IRS written determination 201425025

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.

TREASURY

INTERNAL

UYUE SERVICE

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

MAR 26 2014

201425025

U.I.L 414.08-00

T: EP: RAIT3

Attention:

LEGEND:

Religious Denomination A

Level 1 Church

Level 2 Church

Level 3 Church

Group B

Church C

Church D

Church E

Church F

Church G

Church H

Organization I

Organization J

Organization K

Organization L

Organization M

Organization N

Organization O

Organization P

Organization Q

Organization R

Organization S

Organization T

Organization U

Organization V

Organization W

Organization X

Organization Y

Plan Z

Country A

$
201425025

Dear **********:

This is in response to a letter dated December 22, 2006, as supplemented
by letters dated January 13, 2012, February 2, 2012, February 6, 2012, October
2, 2013, and December 3, 2013, submitted by your authorized representative
regarding the status of Plan Z as a church plan within the meaning of section
414(e) of the Internal Revenue Code (the "Code").

The following facts and representations have been submitted under
penalty of perjury in support of the ruling requested:

Religious Denomination A generally embodies a three-level organizational
structure. Individuals who live in a geographic area typically form, and become
members of, a Level 1 Church, which is the local group or church congregation.
Two or more Level 1 Churches in the same geographical area are united in a
broader Level 2 Church. Level 2 Churches commonly meet four times a year,
and their purpose is to transact business and share information between Level 1
Churches. A Level 1 Church appoints individuals to represent it in the Level 2
Church of which it is a part, and in the Level 3 Church for the geographical area
in which it is located. Level 3 Churches are the highest authority within Religious
Denomination A, and have general oversight of the constituent Level 1 Churches.
(However, some Level 1 Churches are part of a Level 3 Church, but not part of a
Level 2 Church, and a few are not part of either a Level 2 Church or Level 3
Church.) Level 1 Churches, Level 2 Churches and Level 3 Churches are
hereinafter collectively referred to as "Churches."

Group B established Plan Z, a self-funded health benefit plan, effective
January 1, 2007. Plan Z is sponsored, administered, and maintained by Group
B.

Under the terms of Plan Z, the only organizations eligible to enroll and
participate in the plan as participating employer organizations are (1) recognized
Level 3 Churches, Level 2 Churches, Level 1 Churches, or other churches of
Religious Denomination A in the United States, (2) Religious Denomination A
organizations in the United States, (3) recognized regional or national
associations of Religious Denomination A, or (4) members of a recognized
regional or national association of Religious Denomination A. In addition, the
plan provides that a participating employer organization must be "eligible to
receive church plan designation by the Internal Revenue Service." Plan Z is not
established and maintained primarily for the benefit of employees (and their
beneficiaries) of a church or convention or association of churches who are
employed in connection with one or more unrelated trades or businesses (within
the meaning of section 513 of the Code).

Group B was formed in 2006 to carry out the charitable and religious
purposes of Religious Denomination A, in particular to facilitate the provision of

cost-effective health insurance to employees of Religious Denomination A
organizations that are members of Group B. Group B is an organization
described in section 501(c)(3) of the Code. Additionally, the Internal Revenue
Service ("Service") has previously ruled that Group B is a "supporting
organization" that satisfies the requirements of section 509(a)(3) of the Code.

The board of directors of Group B is elected by Group B's member
organizations. The board of directors consists of not fewer than nine and not
more than eleven members. At least 51% of the members of the board must be
members of Religious Denomination A. All but two of the directors must be chief
executive officers, other senior staff members, or active members of the board of
a Group B member organization.

To simplify billing, the Level 1 Churches that have employees covered
under Plan Z are billed by Group B through their respective Level 3 Churches.
Most of such Level 1 Churches have only one employee covered by Plan Z. The
respective Level 3 Churches receive a monthly invoice from Group B, and then
the Level 3 Churches bill their constituent Level 1 Churches for the coverage of
the Level 1 Church employees. In cases where a Level 3 Church is a
participating employer organization with respect to Plan Z, only employees of the
Level 3 Church itself or of a constituent Level 1 Church or Level 2 Church are
intended to receive coverage through the Level 3 Church.

The following entities are participating employer organizations in Plan Z:

Church C, Church D, Church E, Church F, Church G, and Church H are
each a Level 3 Church of Religious Denomination A, and each has previously
been determined by the Service to be exempt from tax under section 501(c)(3) of
the Code. Churches C through H have also each previously been determined by
the Service to be a church described in section 170(b)(1)(A)(i) of the Code.

Organization I is one of the three largest organizations of Religious
Denomination A churches with the stated purpose of nurturing the spiritual vitality
of 14 Level 3 Churches and 10 directly affiliated Level 1 Churches. The Service
has previously determined that Organization I is a convention of churches
described in section 170(b)(1)(A)(i) of the Code, and exempt from tax under
section 501(c)(3) of the Code.

Organization J is an association of Level 3 Churches and smaller
Religious Denomination A groups, all of which consult and work together for
shared purposes. Organization J is exempt from tax under section 501(c)(3) of
the Code. The Service has previously determined that Organization J is a
convention or association of churches.

Organization K is a section 501(c)(3) organization whose stated mission is
to answer God's call to universal love by bringing those of the Religious

Denomination A faith across the hemisphere together to express their common
heritage and bring the Religious Denomination A message to the world. Level 3
Churches and certain foreign-based Religious Denomination A churches
constitute at least 75% of the membership of Organization K. You represent that
the Service has previously determined that Organization K is a convention of
churches.

Organization L is a retirement community which is "under the care of"
Religious Denomination A. Under Organization L's bylaws, the majority of the
trustees of Organization L are appointed by the Level 3 Church for Organization
L's region. Each trustee of Organization L must be a member of Religious
Denomination A. Organization L's values statement lists the "Hallmarks of
[Religious Denomination A] Service" under which it operates. Organization L is
exempt from tax under section 501(c)(3) of the Code.

Organization M is a center for members of Religious Denomination A.
The members of Organization M's board of directors are appointed by the Level
1 Churches listed in Organization M's bylaws, each of which is a constituent of
the regional Level 3 Church. Organization M is listed in the directory of the local
Level 1 Church of Religious Denomination A. Organization M's stated purpose is
to support those who seek to make visible "the [Religious Denomination A]
values of peace, community, simplicity, equality, and truth." Organization M
sponsors educational programs in the subject areas of its mission, provides
direct services to the poor and marginalized through its work camps, and
provides overnight accommodation for travelers. Organization M holds daily
meetings for worship. Organization M is exempt from tax under section 501(c)(3)
of the Code.

Organization N is a center for Religious Denomination A educational
activities and the home of a Level 1 Church. In addition, Organization N is a
residence for 21 people interested in living the Religious Denomination A
principle of community and has two guest rooms. Organization N's governing
corporate board is comprised of representatives of the Level 2 Churches within
Church F. Organization N's mission statement is:
[Religious Denomination A] '

center fulfills its mission by, among other things, providing a center where
members of Religious Denomination A and others can meet, worship and study,
and by advancing and fostering the principles of Religious Denomination A.
Organization N conducts educational programs exploring aspects of Religious
Denomination A through study and workshops. The Service has previously
determined that Organization N is exempt from tax under section 501(c)(3) of the
Code.

Organization O was founded by members of Religious Denomination A
and conducts activities such as nonviolence training and prison workshops.

Under its bylaws, Organization O was organized to function as an agency "under
the care of" Church G. In Religious Denomination A, for an organization to be
"under the care of" Church G means that Church G has a relationship with that
organization and that the church may provide board members, financial support,
or other forms of support for that organization. Six of the approximately 20
members of Organization O's board of directors are appointed by Church G.
Organization O makes decisions in the tradition of Religious Denomination A.
Organization O is listed in the yearbook of Church G and receives regular
financial support from Church G and a number of constituent Level 1 Churches.
The Service has previously determined that Organization O is exempt from tax
under section 501(c)(3) of the Code.

Organization P is a continuing care community. Organization P's
philosophy of care is based on Religious Denomination A values of integrity,
equality, harmony and simplicity, and on the provision of service "that honors the
inner light within each of us." Organization P's philosophy "honors that of God
within, in doing so." Nominations for the board of trustees of Organization P
must be approved by the executive committee of a particular Level 3 Church, and
upon dissolution of Organization P, any remaining assets would be distributed to
such Level 3 Church. At all times, the majority of the board of trustees of
Organization P must be members of Religious Denomination A. The trustees
and all committees of Organization P are to conduct their meetings in
accordance with Religious Denomination A practices and tradition, as reflected in
specified materials of a Level 3 Church. Organization P's bylaws establish a
committee that works to enhance the Religious Denomination A presence or
characteristics of the organization and to further the understanding of the
testimonies of members of Religious Denomination A among the members, staff,
residents, and the surrounding community. The Service has previously
determined that Organization P is exempt from tax under section 501(c)(3) of the
Code.

Organization Q is a health service organization whose services include
continuing care retirement services. A Level 2 Church was involved in the
founding of Organization Q. Organization Q is listed on such Level 2 Church's
website under the heading "Our Retirement and Healthcare Facilities." Currently,
Organization Q has 11 board members, of whom 8 are members of Level 1
Churches that are members of such Level 2 Church. Each week, a different
Level 1 Church within such Level 2 Church is responsible for conducting a
weekly service of worship at Organization Q. Organization Q's bylaws require
that a majority of its directors be members of a Level 1 Church. Organization Q's
stated purpose is to support the capacity of its residents to live creatively and
meaningfully, in part, by the Religious Denomination A philosophy that guides
staff, volunteers, and participants to "seek that of God in everyone."

Organization Q's bylaws state its intent "to improve the quality of life for members
of [Religious Denomination A] and others who are in need of care and treatment."
Organization Q is exempt from tax under section 501(c)(3) of the Code.

Organization R is a continuing care retirement community founded by
members of a Level 1 Church, and is listed on that Level 1 Church's website.
Such Level 1 Church meets every Wednesday for worship at Organization R.
Organization R is "a [Religious Denomination A] directed" facility based on the
values and convictions of Religious Denomination A. Under its bylaws,
Organization R's board is composed of between 11 and 15 regular members,
plus 3 resident members. No less than a majority of the regular members must
be members of Religious Denomination A. Currently, six members of the board
attend such Level 1 Church. The bylaws provide for the use of Religious
Denomination A decision-making procedures in the conduct of the corporation's
business. Under the bylaws, the board appoints members of Organization R's
standing committees from among directors, residents, members of the Level 1
Church and members of the wider community. The Service has previously
determined that Organization R is exempt from tax under section 501(c)(3) of the
Code.

Organization S is a corporation whose stated purpose is to construct,
renovate, operate, and maintain buildings to be occupied by its "member
organizations" and by other organizations which have concerns, practices, and
principles compatible with those of Religious Denomination A. The members of
Organization S are appointed by Church E, by a Level 1 Church associated with
Church E, and by an organization affiliated with Religious Denomination A. Each
of these 3 organizations appoints three individuals to serve as the members of
Organization S. Thus, Church E and such Level 1 Church together appoint a
total of 6 of the 9 members of Organization S. Each of Organization S' members
also serves as a member of the board of directors of Organization S, along with
one director appointed by each of the non-member organizations that occupy
space in the buildings owned by Organization S. The non-member directors
have authority only to participate in decisions relating to the management and
operation of a building owned by Organization S, and have no authority to
participate in other decisions of Organization S' board of directors. Upon
dissolution of Organization S, any assets remaining go to the member
organizations pursuant to an agreement, provided that no assets will be
distributed to any organization that is not then a tax-exempt charitable
organization within the meaning of section 501(c)(3) of the Code. Organization S
is listed in the directory of Church E. The Service has determined that
Organization S is exempt from tax under section 501(c)(3) of the Code, and that
it is a "supporting organization" described in section 509(a)(3) of the Code.

Organization T is a not-for-profit corporation whose purpose is to provide
financial services, such as investment management services and trustee
services, funding grants, and planned giving services to Religious Denomination
A organizations. Organization T serves over 250 Religious Denomination A
Churches, schools, organizations, trusts, and endowments. Organization T's
investment philosophy is "grounded in the beliefs of" Religious Denomination A,

and its statement of purpose provides that it seeks to do its work with Divine
guidance, and in a manner consistent with the principles and practices of
Religious Denomination A. Under its bylaws, the board of directors of
Organization T consists of between 21 and 24 members of Church E, who are
nominated by Church E. There may be up to three additional board members
who are members of other Level 3 Churches. The bylaws of Organization T
provide that it is expected that the corporation's business will be accomplished in
the manner traditionally used for the conduct of business by members of
Religious Denomination A. Organization T's articles of incorporation provide that
upon its dissolution, any remaining assets are to go to Church E, provided
Church E continues to qualify under section 501(c)(3) of the Code or a successor
provision. Organization T is listed in Church E's directory. The Service has
previously determined that Organization T is exempt from tax under section
501(c)(3) of the Code, and that it is a supporting organization described in
section 509(a)(3) of the Code.

Organization U is a school for students in kindergarten through Grade 8.
Under its bylaws, the school's purpose is to be a Religious Denomination A
school whose values, beliefs, principles and practices reflect those of Religious
Denomination A. A majority of the members of Organization U's board of
directors must be members of Religious Denomination A. Organization U is
listed in the directories of Church E and of a Level 2 Church. Organization U is
listed as one of 40 nursery, elementary, and high schools "within [Church E]".
Church E provides tuition assistance for children of Church E families at Church
E schools, including Organization U. The board of Organization U and its
subcommittees are to conduct their business in the manner of Religious
Denomination A. Preference in admission and hiring is given to members of
Religious Denomination A, as well as, in the case of admission, to siblings of
current and former students and children of alumni. One of Organization U's
operating principles is spirituality, and it has a weekly meeting of members of
Religious Denomination A for worship. Organization U is exempt from tax under
section 501(c)(3) of the Code.

Organization V is a senior community offering programs of care and
services to older persons with moderate to severely limited incomes.
Organization V has a historical relationship with a Level 2 Church that is part of
Church E, and with that Level 2 Church's constituent Level 1 Churches.
Organization V receives regular financial support from such local Level 1
Churches. Organization V leases one of its two buildings, and the land
associated with that building, from such a Level 1 Church, at a highly subsidized
rate. That real estate (and other real estate held by Organization V) would revert
to such Level 1 Church if not used by Organization V for the intended purposes.
Organization V provides annual reports to the Level 2 Church. Organization V is
listed on Church E's website among the Religious Denomination A organizations
serving the aged. Organization V is an eligible recipient of grants from Level 1
Churches and groups associated with Church E that provide grants.

Organization V's bylaws require that a majority of its directors be members of
Religious Denomination A. Currently 10 of Organization V's 18 directors are
members of Level 1 Churches that are part of Church E. Organization V's
bylaws contain its mission statement and diversity statement, both reflecting
Religious Denomination A values and practices. Its mission statement provides
that it is guided by Religious Denomination A traditions. The Service has
previously held that Organization V is exempt from tax under section 501(c)(3) of
the Code.

Organization W is a continuing care retirement community guided by the
principles of Religious Denomination A. A majority of the members of
Organization W's board must be members of Religious Denomination A,
meaning that they must be members of a Level 1 Church. Organization W
currently has 13 board members, 8 of whom are members of Religious
Denomination A, and all of whom are drawn from the district of Church E. 6 of
the 13 members of Organization W's board of directors are members of a
specified Level 2 Church. Organization W is listed on such Level 2 Church's
website under the heading "Our Retirement and Healthcare Facilities."
Meetings of the Organization W's board are to be conducted in the manner of
members of Religious Denomination A. A Religious Denomination A meeting for
worship is held at Organization W each week for anyone wishing to attend.
Under Organization W's articles of incorporation, upon its dissolution, the
remaining assets of Organization W must to go to a particular 501(c)(3) entity
associated with Church E. Organization W has a subcommittee that works to
promote a broader understanding of Religious Denomination A practices and
beliefs through lectures, movies, exhibits and other activities. Organization W's
staff attends a program designed to make them more aware of the beliefs and
practices of Religious Denomination A. The Service has previously determined
that Organization W is exempt from tax under section 501(c)(3) of the Code.

Organization X is an international non-sectarian development organization
guided by Religious Denomination A principles and dedicated to reducing poverty
among the indigenous peoples of Country A. You represent that Organization X
is a Religious Denomination A response to poverty. Organization X is supported
by more than 140 Religious Denomination A Churches, and uses the facilities of
a Level 1 Church for its annual meeting. Under its bylaws, a majority of the
members of its board of directors must be members or attendees of Religious
Denomination A. Organization X's bylaws provide that the procedures used in
meetings will be those of Religious Denomination A, to the extent not
inconsistent with its bylaws, articles of incorporation, or provisions of law.
Organization X funds water, irrigation, and agricultural projects that come from
the local Country A communities. This work, which takes place in some of the
poorest communities in the world, is a core activity in [Religious Denomination A]
testimony to equality. Organization X is exempt from tax under section 501(c)(3)
of the Code.

Organization Y is comprised of members of Religious Denomination A and
persons of faith who provide capital to help support women's self-help groups
conducting micro-credit projects. Organization Y's website says "We believe
God is calling [members of Religious Denomination A] and other persons of faith
in the United States" to its goal, and explains the motivation for such goal
grounded in scripture. Organization Y receives virtually all of its funds from
members of Religious Denomination A, from half of the Level 3 Churches in the
United States, and from about 10% of the Level 1 Churches in the United States.
Organization Y solicits the members of its board of directors from Level 3
Churches, Level 2 Churches, and Level 1 Churches. Fourteen of the 16
members of Organization Y's board of directors are members of a Religious
Denomination A church. Organization Y's articles of incorporation describe its
purpose as including "to communicate the religious and spiritual basis for the
Corporation's programs and activities" and "to provide specific action ideas,
particularly the giving of grants, to enable [Religious Denomination A] to
implement actions to address the Corporation's concerns" about specified issues.
Organization Y is exempt from tax under section 501(c)(3) of the Code.

Based on the foregoing, you request a ruling that Plan Z is a church plan
within the meaning of section 414(e) of the Code.

Section 414(e)(1) of the Code generally defines a church plan as a plan
established and maintained for its employees (or their beneficiaries) by a church
or a convention or association of churches which is exempt from taxation under
section 501 of the Code.

Section 414(e)(2)(A) of the Code provides that the term "church plan"
does not include a plan that is established and maintained primarily for the
benefit of employees (or their beneficiaries) of such church or convention or
association of churches who are employed in connection with one or more
unrelated trades or businesses (within the meaning of section 513 of the Code).

Section 414(e)(2)(B) of the Code provides that the term church plan also
does not include a plan if less than substantially all of the individuals covered
under the plan are individuals described in section 414(e)(1) of the Code or
section 414(e)(3)(B) of the Code (or their beneficiaries).

Section 414(e)(3)(A) of the Code provides that a plan established and
maintained for its employees (or their beneficiaries) by a church or by a
convention or association of churches includes a plan maintained by an
organization, whether a civil law corporation or otherwise, the principal purpose
or function of which is the administration or funding of a plan or program for the
provision of retirement benefits or welfare benefits, or both, for the employees of
a church or a convention or association churches, if such organization is
controlled by or associated with a church or a convention or association of
churches.

Section 414(e)(3)(B)(i) of the Code generally defines "employee" of a
church or a convention or association of churches to include a duly ordained,
commissioned, or licensed minister of a church in the exercise of his or her
ministry, regardless of the source of his or her compensation. Section
414(e)(3)(B)(ii) further provides that an employee of a church or convention or
association of churches also includes an employee of an organization, whether a
civil law corporation or otherwise, which is exempt from tax under section 501 of
the Code, and which is controlled by or associated with a church or a convention
or association of churches.

Section 414(e)(3)(C) of the Code provides that a church or a convention or
association of churches which is exempt from tax under section 501 of the Code
shall be deemed the employer of any individual included as an employee under
section 414(e)(3)(B) of the Code.

Section 414(e)(3)(D) of the Code provides that an organization, whether a
civil law corporation or otherwise, is associated with a church or a convention or
association of churches if it shares common religious bonds and convictions with
that church or convention or association of churches.

In this case, Plan Z is a health plan that is maintained and administered by
Group B, which is not itself a church or a convention or association of churches.
A plan that is not established and maintained by a church or convention or
association of churches can qualify as a church plan only if the entity maintaining
the plan is an organization described in section 414(e)(3)(A) of the Code. To be
described in section 414(e)(3)(A) of the Code, an organization must (1) have as
its principal purpose the administration or funding of a plan to provide welfare or
retirement benefits (or both) for employees of a church or convention or
association of churches, and (2) also be controlled by or associated with a
church or convention or association of churches.

Group B is a not-for-profit corporation which is exempt from federal
income tax as an organization described in section 501(c)(3) of the Code. Group
B's primary purpose and function is to sponsor and administer a health benefit
program for Religious Denomination A organizations. Membership in Group B
(and participation in Plan Z) is limited to Churches and other organizations
associated with Religious Denomination A and qualified to maintain a church
plan. Churches C, D, E, F, G, and H are members of Group B, as are three
associations of churches, Organizations I, J and K. The board of directors of
Group B is elected by Group B's member organizations. At least 51% of the
members of the board must be members of Religious Denomination A. All but
two of the directors must be chief executive officers, other senior staff members,
or active members of the board of a Group B member organization. Group B has
been determined to be a "supporting organization" under section 509(a)(3) of the
Code. For these reasons, we conclude that Group B is controlled by or

associated with a church or a convention or association of churches, and is an
organization described in section 414(e)(3)(A) of the Code.

Under Section 414(e)(1) of the Code, to be a church plan, the plan must
also be established and maintained for the benefit of employees of a church or
convention or association of churches. For this purpose, Section 414(e)(3)(B)(ii)
of the Code provides that employees of an organization which is exempt from tax
under section 501 of the Code, and which is controlled by or associated with a
church or a convention or association of churches are deemed to be employees
of a church.

Plan Z requires that each participating employer organization must be
eligible to receive a church plan designation by the Service.

Plan Z covers employees of Churches C, D, E, F, G, and H (including, in
some cases, employees of certain Level 1 Churches that are constituent parts of
such Churches), and employees of Organizations I through Y. Churches C, D,
E, F, G, and H. and Organizations I, J, and K have each previously been
determined to be a church or a convention or association of churches.
Employees of Churches C, D, E, F, G, and H, and of Organizations I, J and K are
thus employees of a church.

Under Section 414(e)(3)(B)(ii) of the Code, employees of an organization
that is not a church or an association of churches can be deemed to be church
employees if the organization: (1) is exempt from tax under section 501 of the
Code; and (2) is controlled by or associated with a church or convention or
association of churches.

The remaining organizations that participate in Plan Z, Organizations L
through Y, are not themselves churches or conventions or associations of
churches, but are organizations that are exempt from tax under Section
501(c)(3). Based on the represented facts discussed above, each such
organization either has a church involved in the governance of such organization,
receives financial support from a church, or is otherwise sufficiently associated
with a particular church, that the employees of each such organization may be
deemed employees of a church. Accordingly, we conclude that, under section
414(e)(3)(B) of the Code, the employees of Organizations L through Y are
deemed to be employees of a church or a convention or association of churches,
because they are employees of an organization which is exempt from tax under
section 501 of the Code and which is controlled by or associated with a church or
a convention or association of churches.

Based on the representations outlined above and our findings that Plan Z
is maintained by an organization described in Section 414(e)(3)(A) for the benefit
of employees (or deemed employees) of a church or convention of churches
which is exempt from tax under section 501(c)(3) of the Code, we further

conclude that Plan Z is a church plan under section 414(e) of the Code, and has
been a church plan, within the meaning of section 414(e) of the Code, since the
plan's establishment effective January 1, 2007.

This ruling applies only with respect to the organizations participating in
Plan Z as of the date of this letter, in accordance with the facts represented
above.

No opinion is expressed as to the tax treatment of the plan described
herein under the provisions of any other section of either the Code or regulations
which may be applicable thereto.

This letter is directed only to the taxpayer who requested it. Section
6110(k)(3) of the Code provides that it may not be used or cited as precedent.

Pursuant to a power of attorney on file with this office, a copy of this letter
ruling is being sent to your authorized representative. If you have any questions
regarding this letter, please contact ************ , ID Number **************** ,at ( *** )
Please address all correspondence to SE:T:EP:RA:T3.

Sincerely yours,

Laura B. Warshawsky, Manager
Employee Plans Technical Group 3

Enclosures:
Deleted copy of ruling letter
Notice of Intention to Disclose

CC:

IRS written determination 201425025

Continua la tua ricerca in ChatGPT o Claude