IRS0000001525

File 04102013

Tab 1- P'otential Abusive Historical

IRS0000001526

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

IRS0000001527

10

11

12

10

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

IRS0000001528

File 04102013

Tab 2 - Potential Abusive

IRS0000001529

2

3

4

5

3

5

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

£

6

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

IRS0000001530

-

..21

7

8

9

10

1112131415161718192021

IRS0000001531

File 04102013

Tab 3 - Emerging Issues

IRS0000001532

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

IRS0000001533

File 04102013

Tab 4 - Coordinated Processing

IRS0000001534

IRS0000001535

File 04102013

Tab 5 - Watch List

IRS0000001536

(b) (6)

IRS0000001537

11

12

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