 41 224 1,284
240 3
3
29
2
6
171 1
1
617 2
1
4
829
5
39 1
16
3
15
12
38
9
1,242
19
105
1
3
79
1
7
124
5
427
1
16
44
Curr Status Cd
26
28
29
30
31
32
228
185
1 2,487 14,039
1
7
6
48
80
2
31
5,781 142,975 3,128
4
103 1,856
1,067 61,059 688
6 167
4,635 53,772 1,138
33
455 13,653 945
3 123
171 14,061 353
5 115
4,053 90,088 1,193
3
209
538
3
2
45
979
9,820 400
3
7
1
4,182
2
2
1
1
12,778
34 35
19
1
1
8
2
1
2
5
11
95
2
36
40
41
5 13,740 57,831
69
334
1
71
44
5,827
4
4
2,430
1
4,201
2
2
8,622
4
666
1
2
646
1
312
1
1,150
277
2
167
1
57
1,294
11
47
3
1
2
32
11
11
17 121,536
1,673
6,133
1
2,366
87 3,483 132,059
17
1
1,600
10
66
1,664
84,246
1,135
2,452
2,631
3,736
300
144
6
9
2
3
1
34
1
1
1
4
7
6
1
1
2
1
6
26,262
8
1
6
2
3
1
7
10
1 23 361,223 12,360 3,987 91 288 1,307 19,428 403,216 8,009 2,493 14,163 2,409 26,286 19 26,088 13,840 57,908
JW1559-019692
42
23,244
2
235
18
6
22
19
2
8
3
2
2
4
1
2
16
1
25
11
70
71 72
97 98
99 (blank)
Grand Total
158 1,111
8
5,228
2,971 1,144,511 1,280,943
1
3
14
273
63
356
1
2,139
8
11,050
3,375 64,997 319 246,953 9 910

1,733,237
877 4,137 17 43,744

23
229,126
115
447
5 11,695
3
127,677
940 2,725 12 24,775

23
128,711
794 4,487 37 26,172

30
115,168
68
144
10,135
3
161,440
552 1,949 10
3,929
16
28,725
34
266
1
1,752
5
30,383
5
21
96
447
3
1,456
1
9,161
26
257
4
3,002
14,192
2
4
547
9,827
43
179 16
684
5
3,437
7
42
1
1
5
1
267
1
1,041
10
9
206
8,254
3
56,481
8
23
184
4
2
30
1
1
3
9
29
197
2,580
15
2
1
14
1
9
2
254
5
23
84
1
1
4
12
16
20
89
227
3,059
9
27,963
1
3
1
210,003
1
2
2
3,533
8,863
77
5,149
23,625 7,192 81,869 434 391,332
9 4,005 1,144,511
4,202,711
JW1559-019693
Budget Line Item
ADP Operations
Communications
Enforcement Expense
Equipment
Labor
Moving Expense
Postage
Printing
Space & Housing
Services/Supplies
Training
Traveling
Funds Center
T001 DIVISION HEADQUARTER
Total
T0UF
UNDSTRBTD OFC-TEGE
Labor
Services/Supplies
Traveling
Total
T101
DIR EMPLOYEE PLANS
ADP Operations
Communications
Enforcement Expense
Equipment
Labor
Moving Expense
Postage
Printing
Space & Housing
Services/Supplies
Training
Traveling
Total
$0
$1
$0
$2,145
$14,367,493
$4
$187
$99,607
$0
$19,361,070
$1,050,152
$748,623
$35,629,282
FY 2010
Total
$0
$1
$0
$1,386
$15,381,944
$4
$51
$102,001
$5,236
$10,849,377
$1,023,336
$619,527
$27,982,862
FY 2011
Total
$0
$0
$7
$2
$15,224,355
$0
$40
$62,002
$1
$7,559,435
$394,213
$349,529
$23,589,584
Overall Result
$748,658
$3
$7
$8,574
$58,311,820
$12
$2,146
$412,811
$6,237
$53,002,213
$3,373,755
$2,342,877
$118,209,113
$43,872
$32,816
$0
$76,688
$0
$88,889
$0
$88,889
$63,188
$101,139
$763
$165,090
$155,223
$233,931
$763
$389,917
$0
$0
$0
$1,914
$0
$241
$0
$0
$939
$4,663
$879
$2,186
$4
$3
$3,022
$0
$95,646,315 $99,109,464 $103,163,053 $104,213,265
$8
$8
$10
$0
$1
$0
$0
$0
$71,300
$73,701
$85,000
$66,002
$33,368
$38,942
$43,248
$302
$196,556
$305,678
$379,568
$227,454
$1,880,607
$2,239,149
$1,838,102
$1,481,689
$2,685,126
$3,201,699
$3,566,688
$1,954,655
$100,514,224 $104,973,548 $109,079,571 $107,947,467
$1,914
$241
$8,668
$3,029
$402,132,097
$26
$1
$296,003
$115,860
$1,109,257
$7,439,547
$11,408,168
$422,514,810
FY 2008
Total
$748,658
$1
$0
$5,041
$13,338,028
$4
$1,868
$149,201
$1,000
$15,232,331
$906,054
$625,199
$31,007,385
$48,163
$11,087
$0
$59,250
FY 2009
Total
JW1559-019694
Budget Line Item
Enforcement Expense
Equipment
Labor
Moving Expense
Printing
Space & Housing
Services/Supplies
Training
Traveling
Funds Center
T201 DIR EXEMPT ORGANIZAT
Total
T301
DIR GOVERNMENT ENTIT
Enforcement Expense
Equipment
Labor
Moving Expense
Printing
Space & Housing
Services/Supplies
Training
Traveling
Total
TEGE TAX EXEMPT/GOVT ENTI
Not assigned
Not assigned
Not assigned
Not assigned
Not assigned
Not assigned
Total
Overall Result
FY 2008
Total
$11,652
$3
$83,918,996
$154,357
$142,098
$0
$1,197,267
$870,072
$2,186,378
$88,480,823
FY 2009
FY 2010
FY 2011
Total
Total
Total
$12,300
$5,204
$9,109
$3
$2,018
$0
$87,592,565 $94,611,953 $97,862,563
$6
$125,208
$0
$178,248
$125,000
$122,902
$6,028
$690
$0
$1,205,339
$1,359,924
$1,338,742
$2,509,314
$1,048,153
$599,379
$2,773,095
$3,681,221
$2,230,349
$94,276,898 $100,959,371 $102,163,044
$27,236
$21,733
$28,189,745
$86,279
$27,500
$1,417
$87,116
$543,930
$1,376,783
$30,361,739
$56,403
$1
$30,968,748
$4
$10,002
$3,715
$172,356
$997,347
$1,847,732
$34,056,308
$2,234
$2
$35,944,270
$5
$11,003
$814
$322,043
$1,066,676
$2,072,619
$39,419,666
$79,725
$3,827
$40,976,306
$0
$9,892
$1
$264,275
$263,267
$1,079,937
$42,677,230
$165,598
$25,563
$136,079,069
$86,288
$58,397
$5,947
$845,790
$2,871,220
$6,377,071
$146,514,943
$0
$0
$0
$0
$0
$65
$65
$0
$0
$0
$5,501,853
$0
$0
$5,501,853
$4,756
$1,750
$113,554
$33,409
$106,685
$148,077
$408,232
$0
$0
$0
$0
$0
$0
$0
$4,756
$1,750
$113,554
$5,535,262
$106,685
$148,142
$5,910,149
$250,423,487 $274,514,577 $277,938,590 $276,542,415
$1,079,419,069
Overall Result
$38,265
$2,024
$363,986,077
$279,571
$568,248
$6,718
$5,101,272
$5,026,918
$10,871,043
$385,880,136
JW1559-019695
Funds Center
Functional area
Exempt Organization
CE&O
EO Director's staff
Exam
Rulings & Agreements
Result
FY2008
8.05
11.00
479.64
332.16
830.85
FY2009
8.99
9.96
470.83
343.38
833.15
FY2010
8.89
10.32
529.10
340.53
888.84
FY2011
11.91
11.80
533.71
328.20
885.63
Overall
Result
37.83
43.08
2,013.28
1,344.27
3,438.46
JW1559-019696
Royalty Income Reported by Nonprofit Charitable Organizations on Form
990, Tax Year 2008
All figures are estimates based on samples. Money amounts are in thousands of dollars.
Number of
returns
Total Royalty income
Amount
Average per
return
2,794
2,638,738
944
Royalty income -- Related or exempt
589
355,137
603
Royalty income -- Unrelated business
71
3,588
51
2,017
2,272,875
1,127
Royalty income -- Exluded
Source: Internal Revenue Service, Statistics of Income Division. October 2011.
Net Rental Income Reported by Nonprofit Charitable Organizations and
Private Foundations on Forms 990 and 990-PF, Tax Year 2008
All figures are estimates based on samples. Money amounts are in thousands of dollars.
Number of
returns
Total Net Rental Income
Amount
Average per
return
23,328
3,233,596
139
Net rental income -- Related or exempt
7,793
749,681
96
Net rental income -- Unrelated business
2,936
84,571
29
12,615
2,308,575
183
Net rental income -- Excluded
Source: Internal Revenue Service, Statistics of Income Division. October 2011.
JW1559-019697
From:
Lerner Lois G
Sent:
To:
Thomas Cindy M
Cc:
Fish David L; Paz Holly O
Subject:
Re: Determ assignment
Thanks Cindy. I know you,ve been moving stuff around to get closures up. Just wanted to be sure we had a plan.
Lois G. Lerner-------------------------- Sent from my BlackBerry Wireless Handheld
----- Original Message ----From: Thomas Cindy M
To: Lerner Lois G
Cc: Fish David L; Paz Holly O
Subject: RE: Determ assignment
All grade 12 and 13 employees (except those in the screening group) were instructed last week to start working full
development cases only. We had asked them not to work these cases during Sept. because EOT was reviewing them in
TEDS to try to boost closures, and we didn't want to duplicate efforts. Also, in September we needed to shift resources
anyway to have more folks screen sinc e that is where we get more bang for our buck for closures.
We'll be focusing on full development cases until we get the control date to be within approx. 4 months.
-----Original Message ----From: Lerner Lois G
To: Thomas Cindy M
Cc: Fish David L; Paz Holly O
Subject: Determ assignment
I am at NYU conference and someone pointed out that our site says we're assigning cases fro March 2011. I get very
uncomfortable with an al$most 8 month backlog. Can you give me some sense of what that really means ans what we
are doing to address it? Thanks Lois G. Lerner -------------------------- Sent from my BlackBerry Wireless Handheld
JW1559-019698
From:
Seto Michael C
Sent:
Wednesday, November 09, 2011 9:57 AM
To:
Seto Michael C; Fish David L
Cc:
Paz Holly O; Trilli Darla J; Neuhart Paige
Subject:
RE: R & A Priorities
Here is additional information on the cases pending in Counsel:
Sent: Wednesday, November 09, 2011 10:50 AM
To: Fish David L
Cc: Paz Holly O; Trilli Darla J; Neuhart Paige
Subject: FW: R & A Priorities
Attached are 2 documents, an updated list of cases pending in Counsel and a list of non -case work items (projects,
technical assistance to EOD, EOQA, and EO Exam)
Here are the summary data for EOT:
1. 13 cases pending in EO Counsel & 5 cases pending in other sections of Counsel - a total of 18 cases
a) The oldest case pending in EO Counsel is dated 3/8/11.
b) The oldest case pending in other section of Counsel is 8/22/07 (a VEBA case, and we are pushing Counsel (health &
benefit to resolve the technical issues).
2. W e have 48 non-case work items that range from major time/personnel commitment (C&U project, RM revision project,
ACA case screening, political advocacy case screening, etc.) to minor time commitment (recognition team, governance
project, etc.)
3. 657 open cases beginning in FY12
a) 446 applications
b) 155 private letter rulings
c) 41 TAMs
d) 15 technical assistance requests
Some of the cases are on hold such as the co -investment PLRs and open sources applications pending counsel
review. Of the 657 cases, 163 are two years or older.
From: Lerner Lois G
To: Fish David L; Seto Michael C; Thomas Cindy M; Abner Donna J; Kindell Judith E; Light Sharon P
Cc: Paz Holly O
Subject: R & A Priorities
I'm getting a little nervous about the amount we have on our plate and how we are handling. I
know everyone is working hard and juggling, but I am wondering whether the juggling
decisions are being made holistically enough. We have only so many resources and things
will probably get worse going forward. I worry that decisions about how to use the resources
are being made without all the information. A couple things have come up through press
accounts and practitioner comments that lead me to believe we should be making
JW1559-019699
prioritization decisions based on EO as a whole, not in our own stovepipes. Something that
may not seem important in Cincinnati, may be crucial in DC. Similarly, DC may be prioritizing
its work based on what is sitting i n DC when something sitting in Cincinnati should be the
focus of DC work. And, in both cases, the hold up might really relate to something sitting in
Counsel that we need to move forward.
To get a better handle on this and help you with prioritizing, I' m going to need some reports
from you.
Judy and Sharon--a list of all projects you are working on, including work that others are
doing and you are overseeing, as well as estimated timeframes for completion if you have
them and any barriers to completion.
Cindy and Donna--lists of backlogs of any specific type of cases and what is contributing to
the backlog--I.e.--are you waiting for assistance from R & A, are you focusing on something
else that impacts your ability to get this piece done. Also, are there kinds of cases that DC
has pushed to Cincinnati, but in hindsight, may be better suited to DC
David/Mike--Holly left me a list of cases that are in Counsel. If it needs to be updated please
do that--David--I forwarded it last night. I also need a list of everything else we have sent to
Counsel and similar information as is in the case list, such as how long it has been there and,
if you know, what might be the hang up. Please include things formally at Counsel, as well as
things we've asked for informally. If it is informal, can I get who we're dealing with. I'd also
like some sense of the inventory that doesn't fall within these categories that looks like it
could be problematic--might need to go to Counsel or a category of cases tha t isn't moving
I'm sure there will be more, but this will give us a good start.
next Wednesday please.
I'd like the information by COB
Lois G. Lerner
JW1559-019700
From:
Fish David L
Sent:
To:
Paz Holly O
Subject:
FW: R & A Priorities
Attachments:
Cases Pending In Counsel as of 11-7-11.xls; EOT Projects & Non-case work items.xls
To: Fish David L
project, etc.)
a) 446 applications
c) 41 TAMs
From: Lerner Lois G
Cc: Paz Holly O
JW1559-019701
its work based on what is sitting in DC when something sitting in Cincinnati should be the
To get a better handle on thi s and help you with prioritizing, I'm going to need some reports
from you.
doing and you are overseeing, as well as estimated timeframes for completion if you ha ve
else that impacts your abilit y to get this piece done. Also, are there kinds of cases that DC
could be problematic--might need to go to Counsel or a category of cases that isn't moving
Lois G. Lerner
JW1559-019702
A. 13 Cases Pending In Counsel CC:TEGE:EO

*A SCR Case
(as of 11/7/11)
Taxpayer's Name:
Type of
Cases:
TRAC Control #: Date The Case
Referred to
Counsel
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
EO Technical Group 1 (Steve Grodnitzky,
Manager) Cases:
Courtney Jones Review should be completed
in two weeks
in two weeks
Application
5/17/2010
Application
5/17/2010
Application
5/17/2010
TAM
6/3/2011
Application
8/9/2011
Courtney Jones Denial of exemption - final
adverse. Not started yet
8/25/2011
Don Spellman
6103
in two weeks
Preston
In process
Quesenberry
PLR
(b)(3)/6103; no...
Expect to receive comments
the week of October 31
Application
3/8/2011
Terri Haris
On hold
Application
5/4/2011
Pam Kartha
Denial of exemption proposed: Not started yet.
Pam will work before

6103
Application
10/7/2011
Denial of exemption proposed
10
Application
9/14/2011
6103
JW1559-019703
EO Technical Group 4 (Mary Jo Salins,
11
12
Application
13
Application
(b)(3)/6103; non-res...
PLR
B 5 cases have been reviewed by and
returned from Counsel CC:TEGE:EO
Type of
Cases:
4/25/2011
Pam Kartha
8/10/2011
Request for TA
10/21/2011
Referred to
Counsel
Denial of exemption proposed adverse. In
process
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
Counsel concurred with
proposed denial of
exemption to EOT and
provided comments and
recommendations to revise
the denial letter.
Counsel returned case to
EOT with comments and
recommendations.
Application
3/17/2011
10/3/2011
Pam Kartha
Application
7/1/2011
8/29/2011
Preston
Quesenberry
(b)(3)/6103; non...
PLR
5/31/2011
11/3/2011
Casey
Lothamer
PLR
5/24/2011
10/21/2011
David Marshall Counsel returned case to
EOT with comments.
PLR
5/24/2011
9/27/2011
EOT with comments.
recommendations.
JW1559-019704
C 5 Cases Pending In Other Sections of
Counsel
Type of
Cases:
Referred to
Counsel
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
EO Technical Group 2 (Ron Shoemaker,
Manager) Cases:
TAM
6103
7/5/2011
PLR
6103
8/22/2007
PLR
6103
6103
3/31/2011
Janet Laufer
Pending In TEGE Counsel
(Health & Welfare) - VEBA
case
In TEGE Counsel
Janet Laufer
Pending
caseCounsel referred the
(David Marshall EO
case to CC:Corp & CC:P&A
is the contact
person in
CC:TEGE:EO)
(b)(3)/6103; ...
n,
Trust
PLR
PLR
6103
12/22/2010
Herbert (Lane)
Pending in PSI
Damaza and
Jim Hogan
6103
7/11/2011
Janet Laufer
case
JW1559-019705
Report as of 11/7/11
A. EO Technical Projects
1 IRM revision
2 Colleges and Universities project
T1
Personnel Assigned to projects, work items, etc.
T2
T3
6 See comment
section for
names
1 (P. Thomas)
3 See comment
section for
names
1 (J. Zelaskco)
5 See comment
section for names
1 (P. Holiat)
1 (R. Cowen)
3 Section 512(b)(12) Report
4 Section 501(c)(10) check sheet project
5 EO Exam Mortgage Foreclosure Compliance
Project
6 EO Exam Section 501(c)(12) Compliance Project
7 Credit Union Project
8 Auto revocation project
9 Gaming Compliance Team
10 Credit Counseling
11 Section 501(c)(27)(B) Complinace Project
12 Governance
13 Community Foundation
14 Conservation Easements
15 ATAT
16 CIC
17 Fraud
18 State Tuition Organizations Project
19 Jeopardizing Investments Project
20 Mortgage Foreclosure FTC Agreement
21 Executive Compensation Transparency Project
22 PACI
23 7611 Regulation Project
24 Private Foundation TEP
25 SPWG Charter School
26 Supporting Organization Project
27 VEBA Project
T4
4 See comment
section for names
1 (S. Barnett)
1 (D. Cowen)
1 (D. Cowen)
1 (McCray)
1 (L. Kastenberg)
1 (E. Berick)
1 (D. Moore)
1 (S. Robbins)
1 (E. Kastenberg)
1 (E. Berick)
1 (K. Burns)
1 (K. Burns)
1 (D. Smith)
1 (McNaughton)
1
1
1
1
1
1
1
1
1
1
1
(Biss)
(Biss)
(Smith)
(Phaup)
(Phaup)
(Phaup)
(A. Beckwith)
(A. Beckwith)
(A. Beckwith)
(E. Mangrum)
(H. Goehausen)
1 (H. Goehausen)
1 (J. Zelasko)
1 (J. Zelasko)
1 S. Copeland)
1 (O. Chukuanu)
JW1559-019706
T1
T2
T3
B. Guidance Items
28 Annual Rev. Proc. - Update
29 ACA Implementation
30
1 (M. Perdoni)
2 (M. McNaughton
& G. Gluth)
1 (S. Copeland)
Guidance Items relation to PPA
C. Non-Project Work Items
31 Congressional & general correspondences
2 (J. Mackay & E.
Mangrum)
1 (S. Robbins)
32 FOIA processing
33 Closing agreement on (c)(6) cases
34 Anti-Terrorism Coordination
1 (J. Mackay)
1 (Schantz)
1 (Schantz)
35 Media Relations Team
36 Walk-in Closing Agreements
37 EO E-mail Assistance to EOD, EOQA & EO Exam
1 (P. Thomas)
1 (A. Beckwith)
D. Techincal Case Assistance to EOD or EOQA
38 Political advocacy case assistance to EOD
39 Political advocacy guide sheet
40 Mortgage Foreclosure/Rescue case
assistance to EOD and EOQA
2 (J. Kovac & D.
Smith)
1 (O. Chukwuanu)
1 (Chip Hull)
1 (A. Beckwith)
41 ACA - Case Screening
42 Group Ruling cases
T4
1 (E. Kastenberg)
1 (J. Kovac)
2 (E. Berrick & L.
Fischer-Dibacco)
1 (L. Orcino)
1 (P. Thomas)
JW1559-019707
E. Techncal Assistance to EO Exam
43 4958 Assistance to EO Exam agents
F. Non-Technical Projects
Recognition team
Secured Messaging Pilot team
International Commmunication Council
EO Business Writing Course Cadre
CFC
T1
T2
T3
1 (D. Moore)
44
45
46
G. Forms - Annual Updates
47 Form 990, Schedules D and G - Annual Update
48 Form 990- General
T4
1 (P. Holiat)
1 (M. Perdoni)
1 (K. Burns)
1 (A. Beckwith)
1 (S. Robbins)
1 (K. Burns)
1 (E. Kastenberg)
JW1559-019708
From:
Fish David L
Sent:
To:
Paz Holly O
Subject:
Attachments:
Advocacy Orgs_Cincinnati.xls
To: Lerner Lois G
Cc: Fish David L
Subject: RE: R & A Priorities
For EO Determinations, there aren't any significant volumes of work that D.C. has pushed to us that are better suited
for EOT. We had issues with certain types of cases in the past such as set asides, voter registration, and
cases. However, we've worked through these issues.
(b)(3)\6103
The backlog of work involves advocacy organizations. As of about a month ago, there were 161 of these cases sitting idle
and we probably have more by now. The control dates for these cases go back to the end of 2009 and all through
2010. We've been waiting for EO in D .C. to get us a guidance/reference document with lessons learned from the c4 and
c3 cases they worked and coordinated with Judy Kindell and Counsel. We're getting calls from POAs wanting to know
who has put the halt on working these cases and threatening to contact their Congressional offices. Just today, I
instructed one of my managers to get an additional information letter out to one of these organizations --- if nothing else to
buy time so he didn't contact his Congressional Office. Soon, we're going to start getting TAO's from TAS or declaratory
judgment cases filed ---- then, I guess everyone will decide its time to start moving the cases when we have mounds of
additional paperwork to process along with the cases (adding even more work for us to do) .
Another area we'd like to see finalized is the guide sheets for Rev. Proc. 96-10 and integrated auxiliary cases. We don't
have a backlog of these cases, but we need these documents finalized in order to finalize our IRM so that all the EO
Determinations employees have a document where they can go to get procedural information for cases --- will save time
and will improve consistency in casework/quality. Also related to this, you sent an email requiring that we send cases to
D.C. for review when an org anization is asking to be exempt from Form 990 filing requirements by virtue of Rev. Procs.
95-48, 96-10, and integrated auxiliary. If the guidesheets can be finalized, perhaps we wouldn't need to send these cases
any longer, which would save time for all involved.
Other than this, it is the group ruling cases and auto revocation cases/issues that we're trying to get through:
A. Regarding the group ruling cases, we spend a lot of clerical time completing research for each sub to see if they are i n
status 97. And, QA seems to believe that we should be getting documents and checking the website for each sub, which
isn't how group ruling cases were ever intended to be worked. All group ruling cases are mandatory review and the group
working these cases were doing what QA required; otherwise, they couldn't get the cases closed.
I instructed the group to
stop doing these things and to follow Rev. Proc. 80-27, and advised that these issues would need to be elevated to the
Acting Director, EO R&A to ge t resolved. W e are checking to see whether the subs are in status 97 and will continue to
do so until instructed otherwise.
B. Regarding the auto revocation cases, we're working through them and elevating new issues as they come up.
Other
than cases with lien and/or assessment issues, I'm not aware of us holding any cases waiting for guidance.
The real area of concern in EO Determinations (other than the advocacy cases) is with our Processing Section.
They are
swamped with correspondence on auto r evocation issues; processing cases where organizations submitted a $100 user
JW1559-019709

fee and don't meet the requirements such as PFs, unincorporated organizations that incorporated somewhere along the
way, and others that have too much income to meet the transitio nal rules under Notice 2011-43; completing IDRS
research for numerous cases to determine whether the application is from an organization that was auto revoked; and,
preparing closing letters/documents for all EO cases in Cincinnati now that specialists are on TEDS and can't complete
this work (timing issue with TEDS and EDS); processing suspense cases; processing Accelerated Processing cases, etc.
If you need additional information, please let me know.
From: Lerner Lois G
Cc: Paz Holly O
prioritization decisions based on EO as a wh ole, not in our own stovepipes. Something that
To get a better handle on this and help you with prioritizing, I'm going to need some reports
from you.
Cindy and Donna--lists of backlogs of any specific type of cases and wha t is contributing to
things we've asked for informall y. If it is informal, can I get who we're dealing with. I'd also
Lois G. Lerner
JW1559-019710
JW1559-019711
3 Year Automatic Revocation Cases
Current
Control
Organization Name
gs
Date
11/19/09
12/04/09
12/29/09
01/02/10
02/10/10
02/10/10
03/02/10
03/08/10
03/15/10
03/18/10
03/19/10
03/26/10
03/26/10
03/29/10
04/01/10
04/05/10
04/09/10
04/14/10
04/16/10
04/29/10
05/03/10
05/05/10
05/07/10
05/10/10
05/11/10
05/11/10
05/20/10
05/20/10
05/21/10
05/26/10
05/27/10
05/28/10
06/03/10
06/07/10
06/11/10
06/11/10
06/14/10
06/18/10
06/23/10
06/30/10
07/06/10
07/08/10
07/12/10
07/13/10
07/14/10
07/19/10
07/20/10
EIN
(b)(3)/6103; no...
Subsection
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-3
c-3
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
EDS Status
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
JW1559-019712
07/21/10
07/23/10
08/04/10
08/05/10
08/09/10
08/20/10
08/24/10
08/28/10
08/31/10
08/31/10
08/31/10
09/03/10
09/13/10
09/20/10
09/21/10
09/24/10
09/28/10
09/30/10
10/13/10
10/16/10
10/18/10
10/25/10
10/25/10
10/25/10
10/28/10
11/12/10
11/12/10
11/19/10
12/01/10
12/17/10
12/17/10
12/17/10
12/21/10
12/22/10
12/30/10
01/03/11
01/05/11
01/07/11
01/10/11
01/11/11
01/13/11
01/13/11
01/18/11
01/18/11
01/20/11
01/24/11
01/27/11
01/31/11
01/31/11
02/01/11
(b)(3)/6103; non-re...
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-3
c-3
c-4
c-4
c-3
c-4
c-3
c-4
c-3
c-4
c-3
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-3
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
JW1559-019713
02/01/11
02/03/11
02/10/11
02/14/11
02/14/11
02/22/11
02/22/11
02/22/11
02/22/11
03/07/11
03/08/11
03/08/11
03/10/11
03/11/11
03/15/11
03/16/11
03/17/11
03/18/11
03/25/11
03/25/11
03/28/11
03/30/11
03/31/11
04/04/11
04/06/11
04/07/11
04/08/11
04/11/11
04/13/11
04/15/11
04/15/11
04/16/11
04/19/11
04/22/11
04/27/11
05/02/11
05/04/11
05/12/11
05/13/11
05/17/11
05/28/11
06/06/11
06/09/11
06/09/11
06/09/11
06/09/11
06/09/11
06/09/11
06/10/11
06/10/11
(b)(3)/6103; non...
c-3
c-3
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-3
c-4
c-4
c-4
c-3
c-3
c-4
c-3
c-3
c-4
c-3
c-4
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
52
JW1559-019714
06/15/11
06/15/11
06/17/11
06/21/11
06/25/11
06/28/11
06/28/11
06/28/11
06/29/11
06/29/11
06/30/11
07/01/11
07/05/11
07/06/11
(b)(3)/6103; no...
c-4
c-4
c-4
c-4
c-4
c-4
c-3
c-4
c-4
c-3
c-3
c-4
c-4
c-3
52
52
52
52
52
52
52
52
52
52
52
52
52
52
JW1559-019715
Action To Be Taken
JW1559-019716
JW1559-019717
JW1559-019718
JW1559-019719
JW1559-019720
nts/po
JW1559-019721
ccu
f ac
JW1559-019722
vin
JW1559-019723
JW1559-019724
JW1559-019725
JW1559-019726
JW1559-019727
Current MF Status
01
02
21
23
24
25
31
32
36
97
Total Number of 27 Month Cases
Current EDS Status
52
37 (ready to close)
TOTAL
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
161
JW1559-019728
From:
Zarin Roberta B
Sent:
To:
Paz Holly O; Lerner Lois G
Subject:
RE: (b)(3);... organization meeting with Rep. Jordan today
This is clear, but I suggest you pull in a reference that these folks are asking for
(b)(5)/DP
--that'a big
deal, which is why it is important that we look closely and ensure that they fit within the guidelines of the Code, etc in or der
to qualify (you can say it better.)
(b)(5)/db
202-283-8868
From: Paz Holly O
To: Zarin Roberta B; Lerner Lois G
Subject: RE:
(b)(3);...
Importance: High
6...
Here is my stab at talking points based on our discussion.
(b)(5)/db
JW1559-019729
(b)(5)/db
Subject: FW:
(b)(3...
Importance: High
6...
see the email request be low and the attached email traffic from late last week.
202-283-8868
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
(b)(3);...
Importance: High
getting some talking points or comments before close -of-business, so that we ca n prep Congressman Jordan? W e do not
below.
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
(b)(3...
(b)(3)...
(b)(3); 6103
been invited to address this group this evening, and she is hoping t o get an update. W e don't have a disclosure
(b)(5) DP
JW1559-019730
(b)(5) DP
Subject: Clip:
(b)(3); 6103
6...
(b)(3); 6103
JW1559-019731
(b)(3); 6103
JW1559-019732
(b)(3); 6103
JW1559-019733
From:
Nielson Jacqueline R
Sent:
To:
Marx Dawn R; Paz Holly O
Subject:
RE:
(b)(3)...
Hi, I just wanted to make sure you had my phone number (614 -280-8739) in case you wanted to call to discuss talking
points for Congressman Jim Jordan for his meeting tonight.
Susan Ohl, his Congressional Aide, is leaving her office at 5
ET, so I told her we would do our best to have something to her by then.
Thanks. Jackie Nielson
From: Marx Dawn R
To: Thomas Cindy M; Hall Eric; Nielson Jacqueline R
Cc: Hall Regeina D
Subject: RE:
(b)(3)...
Cindy, Holly is in a meet ing along with a number of other people right now. Do you want me to catch her on her way out of
that meeting?
Dawn R. Marx
INTERNAL REVENUE SERVICE
ATTN: Dawn R. Marx
TE/GE SE:T:EO
NCA-572
1111 Constitution Avenue, NW
Washington, DC 20224 -0002
(202) 283-8861 Phone
(202) 283-8785 Fax
Dawn.R.Marx@irs.gov
To: Marx Dawn R; Hall Eric; Nielson Jacqueline R
Cc: Hall Regeina D
Subject: FW:
(b)(3...
Dawn - I should have cc'd you on my email below.
Eric -- I meant to cc: you but inadvertently cc'd Regeina Hall instead.
Jackie -- I called Holly prior to sending my email. She didn't answer and I left a voice message.
To: Thomas Cindy M; Paz Holly O
JW1559-019734
Cc: Light Sharon P; Zarin Roberta B; Hall Regeina D
Subject: RE:
(b)(3)...
6...
Holly, are you at your desk? Could I call you? Thanks! Jackie N.
To: Paz Holly O
Subject: FW:
(b)(3...
Importance: High
Holly,
NOTE: This case was ass igned to Joseph Herr on 2/6/2012. It has a control date from 9/2010.
Cc: Hall Eric
Subject: FW:
(b)(3);...
Importance: High
, EIN
(b)(3); 6103
(b)(3); 6103
In the release they sa y their application has been
asked the group to answer. If we could also give him just a couple of talking points, that might be helpf ul, e.g. we review
Subject: FW:
(b)(3...
Importance: High
see the email request b elow and the attached email traffic from late last week.
202-283-8868
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
(b)(3);...
Importance: High
JW1559-019735

below.
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
(b)(3...
(b)(3); 6103
- applied for exempt status in Sept., 2010 a nd has not gotten
Help! An organization in (b)(3)... their determination yet. Per the news report below, IRS has requested substantial additional information from them, and it
sounds like they feel they are being singled out due to their beliefs.
Per the article, there have been allegatio ns of similar
6...
(b)(5) DP
Subject: Clip:
(b)(3); 6103
(b)(3); 6103
JW1559-019736
(b)(3); 6103
JW1559-019737
(b)(3); 6103
JW1559-019738
From:
Marx Dawn R
Sent:
To:
Nielson Jacqueline R; Paz Holly O
Cc:
Thomas Cindy M; Hall Regeina D
Subject:
RE:
(b)(3)...
Couldn't hurt. Working to finalize this.
Thanks.
Dawn R. Marx
ATTN: Dawn R. Marx
TE/GE SE:T:EO
NCA-572
(202) 283-8861 Phone
(202) 283-8785 Fax
Dawn.R.Marx@irs.gov
To: Marx Dawn R; Paz Holly O
Cc: Thomas Cindy M; Hall Regeina D
Subject: RE:
(b)(3)...
Rep. Jordan's Aide said she usually leaves at 5. Should I ask her to stay a little longer? Thanks!!
From: Marx Dawn R
To: Paz Holly O
Cc: Thomas Cindy M; Nielson Jacqueline R; Hall Regeina D
Subject: FW:
(b)(3...
Holly, FYI.
Dawn R. Marx
ATTN: Dawn R. Marx
TE/GE SE:T:EO
NCA-572
JW1559-019739
(202) 283-8861 Phone
(202) 283-8785 Fax
Dawn.R.Marx@irs.gov
From: Hall Eric
To: Nielson Jacqueline R ; Thomas Cindy M; Marx Dawn R
Cc: Hall Regeina D
Subject: RE:
(b)(3)...
I'm gone for the day. Please send whatever you get directly to Jackie. Thanks.
To: Thomas Cindy M; Marx Dawn R
Cc: Hall Regeina D; Hall Eric
Subject: RE:
(b)(3)...
Great!!
To: Nielson Jacqueline R; Marx Dawn R
Cc: Hall Regeina D; Hall Eric
Subject: RE:
(b)(3)...
Jackie - Holly is in a me eting with Lois Lerner and others drafting talking points.
Dawn - No need to catch Holly. She sent me an email indicating she and Lois are working on talking points.
needed.
That is all I
To: Thomas Cindy M; Marx Dawn R; Hall Eric
Cc: Hall Regeina D
Subject: RE:
(b)(3)...
Karen Batey isn't answering either. Cindy, could I call you and we could quickly dra ft a few talking points for Rep. Jordan?
To: Marx Dawn R; Hall Eric; Nielson Jacqueline R
Cc: Hall Regeina D
Subject: FW:
(b)(3...
Dawn - I should have cc'd you on my email below.
Eric -- I meant to cc: you but inadvertently cc'd Regeina Hall instead.
Jackie -- I called Holly prior to sending my email.
She didn't answer and I left a voice message.
JW1559-019740
To: Thomas Cindy M; Paz Holly O
Cc: Light Sharon P; Zarin Roberta B; Hall Regeina D
Subject: RE:
(b)(3);...
Holly, are you at your desk? Could I call you? Thanks! Jackie N.
To: Paz Holly O
Subject: FW:
(b)(3...
Importance: High
Holly,
Cc: Hall Eric
Subject: FW:
(b)(3...
Importance: High
EIN
(b)(3); 6103
(b)(3); 6103
each application for completeness, etc. Thanks! Jackie N., Governmental Liaison , 614-280-8739
Subject: FW:
(b)(3...
Importance: High
202-283-8868
JW1559-019741
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
(b)(3...
Importance: High
below.
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
(b)(3...
organization meeti ng with Rep. Jordan today
(b)(3)...
(b)(3); 6103
their determination yet. Per the news report below, IRS has requested substantial additional information fr om them, and it
Per the article, there have been allegations of similar
incidents by groups in other states. Susan Ohl, a staff member of Rep. Jim Jordan's, called this morning and sa id he has
(b)(5) DP
Subject: Clip:
(b)(3); 6103
(b)(3); 6103
JW1559-019742
(b)(3); 6103
JW1559-019743
(b)(3); 6103
JW1559-019744
From:
Paz Holly O
Sent:
To:
Thomas Cindy M
Subject:
RE:
(b)(3);...
That would be great. Thanks!
To: Paz Holly O
Subject: FW:
(b)(3);...
Importance: High
Holly,
I asked for timeline, etc., for
(b)(3); 6103
simi lar to what Peggy sent to you for
(b)(3); 6103
I hope to have this to you
by 2/22 at the end of the day at the latest.
From: Lerner Lois G
Cc: Thomas Cindy M
Subject: RE
6103
Importance: High
We are handling this at a higher level --Nikole Flax and I are supposed to go talk to
door please.
Lois G. Lerner
Subject: FW:
6103
Importance: High
202-283-8868
JW1559-019745
To: Paz Holly O
Subject: FW:
6103
Importance: High
Holly,
Cc: Hall Eric
Subject: FW:
(b)(3);...
Importance: High
I do have the privac y release from the
6103
(b)(3); 6103
, EIN
6103
Cc: Eldridge Michelle L; Cressman Willia m M; Daly Richard M; Hall Eric; Cressman William M
Subject: FW:
6103
Importance: High
202-283-8868
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
6103
Importance: High
below.
JW1559-019746
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
6103
(b)(3); ...
(b)(...
6103
been invited to address this group this evening, and she is hoping t o get an update. W e don't have a disclosure
(b)(5) DP
Subject: Clip:
(b)(3); 6103
(b)(3); 6103
6103
6103
6103
6103
6103
JW1559-019747
6103
6103
6103
6103
6103
6103
(b)(3); 6103
6103
6103
6103
6103
6103
JW1559-019748
(b)(3); 6103
JW1559-019749
From:
Fish David L
Sent:
To:
Paz Holly O
Cc:
Lowe Justin; Megosh Andy
Subject:
FW: Request for Briefing on section 501(c)(4) Application Process
Attachments:
Development Process for (c)(4) Orgs (2).doc
From: Megosh Andy
To: Fish David L
David,
Here's a draft explanation of the c4 development process.
Andy
From: Fish David L
To: Megosh Andy; Park Nalee; Lowe Justin
Cc: Paz Holly O
Is someone looking at the questions yet? We'll get asked soon.
From: Keith Frank
Joseph J; Fish Dav id L
Rep. Jordan is from Ohio. I would bet that this is the organization he has heard about.
(b)(3); 6103
(...
JW1559-019750
(b)(3); 6103
(...
JW1559-019751
(b)(3); 6103
(...
JW1559-019752
To: Miller Steven T; Davis Jonath an M (Wash DC); Flax Nikole C; Grant Joseph H; Lerner Lois G; Urban Joseph J; Fish
David L
I just received a call from Kristina Mo ore, Senior Counsel to House Committee on Oversight and
respond.
briefing next week?
JW1559-019753
(b)(5)/db
JW1559-019754
(b)(5)/db
JW1559-019755
From:
Thomas Cindy M
Sent:
To:
Paz Holly O
Subject:
RE:
(b)(3)...
will do.
From: Paz Holly O
To: Thomas Cindy M
Subject: RE:
(b)(3);...
Importance: High
Can you please get someone to pull and PDF to me the
(b)(3); ...
for the
(...
orgs? Thanks!
To: Paz Holly O
Subject: FW:
(b)(3...
Importance: High
Holly,
I asked for timeline , etc., for
(b)(3); 6103
similar to what Peggy sent to you for
(b)(3); 6103
From: Lerner Lois G
Cc: Thomas Cindy M
Subject: RE:
(b)(3)...
Importance: High
door please.
Lois G. Lerner
Subject: FW:
(b)(3...
Importance: High
JW1559-019756
Tax Exempt and Government Entiti es
202-283-8868
To: Paz Holly O
Subject: FW:
(b)(3...
Importance: High
Holly,
Cc: Hall Eric
Subject: FW:
(b)(3...
Importance: High
I do have the privac y release from the
(b)(3); 6103
, EIN
(b)(3); 6103
have authorized release of information to Congressman Jordan. In the release they say their application has been
Cc: Eldridge Michelle L; Cressman Willia m M; Daly Richard M; Hall Eric; Cressman William M
Subject: FW:
(b)(3...
Importance: High
202-283-8868
From: Hall Eric
JW1559-019757
To: Zarin Roberta B
Subject: FW:
(b)(3...
Importance: High
have a disclosure authorization, so any talking points would have to be generic, focused on the bigger picture outlin ed
below.
6...
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
(b)(3...
(b)(3)...
(b)(3); 6103
been invited to address this group this evening, and she is hoping to get an u pdate. W e don't have a disclosure
(b)(5) DP
Subject: Clip:
(b)(3); 6103
(b)(3); 6103
JW1559-019758
(b)(3); 6103
JW1559-019759
(b)(3); 6103
JW1559-019760
From:
Thomas Cindy M
Sent:
To:
Paz Holly O
Subject:
RE: 6103 organization meeting with Rep. Jordan today
Attachments:
OtherDocument[2].pdf; Form1024[2].pdf; Form8718[2].pdf;

6103
(b)(3); 6103
6103
(b)(3); 6103
.doc;
.doc
6103
6103
6103
The pdf's are the
(EIN:
) files from TEDS.
Word documents include Joseph Herr's CCR and additional information letter.
The
I'm sending the other file in a separate email.
From: Paz Holly O
To: Thomas Cindy M
Subject: RE:
6103
Importance: High
(b)(3); ...
for the
orgs?
(...
Thanks!
To: Paz Holly O
Subject: FW:
6103
Importance: High
Holly,
6103
6103
From: Lerner Lois G
Cc: Thomas Cindy M
Subject: RE:
6103
Importance: High
Congressman on Friday. No one else should be doing an ything. Bobby can you let the leg
door please.
Lois G. Lerner
JW1559-019761
Subject: FW:
6103
Importance: High
202-283-8868
To: Paz Holly O
Subject: FW:
6103
Importance: High
Holly,
Cc: Hall Eric
Subject: FW:
6103
Importance: High
6103
6103
, EIN
Subject: FW:
6103
Importance: High
Can someone in EO help plea se?
JW1559-019762
202-283-8868
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
6103
Importance: High
below.
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
6103
(b)(3)...
- (b)(3...
6103
(b)(3); 61...
sounds like they feel they are being singl ed out due to their beliefs. Per the article, there have been allegations of similar
(b)(5) DP
Subject: Clip:
6103
6103
JW1559-019763
6103 6103
6103
6103 6103
6103
6103
6103
6103
6103 6103
6103
6103
6103
6103
6103
6103 6103
6103
6103 6103
6103
JW1559-019764
6103
JW1559-019765
6103
6103
6103
6103
6103
6103
6103
6103
6103
JW1559-019766
6103
6103
6103
6103
6103
6103
6103
JW1559-019767
6103
6103
6103
6103
6103
6103
6103
6103
JW1559-019768
6103
JW1559-019769
6103
6103
6103
JW1559-019770
6103
JW1559-019771
6103
6103
6103
6103
JW1559-019772
6103
JW1559-019773
6103
JW1559-019774
6103
JW1559-019775
6103
JW1559-019776
6103
JW1559-019777
6103
JW1559-019778
6103
JW1559-019779
6103
JW1559-019780
6103
JW1559-019781
6103
JW1559-019782
6103
JW1559-019783
6103
JW1559-019784

P.O. Box 2508
Department of the Treasury
6103
6103
6103
6103
6103
JW1559-019785
2
6103
6103
6103
JW1559-019786
3
6103
6103
6103
JW1559-019787
4
6103
6103
6103
JW1559-019788
5
6103
6103
6103
JW1559-019789
EP/EO Case Chronology Record
Page 1
6103
6103
6103
6103
JW1559-019790
Page 2
6103
6103
6103
JW1559-019791
Page 3
6103
6103
6103
JW1559-019792
From:
Thomas Cindy M
Sent:
To:
Paz Holly O
Subject:
RE:
Attachments:
OtherDocument[1].pdf; Form1024[1].pdf; Form2848[2].pdf; Form8718[1].pdf;
(b)(3)...
6103
(b)(3); 6103
(b)(3); 6103
meeting with Rep. Jordan today
.doc;
6103
.doc
(b)(3); 6103
(b)(3); 6103
Attached are pdf files from the information in TEDS for the
(EIN:
(b)(3); 6103 ). The Word documents include Joseph Herr's CCR and additional information letter.
From: Paz Holly O
To: Thomas Cindy M
Subject: RE:
(b)(3);...
Importance: High
(b)(3); ...
for the
orgs?
(...
Thanks!
To: Paz Holly O
Subject: FW:
6103
Importance: High
Holly,
(...
(b)(3); 6103
(b)(3); 6103
by 2/22 at the end of the day at the l atest.
From: Lerner Lois G
Cc: Thomas Cindy M
Subject: RE: (b)(3); ... organization meeting with Rep. Jordan today
Importance: High
Congressman on Friday. No one else should be doin g anything. Bobby can you let the leg
door please.
Lois G. Lerner
JW1559-019793
Subject: FW:
6103
Importance: High
202-283-8868
To: Paz Holly O
Subject: FW:
6103
Importance: High
Holly,
Cc: Hall Eric
Subject: FW:
6103
Importance: High
(b)...
6103
(b)(3); 6103
, EIN
6103
6...
Subject: FW:
6103
Importance: High
202-283-8868
JW1559-019794
From: Hall Eric
To: Zarin Roberta B
Subject: FW:
6103
Importance: High
application for tax exempt status. The group appears to be politically active and vocal. See below . Is there any chance of
have a disclosure authorization, so any talking points would have to be generic, focused on the bigger picture outl ined
below.
Eric Hall
Legislative Affairs
(202) 622-4057
Subject:
6103
6103
(b)(...
6103 6103
their determination yet. Per the news report below, I RS has requested substantial additional information from them, and it
Per the article, there have been allegations of similar
incidents by groups in other states. Susan Ohl, a staff m ember of Rep. Jim Jordan's, called this morning and said he has
(b)(5) DP
Subject: Clip:
(b)(3)/6103
(b)(3)/6103
(b)(5)/DP
6103 6103
6103
JW1559-019795
6103 6103
6103
6103
6103
6103
6103 6103
6103
6103
6103
(b)(3)/6103
6103
6103 6103
6103
6103 6103
6103
(b)(3); 6103
JW1559-019796
(b)(3); 6103
JW1559-019797
6103
6103
(b)(3); 6103
6103
6103
6103
6103
6103
6103
6103
6103
JW1559-019798
6103
6103
6103
6103
(b)(3); 6103
6103
6103
6103
6103
6103
6103
JW1559-019799
6103
(b)(3); 6103
6103
6103
6103
6103
6103
6103
6103
JW1559-019800
(b)(3); 6103
6103
JW1559-019801
6103
(b)(3); 6103
6103
6103
6103
JW1559-019802
(b)(3); 6103
6103
JW1559-019803
(b)(3); 6103
6103
JW1559-019804
(b)(3); 6103
6103
JW1559-019805
(b)(3); 6103
6103
JW1559-019806
(b)(3); 6103
6103
JW1559-019807
(b)(3); 6103
6103
JW1559-019808
(b)(3); 6103
6103
JW1559-019809
(b)(3); 6103
6103
JW1559-019810
(b)(3); 6103
6103
JW1559-019811
(b)(3); 6103
6103
JW1559-019812
(b)(3); 6103
6103
JW1559-019813
(b)(3); 6103
6103
JW1559-019814
(b)(3); 6103
6103
JW1559-019815
6103
6103
6103
6103
(b)(3); 6103
6103
JW1559-019816
6103
(b)(3); 6103
6103
6103
JW1559-019817
6103
6103
(b)(3); 6103
6103
JW1559-019818

P.O. Box 2508
Department of the Treasury
6103
6103
6103
6103
JW1559-019819
2
6103
6103
6103
JW1559-019820
3
6103
6103
6103
JW1559-019821
4
6103
6103
6103
JW1559-019822
Page 1
6103
6103
6103
6103
6103
6103
6103
6103
6103
6103
6103
5464-A
(4-97)
Form
Catalog Number 24265N
Department of the Treasury -
JW1559-019823
Page 2
6103
6103
6103
5464-A
(4-97)
Form
JW1559-019824
Page 3
6103
6103
6103
5464-A
(4-97)
Form
JW1559-019825
(b)(3); 6103
6103
JW1559-019826
(b)(3);
6103
6103
JW1559-019827
(b)(3);
6103
6103
JW1559-019828
(b)(3);
6103
6103
JW1559-019829
(b)(3);
6103
6103
JW1559-019830
(b)(3);
6103
6103
JW1559-019831
(b)(3);
6103
6103
JW1559-019832
(b)(3);
6103
6103
JW1559-019833
(b)(3);
6103
6103
JW1559-019834
(b)(3);
6103
6103
JW1559-019835
(b)(3);
6103
6103
JW1559-019836
(b)(3);
6103
6103
JW1559-019837
(b)(3);
6103
6103
JW1559-019838
(b)(3);
6103
6103
JW1559-019839
(b)(3);
6103
6103
JW1559-019840
(b)(3);
6103
6103
JW1559-019841
(b)(3);
6103
6103
JW1559-019842
(b)(3);
6103
6103
JW1559-019843
(b)(3);
6103
6103
JW1559-019844
(b)(3);
6103
6103
JW1559-019845
(b)(3);
6103
6103
JW1559-019846
From:
Grodnitzky Steven
Sent:
To:
Seto Michael C
Subject:
Attachments:
Thanks.
In the "EOT Projects and Non -case work items," Hillary should be listed under numbers 38 and 39.
Steven Grodnitzky
Manager, Technical Group 1
Exempt Organizations, Rulings and Agreements
Tax Exempt and Government Entities Division
U.S. Internal Revenue Service
Phone: (202) 283-8941
fax: (202) 283 -8937
To: Ghougasian Laurice A; Grodnitzky Steven; Lieber Theodore R; Seto Michael C; Shoemaker Ronald J
Cc: Trilli Darla J; Mackall Derek D; Danzey Rhonda; Salins Mary J
For your eyes only . . . do not distribute
To: Fish David L
technical assistance to EOD, EOQA , and EO Exam)
project, etc.)
a) 446 applications
c) 41 TAMs
JW1559-019847
From: Lerner Lois G
Cc: Paz Holly O
accounts and practitioner comments that lead me to believe we should be maki ng
from you.
do that--David--I forwarded it last night. I also need a list of everything else we ha ve sent to
things we've asked for informally. If it is informal , can I get who we're dealing with. I'd also
I'm sure there will be more, but this will give us a good start. I'd like the information by COB
Lois G. Lerner
JW1559-019848

*A SCR Case
(as of 11/7/11)
Taxpayer's Name:
Type of
Cases:
6103
6103
Referred to
Counsel
Date The Case

Assigned to:
Returned from
Counsel
Application
6103
5/17/2010
Courtney Jones
Application
6103
5/17/2010
Courtney Jones
Application
6103
5/17/2010
Courtney Jones
6/3/2011
Preston
Quesenberry
8/9/2011
Courtney Jones
Status / Comments
6103
6103
6103
6103
6103
TAM
6103
Application
6103
6103
6103
PLR
6103
(b)(3)/6103;
non-responsive
6103
6103
6103
6103
(b)(3)/6103; non-respo...
8/25/2011
Don Spellman
Application
6103
3/8/2011
Terri Haris
Application
6103
5/4/2011
Pam Kartha
6103
6103
6103
6103
Application
6103
10/7/2011
Application
6103
9/14/2011
6103
JW1559-019849
Manager) cases:
6103
Application
6103
4/25/2011
Pam Kartha
6103
Application
6103
8/10/2011
Courtney Jone
6103
PLR
6103
6103
10/21/2011
6103
: Date The Case
Referred to
Counsel
Type of
Cases:
6103
Application
6103
3/17/2011
Date The Case

Assigned to:
Returned from
Counsel
10/3/2011
Pam Kartha
(b)(3)/6103; non-...
Application
6103
6103
7/1/2011
8/29/2011
Preston
Quesenberry
6103
PLR
6103
5/31/2011
11/3/2011
Casey
Lothamer
6103
PLR
6103
5/24/2011
10/21/2011
David Marshall
6103
PLR
6103
5/24/2011
9/27/2011
David Marshall
6103
6103
6103
JW1559-019850
Counsel
Type of
Cases:
Referred to
Counsel
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
6103
6103
6103
TAM
6103
7/5/2011
Janet Laufer
PLR
6103
8/22/2007
Janet Laufer
PLR
6103
3/31/2011
(David Marshall
is the contact
person in
CC:TEGE:EO)
6103
(b)(3)/6103; non-...
6103
6103
6103
PLR
ust
6103
12/22/2010
Herbert (Lane)
Damaza and
Jim Hogan
PLR
6103
7/11/2011
Janet Laufer
6103
6103
JW1559-019851
1 IRM revision
T1
T2
T3
6 See comment
section for
names
1 (P. Thomas)
3 See comment
section for
names
1 (J. Zelaskco)
5 See comment
section for names
1 (P. Holiat)
1 (R. Cowen)
Project
12 Governance
15 ATAT
16 CIC
17 Fraud
22 PACI
27 VEBA Project
T4
4 See comment
section for names
1 (S. Barnett)
1 (D. Cowen)
1 (D. Cowen)
1 (McCray)
1 (L. Kastenberg)
1 (E. Berick)
1 (D. Moore)
1 (S. Robbins)
1 (E. Kastenberg)
1 (E. Berick)
1 (K. Burns)
1 (K. Burns)
1 (D. Smith)
1 (McNaughton)
1
1
1
1
1
1
1
1
1
1
1
(Biss)
(Biss)
(Smith)
(Phaup)
(Phaup)
(Phaup)
(A. Beckwith)
(A. Beckwith)
(A. Beckwith)
(E. Mangrum)
(H. Goehausen)
1 (H. Goehausen)
1 (J. Zelasko)
1 (J. Zelasko)
1 S. Copeland)
1 (O. Chukuanu)
JW1559-019852
T1
T2
T3
B. Guidance Items
30
1 (M. Perdoni)
2 (M. McNaughton
& G. Gluth)
1 (S. Copeland)
2 (J. Mackay & E.
Mangrum)
1 (S. Robbins)
32 FOIA processing
1 (J. Mackay)
1 (Schantz)
1 (Schantz)
1 (P. Thomas)
1 (A. Beckwith)
2 (J. Kovac & D.
Smith)
1 (O. Chukwuanu)
1 (Chip Hull)
1 (A. Beckwith)
T4
1 (E. Kastenberg)
1 (J. Kovac)
2 (E. Berrick & L.
Fischer-Dibacco)
1 (L. Orcino)
1 (P. Thomas)
JW1559-019853
Recognition team
CFC
T1
T2
T3
1 (D. Moore)
44
45
46
T4
1 (P. Holiat)
1 (M. Perdoni)
1 (K. Burns)
1 (A. Beckwith)
1 (S. Robbins)
1 (K. Burns)
1 (E. Kastenberg)
JW1559-019854
From:
Grodnitzky Steven
Sent:
To:
Seto Michael C
Subject:
Agreed. When you see it on one page, it really brings it to light.
Steven Grodnitzky
Phone: (202) 283-8941
fax: (202) 283 -8937
To: Grodnitzky Steven
Thanks for the update. We are doing a lot!
From: Grodnitzky Steven
To: Seto Michael C
Thanks.
In the "EOT Projects and Non -case work items," Hillary should be listed under numbers 38 and 39.
Steven Grodnitzky
Phone: (202) 283-8941
fax: (202) 283 -8937
JW1559-019855
To: Fish David L
project, etc.)
a) 446 applications
c) 41 TAMs
From: Lerner Lois G
Cc: Paz Holly O
I'm getting a little nervous about the amount we have on our plate an d how we are handling. I
from you.
JW1559-019856
things we've asked for informally. If it is informal, can I get who we're dealing w ith. I'd also
I'm sure there will be more, but this will give us a g ood start. I'd like the information by COB
Lois G. Lerner
JW1559-019857
From:
Seto Michael C
Sent:
Wednesday, November 09, 2011 12:38 PM
To:
Seto Michael C; Ghougasian Laurice A; Grodnitzky Steven; Lieber Theodore R;
Cc:
Trilli Darla J; Mackall Derek D; Salins Mary J; Megosh Andy
Subject:
Attachments:
EOT Projects & Non-case work items.xls
Shoemaker Ronald J
I updated the non-case work items to reflect additional personnel assigned to certain work items/projects in T1 and
T3. For your eyes only
Cc: Trilli Darla J; Mackall Derek D; Danzey Rhonda; Sal ins Mary J
To: Fish David L
project, etc.)
a) 446 applications
c) 41 TAMs
Some of the cases are on hold such as the co-investment PLRs and open sources applications pending counsel
From: Lerner Lois G
JW1559-019858
Cc: Paz Holly O
know everyone is working h ard and juggling, but I am wondering whether the juggling
focus of DC work. And, in both cases, the hold up might really relate to somethin g sitting in
from you.
Lois G. Lerner
JW1559-019859
1 IRM revision
T1
T2
T3
6 See comment
section for
names
1 (P. Thomas)
3 See comment
section for
names
1 (J. Zelaskco)
Project
12 Governance
15 ATAT
16 CIC
17 Fraud
22 PACI
27 VEBA Project
T4
4 See comment
section for names
1 (P. Holiat)
1 (P. Holiat)
5 See comment
section for names
1 (S. Barnett)
1 (D. Cowen)
1 (D. Cowen)
1 (McCray)
1 (L. Kastenberg)
1 (E. Berick)
1 (D. Moore)
1 (S. Robbins)
1 (E. Kastenberg)
1
1
1
1
(R. Cowen)
(E. Berick)
(K. Burns)
(K. Burns)
1 (D. Smith)
1 (McNaughton)
1
1
1
1
1
1
1
1
1
1
1
(M. Biss)
(M. Biss)
(D. Smith)
(Phaup)
(Phaup)
(Phaup)
(A. Beckwith)
(A. Beckwith)
(A. Beckwith)
(E. Mangrum)
(H. Goehausen)
1 (H. Goehausen)
1 (J. Zelasko)
1 (J. Zelasko)
1 S. Copeland)
1 (O. Chukuanu)
JW1559-019860
T1
T2
T3
B. Guidance Items
30
1 (M. Perdoni)
2 (M. McNaughton
& G. Gluth)
1 (S. Copeland)
2 (J. Mackay & E.
Mangrum)
1 (S. Robbins)
32 FOIA processing
1 (J. Mackay)
1 (Schantz)
1 (Schantz)
1 (P. Thomas)
1 (A. Beckwith)
2 (J. Kovac & D.
Smith)
1 (O. Chukwuanu)
1 (Chip Hull)
1 (H. Goehausen)
1 (H. Goehausen)
1 (A. Beckwith)
1 (E. Kastenberg)
T4
1 (J. Kovac)
2 (E. Berrick & L.
Fischer-Dibacco)
1 (L. Orcino)
1 (P. Thomas)
JW1559-019861
Recognition team
CFC
T1
T2
T3
1 (D. Moore)
44
45
46
T4
1 (P. Holiat)
1 (M. Perdoni)
1 (K. Burns)
1 (A. Beckwith)
1 (S. Robbins)
1 (K. Burns)
1 (E. Kastenberg)
JW1559-019862
From:
Seto Michael C
Sent:
Monday, November 14, 2011 3:22 PM
To:
Megosh Andy; Salins Mary J; Repass Mike; Ghougasian Laurice A; Grodnitzky Steven;
Cc:
Trilli Darla J; Mackall Derek D
Subject:
FW: Report of SCR Cases
Attachments:
SCR Report Table Oct.doc
Lieber Theodore R; Seto Michael C; Shoemaker Ronald J
To: Lerner Lois G; Light Sharon P; Kindell Judith E; Letourneau Diane L
Cc: Fish David L; Trilli Darla J; Neuhart Paige
Subject: Report of SCR Cases
Summary of SCR cases for October 2011.
JW1559-019863
EO Technical
(October 31, 2011)
22 open SCs
A. Open SCs:
Name of
Org/Group
Group
#/Manager
EIN
1.
Received
4/2/2010
Political Advocacy
Organizations
T2/Ron
Shoemaker
6103
(1)
(2)
Issue
Tax Law
Estimated
Date

Chip Hull &

Hilary
Goehausen
6103
(3)
03/31/2011
(Orig)
05/31/2011
(Rev)
07/31/2011
(Rev)
10/30/2011
(Rev)
12/31/2011
(Rev)
Status/Next action
Being Elevated
to TEGE
Commissioner
This Month
No
Met with

cases; Counsel recommended further
development of the cas es by getting

case returned to EOT for additional
information and preparing another
proposed denial revised and forwarded
to Chief Counsel for review on
07/19/11.
2.
6103
6103
JW1559-019864
3.
6103
P2 Andy
Megosh
Justin Lowe
6103
Next Action:
4.
6103
P2/ Andy
Megosh
6103
Justin Lowe
Whether
.
JW1559-019865
.
Next Action:
.
5.
6103
6.
6103
6103
6103
7.
6103
6103
JW1559-019866
8.
6103
6103
6103
6103
9.
6103
6103
6103
6103
6103
6103
6103
6103
6103
6103
JW1559-019867
10.
6103 6103
6103
6103
6103
11.
6103
6103
6103
6103
12.
6103
6103
JW1559-019868
13.
6103
6103
14.
JW1559-019869
15.
6103
6103
6103
6103
16.
6103
6103
JW1559-019870
17.
6103
6103
18.
19.
JW1559-019871
6103
61036103
20.
6103
6103
6103
21.
6103
22.
6103
6103
6103
B. Closed SCs- None
JW1559-019872
From:
Seto Michael C
Sent:
To:
Ghougasian Laurice A
Cc:
Trilli Darla J
Subject:
Thanks for pushing on this case! Mike
From: Ghougasian Laurice A
To: Seto Michael C
Cc: Trilli Darla J
Chief Counsels (PSI) review of
(b)(3); 6103
, #5 at the bottom, is complete.
To: Fish David L
ACA case screening, politi cal advocacy case screening, etc.) to minor time commitment (recognition team, governance
project, etc.)
a) 446 applications
c) 41 TAMs
JW1559-019873
From: Lerner Lois G
Cc: Paz Holly O
know everyone is working hard and jugg ling, but I am wondering whether the juggling
may not seem important i n Cincinnati, may be crucial in DC. Similarly, DC may be prioritizing
from you.
the backlog--I.e.--are you waiting for assistance f rom R & A, are you focusing on something
like some sense of the inventory that doesn't fall within these categorie s that looks like it
Lois G. Lerner
JW1559-019874
From:
Paz Holly O
Sent:
To:
Seto Michael C
Subject:
Attachments:
Follow Up Flag:
Follow up
Flag Status:
Flagged
Categories:
Red Category
Can you please send me updated versions of both attachments when you get a chance?
Thanks!
To: Fish David L
project, etc.)
a) 446 applications
c) 41 TAMs
From: Lerner Lois G
Cc: Paz Holly O
decisions are being made holis tically enough. We have only so many resources and things
JW1559-019875
from you.
else that impacts your ability to g et this piece done. Also, are there kinds of cases that DC
Lois G. Lerner
JW1559-019876

*A SCR Case
(as of 11/7/11)
Taxpayer's Name:
Type of
Cases:
Referred to
Counsel
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
EO Technical Group 1 (Steve Grodnitzky,
Manager) Cases:
Application
5/17/2010
Application
5/17/2010
Application
(b)(3); 6103
(b)(3); 6103
5/17/2010
in two weeks
in two weeks
in two weeks
Preston
In process
Quesenberry
TAM
6/3/2011
Application
8/9/2011
8/25/2011
Don Spellman
Manager) Cases:
(b)(3); 6103
PLR
(b)(3); 61...
Expect to receive comments
the week of October 31
EO Technical Group 3 (Ted Lieber,
Manager) Cases:
eApplication
3/8/2011
Terri Haris
On hold
Application
5/4/2011
Pam Kartha
Denial of exemption proposed: Not started yet.
Pam will work before (b)(3); ...
(b)(3); 6103
(b)(3); 6103
(b)(3); 6103
Application
10/7/2011
10
Application
9/14/2011
JW1559-019877
Manager) cases:
11
4/25/2011
Pam Kartha
Application
8/10/2011
PLR
10/21/2011
Application
Denial of exemption proposed adverse. In
process
6103
12
6103
13
B 5 cases have been reviewed by and
returned from Counsel CC:TEGE:EO
6103
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
3/17/2011
10/3/2011
Pam Kartha
Application
7/1/2011
8/29/2011
Preston
Quesenberry
Counsel concurred with
proposed denial of
exemption to EOT and
provided comments and
recommendations to revise
the denial letter.
recommendations.
PLR
5/31/2011
11/3/2011
Casey
Lothamer
Type of
Cases:
*
Application
(EOT Group 4 case)
Request for TA
6103
Referred to
Counsel
6103
6103
recommendations.
PLR
5/24/2011
10/21/2011
EOT with comments.
PLR
5/24/2011
9/27/2011
EOT with comments.
JW1559-019878
Counsel
Type of
Cases:
Referred to
Counsel
Date The Case

Assigned to:
Returned from
Counsel
Status / Comments
Manager) Cases:
1
2
TAM
(b)(3); 6103
PLR
7/5/2011
(b)(3); 6103
PLR
3/31/2011
EO Technical Group 4 (Laurice Ghougasian,
Acting Manager) Cases:
4
Trust
PLR
PLR
case
In TEGE Counsel
Janet Laufer
Pending
caseCounsel referred the
(David Marshall EO
case to CC:Corp & CC:P&A
is the contact
person in
CC:TEGE:EO)
12/22/2010
Herbert (Lane)
Pending in PSI
Damaza and
Jim Hogan
7/11/2011
Janet Laufer
(b)(3); 6103
(b)(3); 6103
8/22/2007
Janet Laufer
case
JW1559-019879
1 IRM revision
T1
T2
T3
6 See comment
section for
names
1 (P. Thomas)
3 See comment
section for
names
1 (J. Zelaskco)
5 See comment
section for names
1 (P. Holiat)
1 (R. Cowen)
Project
12 Governance
15 ATAT
16 CIC
17 Fraud
22 PACI
27 VEBA Project
T4
4 See comment
section for names
1 (S. Barnett)
1 (D. Cowen)
1 (D. Cowen)
1 (McCray)
1 (L. Kastenberg)
1 (E. Berick)
1 (D. Moore)
1 (S. Robbins)
1 (E. Kastenberg)
1 (E. Berick)
1 (K. Burns)
1 (K. Burns)
1 (D. Smith)
1 (McNaughton)
1
1
1
1
1
1
1
1
1
1
1
(Biss)
(Biss)
(Smith)
(Phaup)
(Phaup)
(Phaup)
(A. Beckwith)
(A. Beckwith)
(A. Beckwith)
(E. Mangrum)
(H. Goehausen)
1 (H. Goehausen)
1 (J. Zelasko)
1 (J. Zelasko)
1 S. Copeland)
1 (O. Chukuanu)
JW1559-019880
T1
T2
T3
B. Guidance Items
30
1 (M. Perdoni)
2 (M. McNaughton
& G. Gluth)
1 (S. Copeland)
2 (J. Mackay & E.
Mangrum)
1 (S. Robbins)
32 FOIA processing
1 (J. Mackay)
1 (Schantz)
1 (Schantz)
1 (P. Thomas)
1 (A. Beckwith)
2 (J. Kovac & D.
Smith)
1 (O. Chukwuanu)
1 (Chip Hull)
1 (A. Beckwith)
T4
1 (E. Kastenberg)
1 (J. Kovac)
2 (E. Berrick & L.
Fischer-Dibacco)
1 (L. Orcino)
1 (P. Thomas)
JW1559-019881
Recognition team
CFC
T1
T2
T3
1 (D. Moore)
44
45
46
T4
1 (P. Holiat)
1 (M. Perdoni)
1 (K. Burns)
1 (A. Beckwith)
1 (S. Robbins)
1 (K. Burns)
1 (E. Kastenberg)
JW1559-019882
From:
Seto Michael C
Sent:
Saturday, October 15, 2011 1:58 PM
To:
Megosh Andy; Repass Mike; Grodnitzky Steven; Lieber Theodore R; Salins Mary J; Seto
Cc:
Mackall Derek D; Danzey Rhonda
Subject:
FW: SCR Report for September 2011
Attachments:
SCR Report Table Sept 2011.doc
Michael C; Shoemaker Ronald J
FYI
Sent: Saturday, October 15, 2011 2:57 PM
To: Lerner Lois G; Letourneau Diane L; Light Sharon P; Kindell Judith E
Cc: Paz Holly O; Neuhart Paige; Fish David L; Abner Donna J; Thomas Cindy M; Trilli D arla J; Lieber Theodore R
Subject: SCR Report for September 2011
The cases are moving but no closures in September.
(b)(3)\6103
JW1559-019883
EO Technical
( September 30, 2011)
22 open SCs
A. Open SCs:
Name of
Org/Group
Group
#/Manager
EIN
1.
Received
4/2/2010
Political Advocacy
T2/Ron
Organizations
Shoemaker
and
Issue
Tax Law
Estimated
Date
Whether a tea party organization
Chip Hull &
meets the requirements under

Hilary
section 501(c)(3) and is not involved

Goehausen
in political intervention. Whether
3/31/2011 (Orig)
05/31/2011
(Rev)
07/31/2011
(Rev)
10/30/2011
(Rev)
12/31/2011
(Rev)
Status/Next action
Being Elevated
to TEGE
Commissioner
This Month
No
cases. Proposed (c)(4) favorable is
currently being reviewed. Proposed
denial currently being reviewed on
(c)(3). Cases were discussed with Judy
Kindell on 04/06/11. Judy requested
staff to get additional information from
taxpayers regarding certain activities.
Development letters were sent.

Proposed favorable (c)(4) ruling
forwarded to Chief Counsel for
comments on 05/04/11. Information from
(c)(3) organization regarding activities
due on 05/18/2011.Waiting on taxpayer
response. : Met with Director EO on
June 29, 2011. Met with Counsel on
8/10/11 to discuss the cases; Counsel
recommended further development of
the cases by getting information on the
organizations 2010 activities. Counsel
gave us directions on the type of
information needed.
.
Next Action:
JW1559-019884
2
2.
3.
P2 Andy
Megosh
Justin Lowe
.
JW1559-019885
Next Action:
4.
P2/ Andy
Megosh
Justin Lowe
W
.
.
Next Action:
.
5.
6.
JW1559-019886
7.
8.
9.
JW1559-019887
10.
JW1559-019888
6
11.
12.
13.
JW1559-019889
14.
15.
JW1559-019890
16.
17.
JW1559-019891
9
18.
19.
20.
21.
JW1559-019892
10
22.
B. Closed SCs- None
JW1559-019893
From:
Seto Michael C
Sent:
To:
Grodnitzky Steven; Salins Mary J; Shoemaker Ronald J; Lieber Theodore R; Park Nalee;
Cc:
Trilli Darla J
Subject:
FW: Significant Case Report for January 2012
Attachments:
SCR Report Table Jan 2012.doc
Megosh Andy
FYI
Cc: Paz Holly O; Fish David L; Trilli Darla J; Neuhart Paige; Marx Dawn R; Abner Donna J; Thomas Cindy
Subject: Significant Case Report for January 2012
Highlights:
A. Closures
We have no closures for January.
B. Specific Cases
(item 6) -
(b)(3); 6103
Exemption applications / pooled trust cases (item 8) - We have four pending applications, and each is in different
stages of development. Once development of the cases is done, the initial denials will be drafted.
Before issuing
them to the taxpayers, we will get input from Counsel.
PLR /
. -(item 17) -
(b)(3); 6103
JW1559-019894
EO Technical
( January 31, 2012)
21 open SCs
A. Open SCs:
Name
Org/Group
Group
#/Manager
1.
EIN
(2)
Political Advocacy
Organizations
(1)
T1 Steve
Grodnitzky
and
(3)
Received
4/2/2010
Issue
Tax Law
Estimated
Date

Hilary

Goehausen
(2)
(
(3)
03/31/2011
(Orig)
05/31/2011
(Rev)
07/31/2011
(Rev)
10/30/2011
(Rev)
12/31/2011
(Rev)
02/29/2012
(Rev)
05/31/2012
(Rev)
Status/Next action
Being Elevated
to TEGE
Commissioner
This Month
No
Met with

cases; Counsel recommended fu rther
development of the cases by getting

received taxpayer response to third

development letter , tls reviewing.
Organization (3) to be closed FTE.
2.
JW1559-019895
2
3.
P2 Andy
Megosh
Justin Lowe
.
.
Next Action:
.
4.
P2/ Andy
Megosh
Justin Lowe
.
JW1559-019896
Next Action:
.
5.
6.
JW1559-019897
4
7.
8.
JW1559-019898
9.
10.
JW1559-019899
11.
12.
JW1559-019900
13.
14.
JW1559-019901
8
15.
16.
JW1559-019902
17.
18.
JW1559-019903
10
19.
20.
21.
JW1559-019904
11
B. Closed SCs-
None.
JW1559-019905
From:
Davis Jonathan M (Wash DC)
Sent:
To:
Shulman Doug
Subject:
FW: Letter for Commissioner Shulman
Attachments:
TaxExempts Letter.pdf
I wanted to be sure that someone had alerted you to this letter that came in today. It is
another letter from Rep Boustany - asking for lots of statistics about TE/GE
compliance. General stuff - budget, headcount, how many audits, asks about hospitals,
universities, UBIT, etc. Pretty wide-ranging, more oversight than investigative.
thanks
To: Miller Steven T; Davis Jonathan M (Wash DC); Flax Nikole C; Campbell Carol A; Grant Joseph H; Lerner Lois G; Urban
Joseph J; Dash Mary L; Hinton Irma D ; Alexander Bonnie; Marks Nancy J
Cc: Landes Scott S; Norton William G Jr
Subject: FW: Letter for Commissioner Shulman
FYI-- We just received this letter from the Ways and Means Subcommittee on Oversight.
It asks for a large amount of data. The requested due date is October 20.
The letter is divided into the following subject areas:
1.
Overview of the tax -exempt sector;
2.
Compliance;
3.
Unrelated Business Income;
4.
Audits; and
5.
Current tax-exempt enforcement initiatives.
Hi Floyd Please find attached a letter for Commissioner Shulman regarding the tax -exempt sector. Also, a hard copy is in the
mail.
Let me know if you have any questions.
Thanks,
Lauren
Lauren Savory
Legislative Assistan t
JW1559-019906
Committee on Ways and Mean s
Subcommittee on Oversigh t
1136 Longworth HO B
202.225.552 2
JW1559-019907
JW1559-019908
JW1559-019909
JW1559-019910
JW1559-019911
JW1559-019912
From:
Waddell Jon M
Sent:
Monday, January 23, 2012 1:31 PM
To:
Angner William J
Subject:
RE: Significant Case Report for December 2011
Importance:
Low
The credit "all" goes to you.
From: Angner William J
Sent: Monday, January 23, 2012 2:27 PM
To: Waddell Jon M
Subject: FW: Significant Case Report for December 2011
(b)(3); 6103
still lives........
From: Esrig Bonnie A
Sent: Monday, January 23, 2012 11:32 AM
To: Angner William J; Berry Daniel W; Bibb Kenneth B; Brinkley Lynn A; Haley Philip H; Jefferson -White Beverly J; Lewis
Jovonnie; Shankling Lonnie; Waddell Jon M
Subject: FW: Significant Case Report for D ecember 2011
Importance: Low
FYI
Sent: Saturday, January 21, 2012 4:09 PM
To: Combs Peggy L; Esrig Bonnie A; Bowling Steven F; Lahey Victoria; Shafer John H
Cc: Chumney Tyler N
Subject: FYI: Significant Case Report for December 2011
Importance: Low
Attached is a table that includes information regarding the EO R&A Sensitive Case Reports (if you are interested).
Sent: Wednesday, January 18, 2012 12:42 PM
Cc: Marx Dawn R; Fish David L; Trilli Darla J; Neuhart Paige; Thomas Cindy M; Abner Donna J
Subject: Significant Case Report for December 2011
Highlights:
JW1559-019913
A. Closures
We have 1 closure in December,

.
(b)(3); 6103
(b)(3); 6103
B. Specific Cases
Exemption application / Political Advocacy Cases (item 1) in

(b)(3); 6103
(b)(3); 6103
(item 6) -
(b)(3); 6103
(b)(3)\6103
(b)(3); 6103
Exemption application
(item 22) -
(b)(3); 6103
(b)(3)\6103
(b)(3); 6103
PLR /
(b)(3); 6103
. -(item 17) -
(b)(3)\6103
(b)(3)\6...
(b)(3); 6103
(b)(3)\6103
JW1559-019914

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Obtained by Judicial Watch, Inc.

Wednesday, September 15, 2010 11:26 AM

Downing Nanette M; Choi Robert S

FW: EO Tax Journal 2010-130

More fuel for the potential c4 project fire

Director, Exempt Organizations

From: paul streckfus [mailto:pstreckfus@gmail.com]

Sent: Wednesday, September 15, 2010 12:20 PM

To: paul streckfus

Subject: EO Tax Journal 2010 -130

From the Desk of Paul Streckfus,

Editor, EO Tax Journal

Email Update 2010-130 (Wednesday, September 15, 2010)

Copyright 2010 Paul Streckfus

e. I feel for the

IRS's dilemma, especially in this wildly polarized election year.

Obtained by Judicial Watch, Inc. via FOIA

file account to which to post receipt of the return.

agent to analyze, essentially instigating the process you describe.

tax exemption system?

strengthen the filing requirements.

disallowed if a (c)(3) is being used as a conduit to a (c)(4).

Obtained by Judicial Watch, Inc. via FOIA

Friday, February 24, 2012 11:06 AM

Draft of Advocacy Org Guide Sheet

Advocacy Org Guidesheet 11-3-2011.doc

David and I gave it a quick read. It's

We'll get a working group together with EO to work on this.

Please let me know if you have questions/concerns,etc.

From: Paz Holly O [mailto:Holly.O.Paz@irs.gov ]

Sent: Friday, February 24, 2012 11:09 AM

To: Spellmann Don R

Cc: Lerner Lois G; Kindell Judith E

Subject: FW: Draft of Advocacy Org Guide Sheet

Here is the document for review.

From: Goehausen Hilary

Sent: Monday, November 21, 2011 9:45 AM

To: Ardoin Elizabeth A; Elliot -Moore Donna

Cc: Seto Michael C

Subject: Draft of Advocacy Org Guide Sheet

Hi Liz and Donna,

find it helpful for your cases.

Tax Law Specialist

1111 Constitution Ave., NW

Washington, D.C. 20224

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

Wednesday, February 29, 2012 2:01 PM

Age of Draft Advocacy Org Guide Sheet

Advocacy Org Guidesheet 11-3-2011.doc

just anxious to share it.

Susan, David M and I had a good planning meeting this morning.