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Tax-Exempt Organizations See Substantial Increase in Automatic Revocations Due to COVID-19: IRS Missed Opportunities to Support Tax-Exempt Organization

William A. Bailey & Brian Webb

ATA Journal of Legal Tax Research2025https://doi.org/10.2308/jltr-2024-008article
AJG 1ABDC C
Weight
0.50

What the paper says

ABSTRACT IRC §6033(j), passed in 2006, requires the automatic revocation of tax-exempt organizations that fail to file annual information returns or notices for three consecutive years. Upon reviewing the relevant legal and commentary sources, this paper argues that the statute did not anticipate the impact of COVID-19 on small tax-exempt organizations’ ability to file; as such, the statute caused significant hardship to many tax-exempt organizations whose filing ability was interrupted by COVID-19. The paper further argues that the IRS could have done more to help tax-exempt organizations but instead compounded the revocation problem by inexplicably excusing itself from a statutory requirement to warn tax-exempt organizations that were about to lose their tax-exempt status. The paper recommends solutions to these problems, including postponing the statute’s effect during the COVID-19 years, and a reversal of the IRS position regarding providing notice of imminent automatic revocation. JEL Classifications: K34; L38; M48.

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https://doi.org/https://doi.org/10.2308/jltr-2024-008

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@article{william2025,
  title        = {{Tax-Exempt Organizations See Substantial Increase in Automatic Revocations Due to COVID-19: IRS Missed Opportunities to Support Tax-Exempt Organization}},
  author       = {William A. Bailey & Brian Webb},
  journal      = {ATA Journal of Legal Tax Research},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.2308/jltr-2024-008},
}

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Tax-Exempt Organizations See Substantial Increase in Automatic Revocations Due to COVID-19: IRS Missed Opportunities to Support Tax-Exempt Organization

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.