IRS Published Taxpayer Determination Letter 202629019

Private letter rulings and published taxpayer determination letters. Native document type is retained separately; a determination letter is not labeled a private letter ruling. These taxpayer-specific releases cannot be used or cited as precedent under 26 USC 6110(k)(3); applicability and current legal force are not independently certified. Keep repeated UILC subjects attached to one actual numbered document. Native kind: determination letter; this is not a private letter ruling.

Department of the Treasury
Internal Revenue Service
Tax Exempt and Government Entities

IRS

Date:
04/20/2026

Employer ID number:

Form you must file:

Tax years:

Release Number: 202629019

Release Date: 7/17/26

UIL Code: 501.04-00, 501.04-01

Person to contact:

Name:

ID number:

Telephone:

Dear

This letter is our final determination that you don't qualify for exemption from federal income tax under Internal
Revenue Code (IRC) Section 501(a) as an organization described in IRC Section 501(c)(4). Recently, we sent
you a proposed adverse determination in response to your application. The proposed adverse determination
explained the facts, law, and basis for our conclusion, and it gave you 30 days to file a protest. Because we
didn't receive a protest within the required 30 days, the proposed determination is now final.

You must file the federal income tax forms for the tax years shown above within 30 days from the date of this
letter unless you request an extension of time to file. For further instructions, forms, and information, visit
www.irs.gov.

We'll make this final adverse determination letter and the proposed adverse determination letter available for
public inspection after deleting certain identifying information. as required by IRC Section 6110. Read the
enclosed Letter 437, Notice of Intention to Disclose - Rulings, and review the two attached letters that show our
proposed deletions. If you disagree with our proposed deletions, follow the instructions in the Letter 437 on how
to notify us. If you agree with our deletions, you don't need to take any further action.

If you have questions about this letter, you can call the contact person shown above. If you have questions
about your federal income tax status and responsibilities, call our customer service number at 800-829-1040
(TTY 800-829-4933 for deaf or hard of hearing) or customer service for businesses at 800-829-4933.

Sincerely.

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:
Letter 437
Redacted Letter 4034
Redacted Letter 4038

Department of the Treasury
Internal Revenue Service

IRS

Date:
02/26/2026

Employer ID number:

Person to contact:

Name:

ID number:

Telephone:

Fax:

Legend:

B = Date
C = State

D = City
x percent = Percent
y percent = Percent
z percent = Percent

UIL:
501.04-00

501.04-01

Dear
:

We considered your application for recognition of exemption from federal income tax under Internal Revenue
Code (IRC) Section 501(a). We determined that you don't qualify for exemption under IRC Section 501(c)(4).
This letter explains the reasons for our conclusion. Please keep it for your records.

Issues

Do you qualify for exemption under IRC Section 501(c)(4)? No, for the reasons stated below.

# Facts

You incorporated as a mutual benefit corporation on B, in the state of C. Your Articles of Incorporation state
that you are formed to receive and distribute payments from union dues.

Your Corporate Bylaws state that you are formed to support and represent the interests of your members in
matters related to employment conditions, benefits, and related concerns.

Membership is voluntary and open to all active and retired employees of D. All members in good standing are
entitled to full voting rights, representation and advocacy in employment-related matters and grievance
procedures, and access to the retiree and spousal support program.

Your central mission is to act as a representative and advocate for members. You provide essential support to D
employees in navigating workplace concerns, disputes and disciplinary actions. You directly engage with the D
administration to ensure equitable treatment, promoting a stable and positive work environment. Your advocacy
efforts help to resolve issues proactively and strengthen the relationship between employees and management,

contributing to the overall well-being of the workforce. You dedicate x percent of your resources to your
collective representation and employee advocacy activities.

You administer a critical financial support program for the surviving spouses of deceased retired D employees.
You state that you do not establish, operate, fund or control this program. You perform a limited administrative
role as a conduit for funds originating from external sources, such as the D or other third-party programs. Finds
are fully restricted, earmarked, and controlled by the originating entity, and are not treated as your assets. Your
role is limited to ministerial or administrative assistance, such as facilitating the transmission of funds or
providing informational support, without exercising authority, discretion or policy control over the program
itself. You dedicate y percent of your resources to this retiree and spousal program.

You dedicate z percent of your resources to administrative activities. Your operations are funded by member
dues which are deducted from employee paychecks and deposited into your operating account. The funds
support your advocacy and administrative functions, which include the distribution of benefits.

# Law

IRC Section 501(c)(4) provides for the exemption from federal income tax of a local association of employees,
the membership of which is limited to the employees of a designated person or persons in a particular
municipality.

Treasury Regulation Section 1.501(c)(4)-1(a)(1) states a civic league or organization may be exempt as an
organization described in IRC Section 501(c)(4) if it is not organized or operated for profit and it is operated
exclusively for the promotion of social welfare.

Treas. Reg. Section 1.501(c)(4)-1(a)(2)(i) states that an organization is operated exclusively for the promotion
of social welfare if it is primarily engaged in promoting in some way the common good and general welfare of
the people of the community. An organization embraced within this section is one which is operated primarily
for the purpose of bringing about civic betterment and social improvements.

Treas. Reg. Section 1.501(c)(4)-1(b) requires that the net earnings of a local association of employees must be
devoted exclusively to charitable, educational or recreational purposes.

Revenue Ruling 66-59, 1966-1 C.B. 142, described an organization that paid lump sum retirement benefits to its
members or death benefits to their survivors. The organization did not qualify for exemption as an association
of employees under Section 501(c)(4).

Rev. Rul. 75-199, 1975-1 C.B. 160, provides that a nonprofit organization that restricts its membership to
individuals of good moral character and health, who belong to a particular ethnic group residing in a stated
geographical area, and that provides sick benefits to members and death benefits to beneficiaries of deceased
members does not qualify for exemption under IRC Section 501(c)(4) because the benefit to the community at
large is minor and incidental. Membership dues are the primary source of support to the organization.

Rev. Rul. 81-58. 1981-1 C.B. 331 provides that a nonprofit police officer association whose primary activity is
providing lump-sum retirement payments to its members or death benefits to their beneficiaries will not qualify
as a social welfare organization under IRC 501(c)(4). Rev. Rul. 75-199 amplified.

The organization described in Vision Service Plan v. United States, No. CIVS041993LKKJFM, 2005 WL
3406321 (E.D. Cal. Dec. 12, 2005), aff'd sub nom. Vision Service Plan, Inc. v. United States, 265 F. App'x 650
(9th Cir. 2008), provided eye care services to employees of its subscriber companies. The court held that Vision
Service Plan was not operated exclusively for social welfare purposes because it operated primarily for the
benefit of its subscribers rather than for the purpose of benefiting the community as a whole.

# Application of law

You are not described in IRC Section 501(c)(4) and Treas. Reg Section 1.501(c)(4)-1(a)(1) because you are not
operated as a local association of employees, and your activities do not primarily promote social welfare. You
are primarily operating for the benefit of your members as opposed to benefiting the public at large. Your
activities do not exclusively further charitable, educational, or recreational purposes as described in Treas. Reg.
Section 1.501(c)(4)-1(b). You engage in collective representation activities on behalf of your members, which
exclusively benefits your participating members through their employer's contributions. You also administer a
retiree and spousal support program on behalf of D which benefits your members. You are serving the private
interests of your members rather than the interests of a community.

You were established to represent and advocate for your members relating to workplace concerns, disputes, and
disciplinary actions. You also administer a retiree and spousal support program on behalf of D which benefits
your members. You collect membership dues and use these funds to collectively represent and advocate for
your members. These activities do not further charitable, educational, or recreational activities, and are instead
primarily focused on benefiting your members as opposed to promoting the common good and general welfare
of the community as described in Treas. Reg. Section 1.501(c)(4)-1(a)(2)(i).

Similar to the organizations described in Rev. Rul. 66-59, Rev. Rul. 75-199, Rev. Rul. 81-58 and Vision Service
Plan, you are formed as a mutual self-interest type of organization. You operate primarily to represent and
advocate for your members, and to administer a retiree and spousal support program. Both of these activities
provide a direct economic benefit to your members, with any benefit to the larger community being minor and
incidental.

# Conclusion

You do not qualify under IRC Section 501(c)(4) because your activities primarily serve the private interests of
your members, and any benefit to the community at large is secondary to the benefits conferred to your
members. Therefore, you do not qualify for exemption under Section 501(c)(4).

# If you agree

If you agree with our proposed adverse determination, you don't need to do anything. If we don't hear from
you within 30 days, we'll issue a final adverse determination letter. That letter will provide information on
your income tax filing requirements.

# If you don't agree

You have a right to protest if you don't agree with our proposed adverse determination. To do so, send us a
protest within 30 days of the date of this letter. You must include:

· Your name, address, employer identification number (EIN), and a daytime phone number

· A statement of the facts, law, and arguments supporting your position

· A statement indicating whether you are requesting an Appeals Office conference

· The signature of an officer, director, trustee, or other official who is authorized to sign for the
organization or your authorized representative

· The following declaration:

For an officer, director, trustee, or other official who is authorized to sign for the organization:
Under penalties of perjury, I declare that I have examined this request, or this modification to the
request, including accompanying documents, and to the best of my knowledge and belief, the request
or the modification contains all relevant facts relating to the request, and such facts are true, correct,
and complete.

Your representative (attorney, certified public accountant, or other individual enrolled to practice before the
IRS) must file a Form 2848, Power of Attorney and Declaration of Representative, with us if they haven't
already done so. You can find more information about representation in Publication 947, Practice Before the
IRS and Power of Attorney.

We'll review your protest statement and decide if you gave us a basis to reconsider our determination. If so,
we'll continue to process your case considering the information you provided. If you haven't given us a basis
for reconsideration, we'll send your case to the Appeals Office and notify you. You can find more information
in Publication 892, How to Appeal an IRS Determination on Tax-Exempt Status.

If you don't file a protest within 30 days, you can't seek a declaratory judgment in court later because the
law requires that you use the IRC administrative process first (IRC Section 7428(b)(2)).

Where to send your protest
Send your protest, Form 2848, if applicable, and any supporting documents to the applicable address:

U.S. mail:

Street address for delivery service:

Internal Revenue Service

EO Determinations Quality Assurance

Mail Stop 6403

550 Main Street, Mail Stop 6403

PO Box 2508

Cincinnati, OH 45202

Cincinnati, OH 45201

You can also fax your protest and supporting documents to the fax number listed at the top of this letter. If you
fax your statement, please contact the person listed at the top of this letter to confirm that they received it.

You can get the forms and publications mentioned in this letter by visiting our website at www.irs.gov/forms-
pubs or by calling 800-TAX-FORM (800-829-3676). If you have questions, you can contact the person listed at
the top of this letter.

Contacting the Taxpayer Advocate Service

The Taxpayer Advocate Service (TAS) is an independent organization within the IRS that can help protect your
taxpayer rights. TAS can offer you help if your tax problem is causing a hardship, or if you've tried but haven't
been able to resolve your problem with the IRS. If you qualify for TAS assistance, which is always free, TAS
will do everything possible to help you. Visit www.taxpayeradvocate.irs.gov or call 877-777-4778.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

IRS Published Taxpayer Determination Letter 202629019

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