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THE TAXPAYER IS IN RECEIPT OF LETTER NUMBER 2697C IN REGARDS TO THE TAX PERIOD ENDED JUNE 30, 2021, IN WHICH THEIR IRS FORM 990PF WAS NOT ACCEPTED BY THE INTERNAL REVENUE SERVICE, AS IT WAS NOT ELECTRONICALLY FILED. IN THE FOLLOWING PARAGRAPH THE TAXPAYER WILL DEMONSTRATE ITS' CASE FOR AN ABATEMENT OF THE PENALTIES, SHOULD THEY BE ISSUED IN THE FUTURE. STATEMENTS OF FACTS AND CIRCUMSTANCES LEADING TO NONCOMPLIANCE THE TAXPAYER HAD PREVIOUSLY BEEN REQUIRED TO FILE THEIR FORM 990 BY PAPER AS THEY WERE IN THE FIRST 5 YEARS OF THEIR PUBLIC SUPPORT TEST. IN YEAR 6, WHEN THEY BECAME A PRIVATE FOUNDATION, DUE TO PRIOR PAPER FILINGS, THEY CONTINUTED TO PAPER FILE THEIR FORM 990. THE TAXPAYER TIMELY PAID THEIR TAX DUE ELECTRONICALLY THROUGH EFTPS. ONCE THE TAXPAYER BECAME AWARE OF THE ISSUE IN THE ABOVE NOTICE, DATED JULY 29, 2022, THEY PROMPTLY ELECTRONICALLY FILED THEIR IRS FORM 990PF. DEMONSTRATING REASONABLE CAUSE THE TAXPAYER TAKES ITS' FILING OBLIGATIONS SERIOUSLY AND HAS ALWAYS FILED ALL TAX FILINGS ON TIME, INCLUDING THE RETURN ENDING JUNE 30, 2021.IRS REGULATION 301.6724-1(A) STATES THAT THE PENALTY FOR A FAILURE RELATING TO A REPORTING REQUIREMENT IS WAIVED IF THE FAILURE IS DUE TO REASONABLE CAUSE. REASONABLE CAUSE MAY BE DEMONSTRATED IF THE FILER ESTABLISHES THAT THERE ARE SIGNIFICANT MITIGATING FACTORS WITH RESPECT TO THE FAILURE AND THAT THE FILER ACTED IN A RESPONSIBLE MANNER BY EXERCISING REASONABLE CARE, WHICH IS THAT STANDARD OF CARE THAT A REASONABLY PRUDENT PERSON WOULD USE, AND THAT THE FILER UNDERTOOK SIGNIFICANT STEPS TO AVOID OR MITIGATE THE FAILURE. AS PROVIDED UNDER TREASURY REGULATION SECTION 301.6724-1(A), SIGNIFICANT MITIGATING FACTORS INCLUDE ALL PRIOR FILINGS BEING FILED TIMELY AND NO PREVIOUSLY ASSESSED PENALTIES AGAINST THE TAXPAYER FOR NON-COMPLIANCE ISSUES RELATED TO REQUIRED INFORMATIONAL FORM 990 FILING REQUIREMENTS. REQUEST FOR ABATEMENTNO PENALTY HAS BEEN ASSESSED IN THE ABOVE NOTICE. ADDITIONALLY THE TAXPAYER, HAVING FILED THEIR FORM 990PF TIMELY, DID NOT REALIZE THAT THERE WAS AN ISSUE UNTIL AFTER THE FILING DEADLINE. THE ABSENCE OF "WILLFUL NEGLECT" HAS BEEN DEEMED BY THE IRS TO BE ONE FACTOR THAT MAY INDICATE THE EXISTENCE OF REASONABLE CAUSE. THE TAXPAYER HAS NOT SHOWN WILLFUL NEGLECT WITH RESPECT TO ITS FILING OBLIGATIONS AND BELIEVES THEY HAVE DEMONSTRATED THIS WITH THE STATEMENTS AND EVIDENCE IN THIS REQUEST.THE TAXPAYER BELIEVES THAT IT FALLS WITHIN THE REASONABLE CAUSE ABATEMENT PROVISIONS OF THE CODE BY HAVING ESTABLISHED SIGNIFICANT MITIGATING FACTORS WITH RESPECT TO THE FAILURE, AND BY ESTABLISHING THAT THEY ACTED RESPONSIBLY TO CORRECT THE FAILURE, ONCE DISCOVERED. THE TAXPAYER HAS ALWAYS HAD EVERY INTENTION OF BEING IN COMPLIANCE WITH ALL OF ITS FILING REQUIREMENTS.THE TAXPAYER RESPECTFULLY REQUESTS THAT SHOULD THE IRS ISSUE PENALTIES IN THE FUTURE THAT THEY ABATE ALL PENALTIES ASSESSED FOR THE LATE FILING OF FORM 990PF FOR THE YEAR ENDED JUNE 30, 2021 AND APPRECIATES YOUR CONSIDERATIONS OF OUR REQUEST.UNDER PENALTIES OF PERJURY, THE TAXPAYER HEREBY DECLARES THAT THE STATEMENTS CONTAINED HEREIN, TO THE BEST OF OUR KNOWLEDGE AND BELIEF, ARE TRUE, CORRECT, AND COMPLETE.
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