oversight

Tax Administration: IRS Can Improve Its Process for Recognizing Tax-Exempt Organizations

Published by the Government Accountability Office on 1990-06-08.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United   States   General   Accounting   Office
                 Report to the Honorable
GAO              Fred,T. Goldberg, Jr., Commissioner of
                 Intertial Revenue


June 1990




GAO,‘GGD-90-55
                   United States
GAO                General Accounting Office
                   Washington, DE. 20548

                   General   Goverument   Division

                   B-238929

                   June 81990

                   The Honorable Fred T. Goldberg, Jr.
                   Commissioner, Internal Revenue Service

                   Dear Mr. Goldberg:

                   The Internal Revenue Service (IRS) receives over 50,000 requests annu-
                   ally for recognition of tax-exempt status under Section 501(c) of the
                   Internal Revenue Code and had recognized over 1.2 million tax-exempt
                   organizations by the end of fiscal year 1989. Section 501(c) contains 25
                   categories of tax-exempt organizations, including those organized for
                   charitable, educational, religious, and social welfare purposes. IRS tax-
                   exempt determination process is designed to ensure that tax-exempt
                   organizations operate for the purposes specified in Section 501(c).

                   IRSofficials have noted that most tax-exempt organization compliance
                   problems identified by IRSsubsequent to a determination could not have
                   been found during the determination process. Because many of the orga-
                   nizations requesting exemption are new or have had limited activity, a
                   determination is often based on proposed activities. Therefore, IRS can-
                   not determine whether an organization is operating for an exempt pur-
                   pose until it examines data reported on an annual information return
                   filed by the organization. Recognizing the value of expediting the deter-
                   mination process to make more resources available for examinations, IRS
                   authorized an expedited process beginning in October 1987.

                   IRS planned to use over 30 percent of the direct staff time it devoted to
                   exempt organizations in fiscal year 1989 for the determination process.
                   Therefore, this process has a great impact on the resources available for
                   examinations of tax-exempt organizations, A more efficient and effec-
                   tive use of resources in the determination process could ultimately allow
                   more resources to be devoted to the examination process. Our objective
                   was to review the determination process, including the use and impact
                   of expedited determinations.


                   Our work showed that IRS could take several administrative actions to
Results in Brief   better use its resources and improve efficiency. We found that usage of
                   the expedited determination process during fiscal year 1989 varied
                   among the seven district offices responsible for exempt organization
                   matters, ranging from 17 percent of determination requests in one dis-
                   trict to 2 percent in another. While IRS has encouraged the use of the
                   process, an absence of clear guidance has resulted in confusion among


                   Page 1                                  GAO/GGD-9065 Tax-Exempt Organizations
             B-238929




             the district offices as to when the process can be used and variation
             among the districts in the types of determinations for which the process
             is used. As a result, IRSmay not be making the most efficient and effec-
             tive use of its resources through optimum use of the expedited process.

             We also observed that IRS does not use its determination resources most
             effectively when doing advance ruling follow-ups. Advance ruling fol-
             low-ups are performed 5 years after the initial determination to prop-
             erly classify a Section 501(c)(3) organization as a public charity or
             private foundation; private foundations are subject to more stringent
             regulation. The effectiveness of advance ruling follow-ups is limited
             because they do not include a review of expenditure data. Such a review
             could provide IRS with greater insight into whether organizations are
             operating in accordance with their stated tax-exempt purposes.

             Finally, we found that IRS procedures to close cases for lack of informa-
             tion create inefficiencies. Cases closed ‘because they lack sufficient infor-
             mation to make a determination are often reopened because the
             applicant organization subsequently provides the requested information.
             Inefficiencies and delays in responding to the applicant organization
             often result when a case is reopened, because these cases must be
             administratively reestablished.


             The Internal Revenue Code grants tax-exempt status to any organization
Background   qualifying for one of 25 types of exemption under Section 501(c). Most
             organizations apply to IRSfor exempt status by filing an application
             with the IRS Exempt Organization (EO) district in which their principal
             place of business is located. Organizations must also report subsequent
             organizational and operational changes to the EO district office. Section
             501(c)(3) organizations, such as educational, historical, or charitable
             organizations, are classified as (I) private foundations or (2) public
             charities, which are publicly supported or are operated to benefit pub-
             licly supported organizations. This classification is important because
             private foundations are subject to a variety of taxes, requirements, and
             penalties.

             When applying for recognition of tax-exempt status under Section
             501(c)(3), new organizations must indicate whether they expect to be a
             private foundation or a public charity. Some organizations, such as
             churches, educational organizations, and hospitals, may be statutorily
             exempted from classification as a private foundation, Other organiza-
             tions that can reasonably be expected to be publicly supported can


             Page 2                                    GAO/GGD-So-55 Tax-Exempt Organizations
IS238929




receive an advance ruling treating them as public charities for 5 years.
At the end of the advance ruling period, these organizations must sub-
mit annual income data for the 5 years so IRS can make a final determi-
nation of their foundation classification. This determination is called an
advance ruling follow-up. For fiscal year 1988, IRS estimates that 77 per-
cent of all determination requests were for 501(c)(3) status and that the
majority of these will receive an advance ruling follow-up.

During the determination process, IRS must judge whether an organiza-
tion is organized for and is or will be operating for purposes compatible
with those specified in the 501(c) section under which it seeks tax-
exempt determination, The application must be accompanied by copies
of the organization’s certificate of incorporation, the current by-laws, a
statement of receipts and expenditures, and a balance sheet for the cur-
rent and 3 preceding years, if applicable. Because many organizations
have little or no actual activity at the time they apply, the determination
often is based on proposed activities and estimated revenues and
expenditures.

Once an organization has received tax-exempt recognition, IRS can
review reported activity and financial data to ensure compliance with
legal requirements for tax-exempt status during examinations of annual
information returns (Form 990, “Return of Organization Exempt from
Income Tax”) filed by the organization or during the advance ruling fol-
low-up. However, for many tax-exempt organizations, the advance rul-
ing follow-up may be IRS only opportunity to review the reported
results of operations. Many tax-exempt organizations are not required to
file information returns because their annual gross receipts are less than
$25,000 and, therefore, would not normally be selected for examination.
1~s estimates that for fiscal year 1988, approximately 60 percent of all
tax-exempt organizations were not required to file a Form 990. Further,
IRS examines only a small percentage of those organizations that file
information returns. For example, IRS estimates that it has examined
only 1.4 percent of those organizations that filed returns for fiscal year
1985, the latest year for which examination information is available.

In fiscal year 1988, IRS devoted approximately 33 percent of its ~0 direct
staff time to determinations. During this same period, IRS received over
54,000 requests for exempt status and disposed of over 56,000. As
shown in figure 1, 74 percent of requests were approved, and 1 percent
were denied. Determinations were not made for the other 25 percent,
most often because IRS was not provided sufficient information.



Page 3                                   GAO/GGD-W-56 Tax-Exempt Organizations
                                            B-238929




Figure 1: Disposition   of Determinations
in Fiscal Year 1988
                                                 Parcent




                                            60




                                            IRS has given the processing of determination   requests priority among EO
                                            activities As a result, the resources available for examinations and
                                            other EOactivities are directly affected by how efficiently determination
                                            requests are processed.

                                            The expedited determination process was initiated to make the determi-
                                            nation process more efficient. The expedited process is the reviewing of
                                            determination requests by an experienced employee who decides which
                                            applications can be disposed of quickly without further review by a spe-
                                            cialist or contact with the taxpayer. For those requests that cannot be
                                            disposed of quickly, the employee notes the issues needing further con-
                                            sideration before the requests are assigned to specialists. While expe-
                                            dited requests are disposed of in about l/2 hour, it can take 3 hours or
                                            more to dispose of requests assigned to specialists. The expedited pro-
                                            cess can also reduce the time needed by specialists because the initial
                                            reviewer identifies the issues to be considered by the specialists.




                                            Page 4                                  GAO/GGD-90-M TaxXxempt   Organhtio~
                             3-238929




                             Our objective was to examine the efficiency and effectiveness of the
Objectives, Scope, and       determination process, including the use and impact of expedited
Methodology                  determinations.

                             To accomplish our objective, we

                         . obtained and analyzed policies and procedures governing the determina-
                           tion process, to understand the key issues to be addressed in a
                           determination;
                         l analyzed IRS statistics on the number of determination requests
                           processed and resources expended from fiscal years 1986 through 1988,
                           to understand the magnitude of the determination process;
                         l analyzed available IRS studies on the use of an expedited determination
                           process, to identify benefits of and concerns about the process;
                         . talked to IRS officials in the Assistant Commissioner’s office, the EO
                           Determinations Branch, and the seven EO district offices responsible for
                           exempt organization matters, to further identify concerns about the
                           determination process; and
                         l visited the Brooklyn, Chicago, and Baltimore districts and analyzed a
                           total of 143 recent determination dispositions collected for us by IRS, to
                           better understand how the process works

                             We obtained written comments from the Assistant Commissioner
                             Employee Plans and Exempt Organizations (EP~EO) on a draft of this
                             report. These comments, received in a letter dated March 27, 1990, are
                             included in appendix I and are summarized and incorporated in the
                             report where appropriate. We did our work from May 1989 through
                             October 1989, using generally accepted government auditing standards.


                             IASmay not be realizing maximum benefit from its expedited determina-
The Expedited                tion process. IRS recognized the potential benefits of the process when it
Determination                agreed to test the process in one district in November 1986. The test
Program Needs More           results were favorable and the process was authorized for use nation-
                             wide in October 1987. Although IRS has encouraged its use as the most
Guidance and                 effective means of allocating determination time and resources, use of
Evaluation                   the expedited process has been voluntary and its use has not been evalu-
                             ated. Consequently, the EO districts vary in their decisions as to when
                             they use the process and the types of determinations that they expedite.
                             As figure 2 shows, all EO district offices used the expedited process to
                             some degree during fiscal year 1989, the first year for which national
                             statistics are available. However, in fiscal year 1989 usage varied from



                             Page 5                                  GAO/GGD90-55 Tax-Exempt Organizations
                                          Is238929




                                          17 percent of determination cases in one district to only 2 percent in
                                          another.


Figure 2: EO District Office Use of the
Expedited Determination     Process
                                          20   Percent




                                          15




                                          10




                                           5




                                           0

                                               1             2   3   4    5      6         7
                                               EO district


                                          The National Office regards the expedited process as applicable to any
                                          type of organization historically demonstrating high levels of compli-
                                          ance, such as garden clubs, but its guidance does not specify which
                                          types of organizations it regards as such. It only specifies categories of
                                          organizations, such as churches and schools, for which the process can-
                                          not be used due to the complexity of issues generally found in these
                                          cases. As a result, district officials were uncertain about which determi-
                                          nations could be expedited. For example, while an official in one district
                                          told us that advance ruling follow-ups could not be expedited, such
                                          cases were the ones most frequently expedited in three other districts.
                                          Some EO district officials, in order to improve their own use of the pro-
                                          cess, would like a national evaluation of this process to learn the nature
                                          and extent of other districts’ use of it.

                                          In addition, failure to adhere to the guidance that does exist has resulted
                                          in variations in the use of the expedited process. While guidance on the
                                          process prohibits expediting applications that are clerically incomplete




                                          Page 6                                     GAO/GGD90-55 Tax-Exempt Organizations
                      B-238929




                      or considered sensitive, one district was expediting incomplete applica-
                      tions, and another was doing so for what IRS considered potentially sen-
                      sitive cases. Still another district gave managers discretion to expedite
                      determination requests even though the requests initially were not con-
                      sidered appropriate for this process under current guidance.


                      Given the lack of clear guidance and the inconsistency in application
Conclusion and        across the districts, IRS may not be benefiting as much as it could from
Recommendation        the expedited determination process. Accordingly, we recommend that
                      you direct the Assistant Commissioner (EP/EO) to (1) evaluate the cur-
                      rent use of the expedited determination process, as a basis for develop-
                      ing a national program that will include clear guidance on when the
                      process is to be used, and (2) assess the possibility of redirecting
                      resources between determinations and examinations as increased use of
                      the expedited determination process results in more efficient use of
                      determination resources.


                      IRSsaid that it has encouraged the use of the expedited determination
Agency Comments and   process and has given the districts much leeway in implementing the
Our Evaluation        process. IRS agreed that it is time to consider evaluating the process and
                      that it might develop program guidance after such an evaluation. We
                      believe that after an evaluation of the use of the process, IRS should
                      develop program guidance.


                      Advance ruling follow-ups could better help IRS ensure that tax-exempt
Advance Ruling        organizations are complying with the requirements for their tax-exempt
Follow-Ups Could Be   status. Currently, the advance ruling follow-up process is only used to
More Effective        classify Section 50 1(c)(3) exempt organizations as private foundations
                      or public charities on the basis of the amount of public support received
                      during the advance ruling period. Essentially, IRS does a mathematical
                      computation using information from a statement of income sources sub-
                      mitted by the organization. Consideration is not given to how the organi-
                      zation is using its income or the extent to which it is fulfilling its exempt




                      Page 7                                    GAO/GGD-99-66   Tax-Exempt Organizations
                 B-238929




                 purpose. Review of expenditure data as well as revenue data could pro-
                 vide IRS insight into whether the organization is fulfilling its exempt pur-
                 pose and whether there are other potential issues, such as private
                 inurement or unreported unrelated business income.’

                 We reviewed a sample of 31 advance ruling follow-ups collected for us
                 by IRSduring which IRS had used only revenue information to classify
                 organizations as private foundations or public charities. We found, and
                 IRS agreed, that in 13 of the cases, more information about receipts and
                 information about expenditures were needed to resolve questionable
                 matters, such as how exempt purposes were being met and whether
                 there was private inurement. For example, one organization’s initial
                 application projected that annual receipts would be in excess of
                 $300,000. Actual receipts averaged less than $20,000, almost 40 percent
                 of which was from an income source not originally planned and could
                 have been unrelated business income. In addition, questionable expenses
                 that were first disclosed in the initial application were not examined as
                 part of the initial determination or the advance ruling follow-up. Infor-
                 mation needed to examine these receipts and expenses was not
                 requested.

                 If organizations were required to provide both income and expenditure
                 data for advance ruling follow-ups, IRSwould be able to make better
                 assessments of whether they are operating in accordance with their tax-
                 exempt purpose. Expanding the advance ruling follow-up form to
                 include expenditure data or submitting the annual information return
                 currently required of organizations with gross receipts of $25,000 or
                 more could provide much of the necessary data.


                 IRS presently considers only revenue data in following up on its advance
Conclusion and   rulings for tax-exempt status. To better ensure compliance with tax-
Recommendation   exempt status requirements, we recommend that you direct the Assis-
                 tant Commissioner (EP/EO) to obtain and analyze both expenditure and
                 revenue data during the advance ruling follow-up process.



                  ‘Private inurement refers to the prohibited situation in which certain inside individuals, such aa
                 trustees, officers, members, founders, or contributors, receive net earnings of an exempt organization,
                 except as reasonable payment for goods and services. Unrelated business income is the income gener-
                 ated by an exempt organization from conducting any trade or business substantially unrelated to the
                 purpose that qualified the organization for exempt status. Exempt organizations that earn annual
                 unrelated business income in excess of $1,000 must report the income to IRS on Form 990-T and pay
                 tax on it.



                 Page 8                                                  GAO/GGD90-55 Tax-Exempt Organizations
                     I%238929




                     information to measure compliance by tax-exempt organizations. How-
Our Evaluation       ever, they expressed concern about the burden providing such informa-
                     tion might create for some organizations and were unsure of the benefits
                     to be derived. They did agree to consider the recommendation, and may
                     attempt a test in selected districts to determine the benefits that could
                     be derived.

                     Considering the fact that many organizations must currently submit
                     income data for an advance ruling follow-up, we question whether sub-
                     mitting expenditure data would add a significant burden, particularly
                     for those organizations that currently file annual information returns.
                     These returns already include data on expenditures. Further, we believe
                     that this new reporting requirement would help IRS gain better insight on
                     the extent of noncompliance. Accordingly, we believe that as a mini-
                     mum, IRS should test the costs and benefits of obtaining and analyzing
                     expenditure data.


                     Often, IRS must request additional information before determining that
Determination Case   an organization meets the requirements for exemption. Generally, the
Closings Could Be    organization is given up to 35 days to either submit the requested infor-
More Efficient       mation or request an extension. If the organization does not respond
                     within the 35-day period, the case is closed and removed from inven-
                     tory. Approximately 19 percent of all determinations for fiscal year
                     1988 were closed because of insufficient information. If the needed
                     information is submitted at a later date, a new case is established in
                     inventory.

                     The number of cases closed because of insufficient information and sub-
                     sequently reopened is not monitored. However, available IRSstatistics
                     show that 5 percent of all determinations in fiscal year 1988 were
                     reopened cases. We reviewed 35 cases that were closed because of insuf-
                     ficient information. These cases were collected for us by IRS in two dis-
                     tricts Our review disclosed that the information was subsequently
                     received and the cases were reopened in 25 of these cases. In two other
                     cases, the organizations had initiated action to provide the requested
                     information. For 11 of the 25 reopened cases, the requested information
                     was received within 1 month of closing, and in 20 of the 25 cases it was
                     received within 3 months.

                     When a case previously closed for insufficient information is reopened,
                     it must be administratively reestablished in inventory, the case file must


                     Page 9                                  GAO/GGD-99-55 Tax-Exempt Organizations
                      B.238929




                      be retrieved, and it must be reassigned to the specialist. This process
                      often creates delays in responding to the taxpayer and results in unnec-
                      essary technical and processing work. For example, 16 of the 25
                      reopened cases were not reopened and processed until the month after
                      the information was received. Additionally, 11 of the 25 cases were
                      reassigned to a specialist other than the one who had previously worked
                      the case. While cases are normally assigned to the same specialist, IRS
                      officials said that this was not always possible because the initial spe-
                      cialist might be unavailable due to training, reassignment, or heavy
                      work load. Reassignment to a new specialist creates inefficiencies
                      because the newly assigned specialist has to become familiar with the
                      details of the case.


                      IRS agreed that cases may too often be closed prematurely because of
Agency Comments and   insufficient information and that unnecessary closing and reopening of
Our Evaluation        cases causes inefficiencies. IRS said that, as a result of its own concerns
                      about closing procedures for cases with insufficient information, revised
                      case closing procedures were issued in December 1989 after the comple-
                      tion of our fieldwork. These procedures allow an extension of the 35-day
                      waiting period when the organization notifies IRS that it is assembling
                      the requested information. We believe these procedures should reduce
                      the inefficiencies currently created from the frequent closing and subse-
                      quent reopening of cases.


                      As you know, 31 1J.S.C.720 requires the head of a federal agency to
                      submit a written statement on actions taken on our recommendations to
                      the House Committee on Government Operations and the Senate Com-
                      mittee on Governmental Affairs not later than 60 days after the date of
                      the report. A written statement must also be submitted to the House and
                      Senate Committees on Appropriations with the agency’s first request for
                      appropriations made more than 60 days after the date of the report.

                      We are sending copies of this report to the Director, Office of Manage-
                      ment and Budget, the Secretary of the Treasury, and interested congres-
                      sional committees. We will make copies available to others upon request.




                      Page 10                                 GAO/GGD-90-55 Tax-Exempt Organizations
B238929




We appreciated the support and cooperation of your staff during this
work. Major contributors to this report are listed in appendix II. Please
contact me at 272-7904 if you or your staff have any questions concern-
ing this report.

Sincerely yours,




Paul L. Posner
Associate Director, Tax Policy and
  Administration Issues




Page 11                                 GAO/GGD-90-65 Tax-Exempt Organizations
Contenti


Letter                                                                                                       1

Appendix I                                                                                              14
Comments From the            GAO Comment                                                                16
Internal Revenue
Service
Appendix II                                                                                             17
Major    Contributors   to   General Government Division                                                17
                             New York Regional Office                                                   17
This Report
Figures                      Figure 1: Disposition of Determinations in Fiscal Year                          4
                                  1988
                             Figure 2: EO District Office Use of the Expedited                               6
                                  Determination Process




                                                                                                         -
                             Abbreviations

                             EO        exempt organization
                             EP/EO     employee plans and exempt organizations
                             IRS       Internal Revenue Service


                             Page 12                                GAO/GGD-90-65 Tax-Exempt Organizations
                                                   i




Page 13   GAO/GGDso-SS TaxZxempt   Organizations
Appendix I

Comments From the Internal RevenueService


Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.                                       DEPARTMENT          OF THE TREASURY
                                                              INTERNAL         REVENUE          SERVICE
                                                                 WASHINGTON.             D.C.   20224




                                                                     MARP 7 rssa
                             Mr. Paul Posner
                             U.S. General Accounting     Office
                             Associate  Director  for GGD Tax Group
                             1440 New York Ave.,    N.W.
                             Suite      400
                             Washington,         DC 20005

                             Dear Mr.         Posner:
                                    This is in response to your draft     report  entitled    Tax
                             i
                             Administration:
                             Tax-Exemnt Oraanizations.      A copy of this report      was informally
                             provided     to us by a member of your staff    on March 14, 1990.
                                    Your report       makes three recommendations           regarding      the Exempt
                             organizations'        determination      program.      The first    addresses the
                             expedited      determination      process     (also known as the technical
                             screening      program) and recommends that the National                 Office:     (1)
                             evaluate     the current      use of the process as a basis for developing
                             a national       program that will       include    guidance on when technical
                             screening      is to be used: and, (2) assess the possibility                    of
                             redirecting       resources    between determinations          and examinations       as
                             increased      use of technical       screening     results    in more efficient
                             use of determination          resources.
                                    The second recommendation           concerns advance ruling       follow-ups
                             of initial     IRC 501(c)(3)      public    charity determinations.          It
                             recommends that,        to better    insure compliance     with the
                             requirements      for tax exemption,        advance ruling    follow-ups        include
                             a review of expenditure          data (in addition      to the revenue data
                             currently    required).
See comment 1                        The third    recommendation        concerns the so-called          "failure      to
                             establish"      procedures    regarding      those determination         cases      closed
                             because of a lack of sufficient              information       to make a
                             determination.        It recommends that the data on cases closed under
                             these procedures,        and then later        reopened,      be reviewed     in order
                             to establish       an appropriate      time    frame for holding        cases open
                             where the Service        has insufficient         information     to make a
                             determination.
                                    After review of your recommendations    we have several
                             comments about them, particularly     in regard to the background
                             information    (which were shared with members of the audit team in
                             a meeting held on March 21, 1990).




                                     Page14                                                     GAO/GGD-SOSSTax-ExemptOrganizations
              Appendix I
              Comments From the internal Revenue Service




                                                   -2-
    Mf.   Paul     Posner

            In regard to the expedited           determination        process,      we wish to
    note that the program is still             relatively      new (having been
    implemented     nationwide      in FY 1989).         In addition,        since the
    program was started,        and continuing         to present,        the key district
    offices    have been allowed much leeway in how they use this
    process in order to permit the development                  of innovative
    techniques     and applications.          Since it is a relatively              new
    process,     no national    evaluation       of it has been done, although                we
    are now at the point where one is being considered.                          It should be
    noted that we have overseen the technical                  screening        operations     of
    the individual       key district     offices      in order to monit.or their
    progress.      We have encouraged the use of this process and have
    offered    suggestions     on it to the key district              offices,      and we
    contemplate     issuing    program guidelines          once a national          evaluation
    has been completed.
            Concerning    the expansion     of the use of the advance ruling
    follow-ups     to include    expenditure     data, we have reservations
    about this.       Our primary    concern is the burden that this will
    impose on taxpayers,       as well as the resources       it will    cost the
    Service.      We also are not sure of the benefits          that will    be
    derived    from this.     However, we will       consider this matter further
    and may attempt a test of it at one or more key district                 offices
    in order to determine        its benefits.
            Finally,       regarding      the "failure      to establish"      procedures,
    because      of our own concerns in this area, in July 1989 we issued
    guidance to our field             offices      for development       of their     FY 1990
    workplans.           We indicated       that 'Ithe effect     on service      to the
    public     and organizational             cost of closing     cases as "failure          to
    establish"         must also be considered.             We went on to say "it           (the
    IRM) will        recommend holding          cases   open for a reasonable          period
    when the response is expected                  in the near future".          The IRM was
    punlished        in December 1989, allowing             for an extension        of the time
    period     for an organization             seeking a determination         to supply
    missing      information.         In addition,       it has always been our policy
    that determination            cases closed for "failure            to establishI'      and
    then later         reopened be assigned to the same specialist,                    if
    practicable.
              We   hope that   you will     find     these      comments useful.
                                                         Sincerely,


                                             &-b---L
                                             URobert                  I.   Brauer




L

              Page 15                                                  GAO/GGD-9MS Tax-Exempt Organizations
              Appendix I
              Cumments From the Internal   Revenue Service




              The following is GAO’S comment on the Internal Revenue Service’s letter
              dated March 27,199O.


              1. Because IRS recently issued guidance on determination case closing
GAO Comment   procedures, this recommendation has been deleted.




              Page 16                                        GAO/GGD-9046   Tax-Exempt   Organbtious
Appendix II

Major Contributors to This Report


General Government     Issues
Division             Charles Kilian, Assignment Manager


                     Andrew Macyko, Regional Management Representative
New York Regional    John P. Harrison, Evaluator-in-Charge
Office




(268411)             Page 17                              GAO/GGD-90-55   Tax-Exempt   Organizations
             .’




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