501 (c)(3) IRS Determination Letter
Internal Revenue Service
Department of the
Treasury
P. 0. Box 2508
Cincinnati,
OH 45201
Date: November 21, 2000
Person to Contact:
Kendall Hilson 31-07340
Customer Service Representative
American Institute of Marine Studies, Inc
Toll Free Telephone Number:
3497 N Dixie HY
8:00
a.m. to 9:30 p.m. EST
Oakland Park, FL 33334-2872
877-829-5500
Federal Identification Number:
23-7391668
Advance Ruling Period Begins:
September 1999
Advance Ruling Ends:
December 31, 2003
Dear Sir.
This letter is in response to your telephone inquiry
of November 21, 2000, requesting a copy of
your organization's determination letter. This letter will take the place
of the copy you
requested.
Our records indicate that by a determination letter
issued in January 2000 your organization
was recognized as exempt from federal income tax under section 501 (c)(3)
of the Internal
Revenue Code.
Because your organization was newly created, we did
not at that time make a final
determination of its foundation classification under section 509(a) of the
Code. However,
based on information submitted with the application, we classified your
organization as one
that is not a private foundation within the meaning of section 509(a) of
the Code because it
can reasonably expect to be a publicly supported organization described in
sections 509(a)(1)
and 170(b)(1)(A)(vi).
According to this advance ruling, your organization
will be treated as a publicly-supported
organization and not as a private foundation until the end of the advance
ruling period as
shown above. Within 90 days from the end of the advance ruling period,
your organization
must submit to us information needed to determine whether it has met the
requirements of the
applicable support test during the advance ruling period. This information
is currently supplied
on the Form 8734, Support Schedule for Advance Ruling Period.
Grantors and contributors may rely on the
determination that your organization is not a private
foundation until 90 days after the end of its advance ruling period. If
the organization submits
the required information within 90 days, grantors and contributors may
continue to rely on the
advance determination until the Service makes a final determination of
your organization's
foundation status.
The classification discussed in paragraph three (3)
was based on the assumption
that your organization's operations would continue as stated in its
application. If your organization's
sources of support, or its character, method of operations, or purposes
have changed, please
let us know so we can consider the effect of the change on your
organization's exempt status
and foundation status.
Your organization is required to file Form 990,
Return of Organization Exempt from Income
Tax, only if its gross receipts each year are normally more than $25,000.
If a return is
required, it must be filed by the 15th day of the fifth month after the
end of the organization's
annual accounting period. The law imposes a penalty of $20 a day, up to a
maximum of
$10,000, when a return is filed late, unless there is reasonable cause for
the delay.
-2-
American Institute of Marine Studies, Inc
23-7391668
All exempt
organizations (unless specifically excluded) are liable for taxes under
the Federal
Insurance Contributions Act (social security taxes) on remuneration of
$100 or more paid to
each employee during a calendar year. Your organization is not liable for
the tax imposed
under the Federal Unemployment Tax Act (FUTA).
Organizations that are
not private foundations are not subject to the excise taxes under
Chapter 42 of the Code. However, these organizations are not automatically
exempt from
other federal excise taxes.
Donors may deduct
contributions made to your organization as provided in section 170 of the
Code. Bequests, legacies, devises, transfers, or gifts to your
organization for its use are
deductible for Federal estate and gift tax purposes if they meet the
applicable provisions of
sections 2055, 2106, and 2522 of the Code.
Your organization is
not required to file federal income tax returns unless it is subject to
the tax
on unrelated business income under section 511 of the Code. If your
organization is subject to
the tax, it must file an income tax return on the Form 990- T, Exempt
Organization Business
Income Tax Return. In this letter, we are not determining whether any of
your organization’s
present or proposed activities are unrelated trade or business as defined
in Section 513 of the
Code.
The law requires you
to make your organization's annual return available for public inspection
without charge for three years after the due date of the return. You are
also required to make
available for public inspection a copy of your organization’s exemption
application, any
supporting documents and the exemption letter to any individual who
requests such
documents in person or in writing. You can charge only a reasonable fee
for reproduction and
actual postage costs for the copied materials. The law does not require
you to provide copies
of public inspection documents that are widely available, such as by
posting them on the
Internet (World Wide Web). You may be liable for a penalty of $20 a day
for each day you do
not make these documents available for public inspection (up to a maximum
of $10,000 in the
case of an annual return).
Because this letter
could help resolve any questions about your organization’s exempt status
and foundation status, you should keep it with the organization's
permanent records.
If you have any
questions, please call us at the telephone number shown in the heading of
this
letter.
This letter affirms your organization's exempt status.
Sincerely,
