The Internal Revenue Service has revoked its determination that the
organization listed below qualifies as an organization described in sections
501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.
Generally, the Service will not disallow deductions for contributions
made to a listed organization on or before the date of announcement in the
Internal Revenue Bulletin that an organization no longer qualifies. However,
the Service is not precluded from disallowing a deduction for any contributions
made after an organization ceases to qualify under section 170(c)(2) if the
organization has not timely filed a suit for declaratory judgment under section
7428 and if the contributor (1) had knowledge of the revocation of the ruling
or determination letter, (2) was aware that such revocation was imminent,
or (3) was in part responsible for or was aware of the activities or omissions
of the organization that brought about this revocation.
If on the other hand a suit for declaratory judgment has been timely
filed, contributions from individuals and organizations described in section
170(c)(2) that are otherwise allowable will continue to be deductible. Protection
under section 7428(c) would begin on June 27, 2005, and would end on the date
the court first determines that the organization is not described in section
170(c)(2) as more particularly set forth in section 7428(c)(1). For individual
contributors, the maximum deduction protected is $1,000, with a husband and
wife treated as one contributor. This benefit is not extended to any individual,
in whole or in part, for the acts or omissions of the organization that were
the basis for revocation.
|University Lithotripsy Affiliates, Inc.
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