Document012 Redacted 041013
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Transcript of Document012 Redacted 041013
IRS0000001525
File 04102013
Tab 1- P'otential Abusive Historical
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4 Pu_R1~ Applicant usually has a Puerto RIcoaddress. ActMties involve elderly or lowincome housing, operating 8 school, andhead-start programs. The return address.on:~ or @otoCOPyoftheenvetope
Federalgovernment grants Is ed as the primarySOlXce of income. Other identifying factorsindude intention to buld a 42 unit faciity, noownership of property, application showing
These cases are baslcalty NECls but aD of PF status Is being requested. Case gradethem have not filed Forms 99O-PF as they should be 12. Contributions paid out mayare required to dQ. Some trusts fled Form exceed $1 0,000 even though a $150 user1041 and some <id not. fee was paid.
Questionablefinancial data.
Forward case toGroup 7827
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11 Potentialty Abusive FamilyFoundation
12 Pain Management cmics Pain management appfyingfor exemption Wlder 501 (c 3) of the Code.These clinics appear to be invofved inabusive sChemes as they are forming toavoid state licensing and oversightrequirements.
Forward case toGroup 7827
Forwardc:asetoGroup 7827
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File 04102013
Tab 2 - Potential Abusive
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Corporation Sole The AOI and application will refer to "corporation sole" or "corporate sole".Form 1023 may show only one person involved with the applicant Titles likeOverseer, Elder, Patriarch, Matriarch, Administrator, Pastor, etc. The
. applicant mayor may not request church classification.
Fictitious Exemption Determination letter sUbmitted appears questionable. May include incorrectLetter information or may appear invalid due to format, font, etc.
Forward case to Group 7827
Forward case to Group 7827
..,
Open
Open
£
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8 Charity Owned LifeInsurance (CHOLl)or Annuity
Applicant may show that it is the beneficiary of an insurance policy and/orannuity. Individual loans money (possibly their IRA) to the charity; charityused the money to pay the policy costs/premiums and in tum the charity pays
to the donor interest on the loan. May be ref.e:;rr.ed..t~o.aijsiailciih_a,ril%IIOwn"led~Llif.eInsurance (CHOLl). May be administered b;y-. •••~lII_•••••II••••may also be mentioned in theapplication. Program involves a high value insurance policy,where theapplicant will receive 10% of the face value of the insurance if they show thatthey are 501 (c)(3).
. Forward case to Group 7827
Open
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File 04102013
Tab 3 - Emerging Issues
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Current Political 501(c)(3), 501(c)(4), 501 (c)(5), and 501 (c)(6) organizations with i(ldicators of significantIssues 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 arecurrently listed on the Case Assignment Guide (CAG) do not meet this criteria.
EI-1 x Forward case to Group 7823. Open
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File 04102013
Tab 4 - Coordinated Processing
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File 04102013
Tab 5 - Watch List
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(b) (6)
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Paying National Organizations formed to pay down the national detitDebt
26 201.2 -#1 Forward case to Group 7823 to coordinate with Open 3/26/12EOTlEOG.
Supporting Forms 1023 and 8940 submitted by organizations seeking SO status as follows:Organizations 1) Type I where there is other than the unconditional power to appoint and remove the
(SO's) - 509(a)(3) majority of the directors or trustees. and2) Types I or " where there is more than one supported organization (whether specified byname or designated by class or purpose) or where it appears that the supportedorganization does not unconditionally control the supporting organization.
27 2013-#1 Transfer case to EOT. Open 3/22113