July 16, 1980
Internal Revenue Service, Department of the Treasury, District Director, P.O. Box 2350, Los Angeles, CA. 90053
Employer Identification Number: 99-0194894, Accounting Period Ending December 31, 1980
Foundation Status Classification: 509(a)(2), Advance Ruling Period Ends: December 31, 1981
Person to contact: B. Brewer, Contact Telephone Number: (213)688-4889.
Hawaii Police Athletic Club, c/o Honolulu Police Department, 1455 South Beretania Street, Honolulu, Hawaii 96814
Based on information supplied, and assuming your operations will be as stated in your application for recognition of exemption, we have determined you are exempt from Federal income tax under section 501(c)(3) of the Internal Revenue Code.
Because you are a newly created organization, we are not now making a final determination of your foundation status under section 509(a) of the Code. However, we have determined that you can reasonably be expected to be a publicly supported organization described in section 509(a)(2).
Accordingly, you will be treated as a publicly supported organization, and not as a private foundation, during an advance ruling period. This advance ruling period begins on the date of your inception and ends on the date shown above.
Within 90 days after the end of your advance ruling period, you must submit to us information needed to determine whether you have met the requirements of the applicable support test during the advance ruling period. If you establish that you have been a publicly supported organization, you will be classified as a section 509(a)(1) or 509)(a)(2) organization as long as you continue to meet the requirements of the applicable support test. If you do not meet the public support requirements during the advance ruling period, you will be classified as a private foundation for future periods. Also, if you are classified as a private foundation, you will be treated as a private foundation from the date of your inception for purposes of sections 507(d) and 4940.
Grantors and donors may rely on the determination that you are not a private foundation until 90 days after the end of your advance ruling period. If you submit the required information within the 90 days, grantors and donors may continue to rely on the advance determination until the Service makes a final determination of your foundation status. However, if notice that you will no longer be treated as a section 509(a)(2) organization is published in the Internal Revenue Bulletin, grantors and donors may not rely on this determination after the date of such publication. Also a grantor and donor may not rely on this determination if he or she was in part responsible for, or was aware of, the act or failure to act that resulted in the loss of section 509(a)(2) status, or acquired knowledge that the Internal Revenue Service had given notice that you would be removed from classification as a section 509(a)(2) organization.
If your sources of support, or your purposes, character, or method of operation changes, please let us know so we can consider the effect of the change on your exempt status and foundation status. Also you should inform us of all changes in your name or address.
Generally, you are not liable for social security (FICA) taxes unless you file a waiver of exemption certificate as provided in the Federal Insurance Contributions Act. If you have paid FICA taxes without filing the waiver, you should call us. You are 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, you are not automatically exempt from other Federal excise taxes. If you have any questions about excise, employment, or other Federal taxes, please let us know.
Donors may deduct contributions to you as provided in section 170 of the Code. Bequests, legacies, devises, transfers, or gifts to you for your 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.
You are required to file Form 990, Return of Organization Exempt from Income Tax, only if your gross receipts each year are normally more than $10,000. If a return is required, it must be filed by the 15th day of the fifth month after the end of your annual acccounting period. The law imposes a penalty of $10 a day, up to a maximum of $5,000, when a return is filed late, unless there is reasonable cause of the delay.
You need an employer identification number even if you have no employees. If an employer identification was not entered on your application, a number will be assigned to you and you will be advised of it. Please use that number on all returns you file and in all correspondence with the Internal Revenue Service.
Because this letter could help resolve any questions about your exempt status and foundation status, you should keep it in your permanent records.
If you have any questions, please contact the person whose name and telephone number are shown in the heading of this letter.
(s) W.H. Connett, District Director - letter 1045(DO)(6-77)
August 17, 2001
Internal Revenue Service, P.O. Box 2508, Cincinnati, OH 45201
Employer Identification Number: 99-0194894 DLN: 601206003
Contact Person: Richard Combs, ID#310024, Contact Telephone Number (877)829-5500 Re - our letter dated March, 1980
Addendum Applies: No
Hawaii Police Athletic Federation, c/o Captain Gordon Lee, P.O. Box 22623, Honolulu, HI 96823-2623
This modifies our letter of the above date in which we stated that you would be treated as an organization that is not a private foundation until the expiration of your advance ruling period.
Your exempt status under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3) is still in effect. Based on the information you submitted, we have determined that you are not a private foundation within the meaning of section 509(a) of the Code because you are an organization of the type described in section 509(a)(1) and 170(b)(1)(A)(vi).
Grantors and contributors may rely on this determination unless the Internal Revenue Service publishes notice to the contrary. However, if you lose your section 509(a)(1) status, a grantor or contributor may not rely on this determination if he or she was in part responsible, or was aware of, the act or failure to act, or the substantial or material change on the part of the organization that resulted in your loss of such status, or if he or she acquired knowledge that the Internal Revenue Service had given notice that you would no longer be classified as a section 509(a)(1) organization.
If we have indicated in the heading of this letter that an addendum applies, the addendum enclosed is an intergal part of this letter.
Because this letter could help resolve any questions about your private foundation status, please keep it in your permanent records.
If you have any questions, please contact the person whose name and telephone number are shown above.
(s) Steven T. Miller, Director, Exempt Organizations - letter 1050(DO/CG)
May 5, 1993
Internal Revenue Service, Department of the Treasury, District Director, McCaslin Industrial Park, 2 Cupania Circle, Monterey Park, CA. 91754-7406
Employment Identification Number: 99-0194894
Person to Contact: EOMF Coordinator, Contact Telephone Number: (213)725-1235
Internal Revenue Code Section: 501(c)(3)
HAWAII POLICE ATHLETIC FEDERATION %Capt Gordon Lee HPD, P.O. Box 22623, Honolulu, HI 96823-2623
Thank you for submitting the information shown below or on the enclosure. We have made it a part of your file.
The changes indicated do not adversely affect your exempt status and the exemption letter issued to you continues in effect.
Please let us know about any future change in the character, purpose, method of operation, name or address of your organization. This is a requirement for retaining your exempt status.
Item Changed From To
(NAME) Hawaii Police Athletic Club (SEE ABOVE)
Thank you for your cooperation.
(s) Michael Quinn - letter 976(DO) (Rev. 1-87)
Department of Taxation, State of Hawaii, P.O. Box 259, Honolulu, Hawaii 96809
Hawaii Police Athletic Club, 1455 S. Beretania Street, Honolulu, Hawaii 96814 Attn: Capt. Gordon Lee, Treasurer
We have reviewed your Application for Exemption from the Payment of General Excise Taxes under the provisions of Section 237-23, Hawaii Revised Statutes. Based upon the information submitted in your application, the claim for exemption has been approved.
This approval for exemption does not apply to any income from activity, the primary purpose of which is to produce income, even though such income is to be used or or in furtherance of the exempt activities of the organization. This exemption will be in force only as long as there is no material change in the facts as set forth in your application for exemption.
Furthermore, this exemption does not apply to any general excise tax imposed upon the seller of tangible personal property or upon the person providing a service who may pass on or include such tax in the price of the service rendered or in the sales price of any purchases made by your organization.
Please note that your organization is required to register annually on or before January 31 of each year by filing a statement, Form G-10, and to pay the annual registration fee of $1.00 at the time of such filing. This form will be mailed to you before the end of each year.
Enclosed is your receipt for the current year.
(s) Tomotaru Ogai, Income Tax Program Officer - enclosure cc: George Hoshide