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(c)(4) applicant can’t challenge Rev. Ruling

(c)(4) applicant can’t challenge Rev. Ruling

(c)(4) applicant can’t challenge Rev. Ruling

An applicant for 501(c)(4) social welfare status may not challenge the facial constitutionality of a Revenue Ruling relied upon by the Internal Revenue Service in denying its claim for (c)(4) status, the Fifth Circuit Court of Appeals has ruled. Freedom Path, which has been seeking the recognition of (c)(4) status for several years, challenged the IRS denial in a District Court in Texas. ( See Nonprofit Issues ® , 2/15. ) The IRS had asked the applicant for additional information but Freedom Path refused to provide it, in part because it said the IRS had leaked its tax returns to a news organization. In 2013, the IRS sent Freedom Path a proposed denial letter, which applied Revenue Ruling...

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