File 06162012

Tab 1 - Potential Abusive Historical

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 File 06162012

Tab 2 - Potential Abusive

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Corporation Sole The AOI and application will refer to "corporation sole" or "corporate sole". Forward case to Group 7824 Open
Form 1023 may show only one person involved with the applicant. Titles like
Overseer, Elder, Patriarch, Matriarch, Administrator, Pastor, etc. The

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applicant mayor may not request church classification.
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3 Fictitious Exemption Determination letter submitted appears questionable. May include incorrect Forward case to Group 7824 Open
5 Letter information or may appear invalid due to format, font, etc.
4 Puerto Rico_ Applicant usually has a Puerto Rico address. Activities involve elderly or low-
income housing, operating a school, and head-start programs. The return
address on the original or photocopy of the envelope may b'4• •
Federal government
grants is listed as the primary source of income. Other identifying factors
include intention t6 b,.;;u.ild.a.4.2.u.n.it.fa.c.il.ity.,.n.o.oilwllnlle.rs.h.iP.of.p.r.o.pe~rt.y., • • •
application showing.

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 8 Charity Owned Ufe Applicant may show that it is the beneficiary of an insurance policy and/or Forward caseto Group 7824 Open
Insurance (CHOLl) annuity. Individual loans money (possibly their IRA) to the charity; charity
or Annuity used the money to pay the policy costs/premiums and in turn the charity pays
to the donor interest oil the loan. May be referred to as a Charity Owned Life
Insurance (CHOU). May be administered by • • • • • • • • • •
• 1I!!I• • • • • • • • • ••
II!I!I~ ,may also be mentioned in the
~pplication. Program involves a high value insurance policy, where the
applicant will receive 10% of the face value of the insurance if they show that
they are 501(c)(3).
9

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11 Potentially Abusive Private foundations with identical narrative descriptions, 5 page trust . Forward case to Group 7824 Open
Family Foundation agreements, and husband I wife trustees.
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12 Pain Management Pain management clinics in applying for exemption under 501 (c){3)of Forward case to Group 7824 Open
Clinics the Code. These clinics appear to be involved in abusive schemes as they
are forming to avoid state licensing and oversight requirements.
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Forward case to Group 7824 Open

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Tab 3 - Emerging Issues

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501 (c)(3), 501 (c)(4),. 501(c)(5), and 501 (c)(6) organizations with indicators of significant x Forward case to Group 7822. Open
amounts of political campaign intervention (raising questions as to exempt purpose
and/or excess private benefit). Note: advocacy action type issues (e.g., lobbying) that
are currently listed on the Case Assignment Guide (CAG) do not meet this criteria.

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Tab 4 - Coordinated Processing

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Group Rulings Cases that involve group rulings, whether parent applying for; or subordinate 5 Forward case to Group 7829 Open - 8/25/11
leaving a group ruling need to be worked in Group 7829. The only exception is
cases that have been auto revoked ..
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Tab 5 - Watch List

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Medical Cases involving Medical Marijuana 2010-#1 Forward case to Group 7888. (b) (6) (coordinator). Note: Open- 7
Marijuana the· coordinator has permission to close "exclusively educational" 15-10
organizations.

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Fire Fighter organizations located in will be filing for
retroactive reinstatement of exempt status ue to the Auto-Revocation project. (b) (6)

Green Energy Organizations applying for 501 C-3 status by providing green energy (electricity/power) to 14 2011-#1 Coordinate processing with(b) (6) Group 7827. Open-
Organizations other organizations . 7/11/11

12

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