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?Iti - Z - - . 4 • *ST pETtRS HUMAN ScRVIC :. S - T- you would no longer be classified as a section 509 ( a ) ( 1 ) organization . - r , Donors may deduct contributions to you as provided in section 170 of the Cade _ 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 . f r Contribution deductions are allowable to donors only to the extent that their contributions are gifts , with no consideration received . Ticket pur - chases and sisilar payments in conjunction with fundraisinq events may not i nec - ssarily qualify as deductible contributions , depending on the cirCUAm s Lances _ See Revenue Ruling 67 - 246 , published in Cumulative Bulletin 1967 - Z , an 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 fundraisinq activities for charity . In the heading of this letter we have indicated whether you must file Form 990 , Return of Organization Exempt From Income Tax . If Yes is indicated , you are required to file Fara 990 only if your gross receipts each year are normally more than $ 25 , 000 . However , if you receive a Fora 990 package in the mail , please file the return even if you do not exceed -the gross receipts test . If you are not required to file , simply attach the label provided , check the box in the heading to indicate that your annual gross receipts are normally 525 , 000 or Less , and sign the return _ If a return is required , it - oust be filed by the 15th day of the fifth month after the end of your annual accounting period _ A penalty of S20 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 SL01000 or 5 percent of your grass receipts for the year , whichever is Less _ For organizations with gross receipts exceeding $ 1 , 000 , 000 in any y " ar , the penalty is 6100 per day per return , unless there is reasonable cause far the delay . The maximum penalty for an organization with gross receipts exceeding ; 1 , 000 , 000 shall not exceed 550 , 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 sake available a copy of your exemption application , any supporting documents , and this exeantion letter . Failure to sake these documents available for public inspection say subject you to a penalty of - S20 per day for each day there is a failure to comply ( up to a maximum of $ 10 , 000 in the case of an annual return ) _ You are not required to file federal income tax returns unless you are subject to the tax an 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 , Cxempt Organization Business Income Tax Return . In this letter we are not determininq wnether any of your present or proposed acts vities are unre- lated trade or business as defined in section 5L3 of the Code . Letter 947 ( DO / CG )