What this service is
Under section 6033(j) of the Internal Revenue Code, an organization that does not file a required annual return or notice for three consecutive years loses its tax-exempt status automatically. The IRS typically notifies the organization with a revocation letter (CP-120A) and lists it on its revocation list. To become exempt again, the organization has to apply, and Rev. Proc. 2014-11 sets out how. We work out which path fits, prepare everything it requires and file the application. Our guide to automatic revocation and reinstatement covers the background.
Who needs it
- Organizations that received a revocation letter or found their name on the IRS revocation list.
- Small volunteer groups that never realized the Form 990-N e-Postcard was required.
- Organizations whose treasurer left and whose filings stopped.
- Boards that discover a revocation when a donor, grant-maker or bank asks for proof of exemption.
The four paths
| Path | Who can use it | Effective date if approved |
|---|---|---|
| Streamlined (section 4) | Eligible to file Form 990-EZ or 990-N for each missed year, never auto-revoked before, applying within 15 months | Date of revocation |
| Retroactive within 15 months (section 5) | Organizations that cannot use the streamlined path, applying within 15 months | Date of revocation |
| Retroactive after 15 months (section 6) | Organizations applying more than 15 months after revocation | Date of revocation |
| Post-mark date (section 7) | Any revoked organization | Date the application is postmarked |
The 15 months run from the later of the date of the revocation letter or the date the IRS posted your name on the revocation list.
What's included
- Path selection: we review your filing history, size and dates and recommend the path that best fits your facts.
- Late returns: we identify every missed year and coordinate the annual returns the chosen path requires. Sections 5 and 6 require paper returns for the three years that caused the revocation and any later unfiled years, marked "Retroactive Reinstatement."
- Reasonable cause statement: for sections 5 and 6, a detailed account of what led to the failure, how you discovered it and the safeguards you have put in place. Section 5 requires reasonable cause for at least one of the three years; section 6 requires it for all three.
- Application: Form 1023, Form 1023-EZ, Form 1024 or Form 1024-A as the path allows, with the correct reinstatement box checked.
- Compliance plan so it does not happen again.
What we need from you
- The revocation letter, if you have it, and your EIN.
- Your original determination letter, if you have one.
- Bank statements and records for each missed year.
- Your organizing documents and bylaws.
- An honest account of why the returns were not filed.
How it works
- Review and quote. We confirm the revocation date, the missed years and your options. You receive a fixed quote before work starts.
- Returns. We coordinate the annual returns your path requires.
- Statement. We draft the reasonable cause statement. An authorized officer signs the penalties of perjury declaration that Rev. Proc. 2014-11 requires.
- Application. We prepare the application, and your authorized officer signs it. It is filed with the user fee for the form used: $600 for Form 1023, Form 1024 or Form 1024-A, or $275 for Form 1023-EZ under Rev. Proc. 2026-5.
- Follow-through. We help with any IRS questions and set up your annual filing reminders.
What affects timing
Reconstructing old records usually takes the longest, and that depends on what you can find. After filing, IRS processing is outside our control. The IRS also says to keep filing annual returns while your reinstatement is pending. If you are near the 15-month mark, contact us quickly: missing it can change which paths are open.
Frequently asked questions
Can we use Form 1023-EZ to be reinstated?
Only for the streamlined path or the post-mark date path, and only if you otherwise qualify for Form 1023-EZ. A 501(c)(3) seeking retroactive reinstatement under sections 5 or 6 must use Form 1023.
What counts as reasonable cause?
The IRS looks at whether you used ordinary business care and prudence. Factors in your favor include reliance on erroneous written IRS information, events beyond your control that made filing impossible, prompt steps to fix the problem and a history of compliance.
Can we be revoked again?
Yes. If you miss three consecutive years again, starting with the year the IRS approves your reinstatement, the revocation repeats, and the streamlined path is no longer available. Our annual compliance service is designed to prevent that.
Sources
- IRS: Rev. Proc. 2014-11. irs.gov
- IRS: Automatic revocation, how to have your tax-exempt status reinstated. irs.gov
- IRS: Instructions for Form 1023-EZ (Rev. January 2025). irs.gov
- IRS: Rev. Proc. 2026-5, Internal Revenue Bulletin 2026-1. irs.gov
IRS forms, fees and inflation-adjusted amounts change. We review this page when the IRS publishes new instructions.
501Nonprofit.com is a private company, not the IRS. This page is general information, not legal or tax advice for your organization. Example organizations and figures are hypothetical.