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ter, '•i • jtjtfj r. 5'i PETERS HUMAN SERVICES you would no longer be classified as a section 509 ( a ) ( 1 ) organization . Donors may deduct contributions to you as provided in section 170 of the Code . Bequests , legacies , devises , transfers , or gifts to you or for your use are deductible for federal estate and gift tax purposes if they meet the applicable provisions of Code sections 2055 , 2106 , and 2522 . Contribution deductions are allowable to donors only to the extent that their contributions are gifts , with no consideration received . Ticket pur -_ chases and similar payments in conjunction with fundraisinq events may not necessarily qualify as deductible contributions , depending on the circum - s stances . See Revenue Ruling 67 - 246 , published in Cumulative Bulletin 1967 - 2 , on page 104 , which sets forth guidelines regarding the deductibility , as Chari - table contributions , of payments made by taxpayers for admission to or other participation in fundraising activities for charity . In the heading of this letter me have indicated whether you must file Form 990 , Return of Organization Exempt From Income Tax . If Yes is indicated , you are required to file Form 990 only if your gross receipts each year are normally more than $ 25 , 000. However , if you receive a Form 990 package in the mail , please file the return even if you do not exceed the gross receipts test . If you .are rot required to file , simply attach the label provided , check the box in the heading to indicate that your annual gross receipts are normally 5251000 or less , and sign the return . If a return is required , it - must be filed by the 15th day of the fifth month after the end of your annual . accounting period . A penalty of $20 a day is charged when a return is filed late , unless there is reasonable cause for the delay . However , the maximum penalty charged cannot exceed 610 , 000 or 5 percent of your gross receipts for the year , whichever is less . For organizations with gross receipts exceeding $ 1 , 000 , 000 in any year , the penalty is 5100 per day per return , unless there is reasonable cause far the delay . The maximum penalty for an organization with gross receipts exceeding 61 , 000 , 000 shall not exceed $ 50 , 000 . This penalty may also be charged if a • return is not complete , so be sure your return is complete before you file it . You are required to make your annual return available for public inspection for three years after the return is due . You are also required to make available a copy of your exemption application , any supporting documents , and this exemption letter . Failure to make these documents available for public inspection may subject you to a penalty of 320 per day for each day there is a failure to comply ( up to a maximum of $ 10 , 000 in the use of an annual return ) . You are not required to file federal income tax returns unless you are subject to the tax on unrelated business income under section 511 of the Code . If you are subject to this tax , you must file an income tax return on Form 990 - T , Exempt Organization Business Income Tax Return . In this letter we are not determining whether any of your present or proposed activities are unre- lated trade or business as defined in section 513 of the Code . Letter 947 ( DO / CG )