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File 06152012

Tab 1 - Potential Abusive Historical

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File 06152012

Tab 2 - Potential Abusive

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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 Determination letter submitted 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

income housing, operating a school, and head-start programs. The returnaddress on the original or photocopy of the envelope may be'"ti._.....Ii._.IIII11.~~•••,Federal governmentgrants is listed as the primary source of income. Other identifying factorsinclude intention to build a 42 unit facility, no ownership of property,application showing••••••••••••••iI•••••1

Forward case to Group 7824

Forward case to Group 7824

Forward case to Group 7824

Open

Open

Open

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• 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 charity paysto the donor interest on the loan. May be referred to as a Charity Owned LifeInsurance (CHOLl). May be administered by

Ilay 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 7824 Open

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

Forward case to Group 7824 Open

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12 Pain ManagementClinics

Pain management clinics in applying for exemption under 501 (c)(3)of the Code. These clinics appear to be involved in abusive schemes as theyare forming to avoid state licensing and oversight requirements.

Forward case to Group 7824

Forward case to Group 7824

Open

..Open

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File 06152012

Tab 3 Emerging Issues

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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) thatare currently listed on the Case Assignment Guide (CAG) do not meet this criteria.

x Forward case to Group 7822. Open

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File 06152012

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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File 06152012

Tab 5 - Watch List

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11 2011-#1

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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

2011-#1

Forward case to Group 7888. (coordinator). Note:the coordinator has permission to close "exclusively educational"organizations.

Coordinate processing with Group 7827.

Open- 715-10

.open12113/10

Open­7/11/11

(b) (6)

(b) (6)

(b) (6)

(b) (6)

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