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File 06162012

Tab 1 - Potential Abusive Historical

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File 06162012

Tab 2 - Potential Abusive

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Open

Open

-Forward case to Group 7824

Forward case to Group 7824

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. Theapplicant mayor may not request church classification.

Puerto Rico_ Applicant usually has a Puerto Rico address. Activities involve elderly or low­income housing, operating a school, and head-start programs. The returnaddress on the original or photocopy of the envelope may b'4••

Federal governmentgrants 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.

Fictitious Exemption Determination letter submitted appears questionable. May include incorrectLetter information or may appear invalid due to format, font, etc.

Corporation Sole

4

3

•5

4

3

2

6

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9

8 Charity Owned UfeInsurance (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 turn the charity paysto the donor interest oil the loan. May be referred to as a Charity Owned LifeInsurance (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 theapplicant will receive 10% of the face value of the insurance if they show thatthey are 501(c)(3).

Forward caseto Group 7824 Open

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10

11

12

11 Potentially Abusive Private foundations with identical narrative descriptions, 5 page trustFamily Foundation agreements, and husband I wife trustees.

. Forward case to Group 7824 Open

12 Pain ManagementClinics

Pain management clinics in applying for exemption under 501 (c){3)ofthe Code. These clinics appear to be involved in abusive schemes as theyare forming to avoid state licensing and oversight requirements.

Forward case to Group 7824 Open

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14

15

16

Forward case to Group 7824 Open

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File 06162012

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 significantamounts ofpolitical campaign intervention (raising questions as to exempt purposeand/or excess private benefit). Note: advocacy action type issues (e.g., lobbying) thatare currently listed on the Case Assignment Guide (CAG) do not meet this criteria.

x Forward case to Group 7822. Open

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File 06162012

Tab 4 - Coordinated Processing

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5

6

Group Rulings Cases that involve group rulings, whether parent applying for; or subordinateleaving a group ruling need to be worked in Group 7829. The only exception iscases that have been auto revoked..

5 Forward case to Group 7829 Open - 8/25/11

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File 06162012

Tab 5 - Watch List

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4Medical

MarijuanaCases involving Medical Marijuana 2010-#1 Forward case to Group 7888. (coordinator). Note:

the·coordinator has permission to close "exclusively educational"organizations.

Open- 715-10

8Fire Fighter organizations located in will be filing forretroactive reinstatement of exempt status ue to the Auto-Revocation project.

Green Energy Organizations applying for 501 C-3 status by providing green energy (electricity/power) toOrganizations other organizations .

12

14 2011-#1 Coordinate processing with Group 7827. Open­7/11/11

(b) (6)

(b) (6)

(b) (6)

(b) (6)

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17

18