IRS Form 991: Application for Relief From Revocation

An application for relief from revocation is a formal request to the IRS to reinstate an organization’s tax-exempt status after it has been automatically revoked. The purpose of the application is to demonstrate that the organization has corrected its compliance failures and once again qualifies for tax exemption under the Internal Revenue Code.

Eligibility for Reinstatement

An organization faces automatic revocation of its tax-exempt status for failing to file the required Form 990-series return for three consecutive years. The IRS sends a CP-120A notice to inform the organization of this revocation. To regain its status, the organization must apply for reinstatement, and the specific process depends on the timing of the application and the organization’s filing history.

The IRS provides different procedures for reinstatement. The Streamlined Retroactive Reinstatement Process is available for smaller organizations that were eligible to file Form 990-EZ or Form 990-N for the three years in question. This option requires filing for relief within 15 months of the revocation date and is only available to organizations that have not had their status revoked previously. Organizations that do not meet these criteria must use a different reinstatement process, which involves a more detailed review.

Required Information for the Application

An organization must gather its full legal name, Employer Identification Number (EIN), and the effective date of revocation from the IRS revocation list. The application, which is usually a Form 1023 or Form 1024, requires the applicant to select the appropriate reinstatement procedure based on their eligibility.

For organizations that do not qualify for the streamlined process, a “reasonable cause statement” is a required part of the application. This is a detailed explanation of why the organization failed to file its required returns for three consecutive years. A successful statement can lead to retroactive reinstatement, which treats the tax-exempt status as if it were never revoked.

Filing the Application for Relief

The reinstatement application must be filed electronically. At the time of submission, the organization must also pay the required user fee online through the Pay.gov website. The fee is $600 for organizations filing Form 1023 and $275 for those eligible to use the streamlined Form 1023-EZ. The IRS no longer accepts checks or money orders for these fees.

As part of the reinstatement process, the organization must also file its past-due Form 990-series returns for the years it failed to file. These paper returns should be mailed to the IRS service center in Ogden, UT. Once the IRS approves the application, it will issue a new determination letter confirming the reinstatement of the organization’s tax-exempt status.