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Document8 Redacted 071012

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IRS0000001468 File 071012 Tab 1 - Potential Abusive Historical File 071012 Tab 1 - Potential Abusive Historical
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Page 1: Document8 Redacted 071012

IRS0000001468

File 071012

Tab 1 - Potential Abusive Historical

File 071012

Tab 1 - Potential Abusive Historical

Page 2: Document8 Redacted 071012

IRS0000001469

Page 3: Document8 Redacted 071012

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Page 4: Document8 Redacted 071012

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Page 5: Document8 Redacted 071012

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File 071012

Tab 2 - Potential Abusive

File 071012

Tab 2 - Potential Abusive

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IRS0000001473

2Corporation Sole The AOI and application will refer to "cOrporation sole" or "corporate sole".

Fonn 1023 may show only one person involved with the applicant. Titles likeOverseer, Elder, Patriarch, Matriarch, Administrator, Pastor, etc. Theapplicant mayor may not request churchclassification.

Forward case to Group 7824

Open

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Fictitious Exemption e ennlna Ion er su mitted appears questionable. May include incorrectLetter information or may appear invalid due to format, font, etc.Puerto Rico'" Applicant usually has a Puerto Rico address. Activities involve elderly or low

incomehousing. operating a school, and head-start programs. The return

L,;aiidiid.reiisjs.o.nllt.he.o.rig_i.na.lllo.riiPllh.ot.O.co.PiilYiloiif~t.he.e.nv.e.lo~pe may be_II . Federal governmentgrants is listed as the primarysource of income. Other identifying factorsinclude intention to build a 42 unit facili ,no ownership of property,appli~tion showing

Forward case to Group 7824

Forward case to Group 7824

Open

Open

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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. Theapplicant mayor may not request church classification.

Fictitious Exemption e ermma Ion er su milted appears questionable. May include incorrectLeiter information or may appear invalid due to format, font, etc.Puerto Rico'" Applicant usually has a Puerto Rico address. Activities involve elderiy or low

income housing, operating a school, and head-start programs. The returnaddress on the original or photocopy of the envelope maybe_

~~~."I,iII!!IIiIl.l~~.IiI~~~~~.Federal governmentgrants is listed as the primary source of income. Other identifying factorsinclude intention to build a 42 unit facili ,no ownership of property,application showing

Forward case to Group 7824

Forward case to Group 7824

Forward case to Group 7824

Open

Open

Open

Page 7: Document8 Redacted 071012

IRS0000001474

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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 turn the charitypays to the donor interest on the loan. May be referred to as a CharityOwned Life Insurance (CHOLl).Ma be administered by

may also bementioned in the application. Program involves ~ high value insurancepolicy. where the applicant will receive 10% of the face value of theinsurance if they show that they are 501 (c)(3).

Forward case to Group 7824

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. Open

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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 turn the charitypays to the donor interest on the loan. May be referred to as a CharityOwned Life Insurance (CHOLl). Ma be administered b

may also bementioned in the application. Program involves a high value insurancepolicy, where the applicant will receive 10% of the face value of theinsurance if they show that they are 501 (c)(3).

Forward case to Group 7824

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Open

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Open

Open

Open

--

- ~- - - ------_. --~"'~~_ ~~._ r -':<l'>-""",- =~~,.. :r

Forward case to Group 7824

Forward case to Group 7824

Forward case to Group 7824

Pain Management Pain management clinics in applying for exemption under 501 (c)(3)Clinics of the Code. These clinics appear to be involved in abusive schemes as

they are forming to avoid state licensing and oversight requirements.

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

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

Pain Management Pain management clinics in applying for exemption under 501 (c)(3)Clinics ofthe Code. These clinics appear to be involved in abusive schemes as

they are forming to avoid state licensing and oversight requirements.

Forward case to Group 7824

Forward case to Group 7824

Forward case to Group 7824

Open

Open

Open

Page 9: Document8 Redacted 071012

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Page 10: Document8 Redacted 071012

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File 071012

Tab 3 - Emerging Issues

File 071012

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 of political campaign intervention (raising questions as to exempt purposeandlor 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.

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Current PoliticalIssues

501 (c)(3) , 501 (c)(4), 501(c)(5), and 501 (c)(6) organizations with indicators of significantamounts of political campaign intervention (raising questions as to exempt purposeand/or excess private benefit). Note: advocacy action type issues (e.g., lobbying) th;ltare currently listed on the Case Assignment Guide (CAG) do not meet this criteria.

EI-1 x Forward case to Group 7822. Open

Page 12: Document8 Redacted 071012

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File 071012

Tab 4 - Coordinated Processing

File 071012

Tab 4 - Coordinated Processing

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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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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 071012

Tab 5 - Watch List

File 071012

Tab 5 - Watch List

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MedicalMarijuana

Cases involving Medical Marijuana

Organizations applying for 501C-3 status by providing green energy (electricity/power) toother organizations

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2010 -#1 Forward case to Group 7888. Denise Tamayo (coordinator). Note:the coordinator has permission to close "exclusively educational"organizations.

Coordinate.processing with Mitch Steele, Group 7827.

Open- 715-10

Open­7/11/11

4Medical

MarijuanaCases involving Medical Marijuana 5 2010 -#1 Forward case to Group 7888. (coordinator). Note:

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

Open- 715-10

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

14 Coordinate processing with Group 7827. Open ­7/11/11

(b) (6)

(b) (6)

(b) (6)

(b) (6)

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