INTERNAL REVENUE SERVICE
P. O. BOX 2508
CINCINNATI, OH. 45201
Employer Identification Number:
Date: JUL 2 4 2001 22-3843841
DLN:
17053067052007
SIDEWALK UNIVERSITY INC
C/O CONRAD HOWELL
Contact Person:
MICHELLE A GLUTZ ID# 31213
DEPARTMENT OF THE TREASURY
15 HUDSON AVE
MAPLEWOOD, NJ 07040-1506
Dear Applicant:
Contact Telephone Number:
(877) 829-5500
Addendum Applies:
Yes
We have considered your application for a group exemption letter recognizing your
subordinates as exempt from federal income tax under section 501(a) of the Internal Revenue Code
as organizations of the type described in section 501(c)(3).
Our records show that you were recognized as exempt from federal income tax under
section 501(c)(3) of the Code. Your exemption letter remains in effect.
Based on information you supplied, we recognize your subordinates whose names appear on
the list you submitted as exempt from federal income tax under section 501(c)(3) of the
Code.
Additionally, we have classified the organizations that you operate, supervise, or
control, and that are covered by your notification to us, as organizations that are not
private foundations because they are organizations of the type described in sections 509(x)(1)
and 170(b)(1)(A)(vi) of the Code.
Donors may deduct contributions to your subordinates as provided in section 170 of the
Code. Bequests, legacies, devises, transfers, or gifts to your subordinates or for
their use are deductible for federal estate and gift tax purposes if they meet the applicable
provisions of section 2055, 2106, and 2522 of the Code.
Your subordinates whose gross receipts each year are normally more than $25,000 are each
required to file Form 990, Return of Organization Exempt From Income Tax, by the 15th day of the
fifth month after the end of their annual accounting period. If you prefer, you may file a group
return for those subordinates that authorize you in writing to include them in that return. If
you are required to file Form 990 for your own activities, you must file a separate return and
may not be included on any group return that you file for your subordinates. The law imposes a
penalty of $20 a day when a return is filed late, unless there is reasonable cause for the
delay. However, the maximum penalty imposed cannot exceed $10,000 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 $100 per day per return, unless there is
reasonable
Letter 2419 (DO/CG)
SIDEWALK UNIVERSITY INC
cause for the delay. The maximum penalty for an organization with gross receipts exceeding
$1,000,000 shall not exceed $50,000. This penalty may also be charged if a return is
not complete, so your subordinates should make sure their returns are complete before
filing them. Please advise your subordinates that, if they receive a Form 990 package in
the mail, they should file the return even if their gross receipts do not exceed the $25,000
minimum. If not required to file, a subordinate should simply attach the label provided, check
the box in the heading to indicate that its annual gross receipts are normally $25,000 or less
and sign the return. This will allow us to update our records to show that the subordinate is not
required to file and to delete that subordinate from the list of organizations that will receive
Form 990 packages in future years.
Your subordinates are required to make their annual information return, Form 990 or Form 990-EZ,
available for public inspection for three years after the later of the due date of the return or
the date the return is filed. You and your subordinates are also required to make available for
public inspection your group exemption application, any supporting documents and this exemption
letter. Copies of these documents are also required to be provided to any individual upon written
or in person request without charge other than reasonable fees for copying and postage.
You may fulfill this requirement by placing these documents on the Internet.
Penalties may be imposed for failure to comply with these requirements. Additional
information is available in Publication 557, Tax-Exempt Status for Your organization, or you
may call our toll free number shown above.
Your subordinates are not required to file federal income tax returns unless subject to the tax on
unrelated business income under section 511 of the Code. Each organization subject to this
tax must file Form 990-T, Exempt Organization Business Income Tax Return. In this letter we
are not determining whether any of your subordinates’ present or proposed activities are
unrelated trade or business as defined in section 513 of the Code.
As of January 1, 1984, each of your subordinates is liable for social security taxes under the
Federal Insurance Contributions Act on remuneration of $100 or more they pay to each of their
employees during a calendar year. Your subordinates are not liable for the tax imposed under the
Federal Unemployment Tax Act (FUTA).
Each year, at least 90 days before the end of your annual accounting period, please
send the items listed below to the Internal Revenue Service Center at the address
shown below.
- A statement describing any changes during the year in the purposes, character, or
method of operation of your subordinates; - A list showing the names, mailing addresses (including Postal ZIP
codes), actual addresses if different, and employer identification numbers of
subordinates that, since your previous report:
a. Changed names or address;
b. Were deleted from your roster; or
Letter 2419 (DO/CG)
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SIDEWALK UNIVERSITY INC
c. Were added to your roster. - For subordinates to be added, attach:
a. A statement that the information on which your present group
exemption letter is based applies to the new subordinates; b. A statement
that each has given you written authorization to
add its name to the roster;
c. A list of those to which the Service previously issued
exemption rulings or determination letters;
d. A statement that none of the subordinates is a private
foundation as defined in section 509(a) of the Code if the group
exemption letter covers organizations described in section 501(c)
(3);
e. The street address of each subordinate whose mailing
address is a P.O. Box; and
f. The information required by Revenue Procedure 75-50, 1975-2
C.B’. 587, for each subordinate that is a school claiming
exemption under section 501(c)(3). Also include any other
information necessary to establish that the school is complying with the
requirements of Revenue Ruling 71-447, 1971-2 C.B. 230. This is
the same information required by Schedule B, Form 1023, Application
for Recognition of Exemption Under Section 501(c)(3) of the Internal
Revenue Code. - If applicable, a statement that your group exemption roster did not
change since your previous report.
Please mail the information requested in this letter to the following address:
Internal Revenue Service
Ogden UT 84201
Your Group Exemption Number is 5408. Your subordinates are required to include this number on
each Form 990, Return of Organization Exempt From Income Tax, and Form 990-T, Exempt
Organization Business Income Tax Return, that they file. Please advise your
subordinates of this requirement and provide them with the Group Exemption
Number.
If the heading of this letter indicates that an addendum applies, the enclosed addendum is
an integral part of this letter.
Because this letter could help resolve any questions about the exempt status and foundation
status of your subordinates, you should keep it for your records.
Letter 2419 (DO/CG)
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SIDEWALK UNIVERSITY INC
If you have any questions, please contact the person whose name and telephone
number are shown in the heading of this letter.
Sincerely yours,
Robert Choi
Director, Exempt Organizations Rulings and Agreements
Letter 2419 (DO/CG)