# Losing and Regaining 501(c)(3) Status for a Booster Club

> How a booster club loses 501(c)(3) status after three missed Form 990 filings and the four ways to regain it under Rev. Proc. 2014-11, with fees and deadlines.

- URL: https://boosterclub.org/taxes/revocation-and-reinstatement/
- Section: Taxes
- Updated: 2026-10-06

A booster club that fails to file its required Form 990-N, 990-EZ, or 990 for three consecutive years loses its 501(c)(3) status, its federal recognition as a tax-exempt charitable or educational organization, automatically under section 6033(j) of the Internal Revenue Code (IRC). No hearing or appeal stops it, and the Internal Revenue Service (IRS) has no authority to undo a proper revocation. The club regains exemption only by applying again, and how quickly it acts decides whether the gap can be erased.

In volunteer-run clubs it usually happens quietly, across several officer turnovers, with each new treasurer assuming the last one filed. The president and treasurer own the recovery, and the board approves the application and the fee.

## How Automatic Revocation Works

1. The club misses its annual return or notice for one year. Form 990-N carries no penalty for lateness, so nothing visible happens.
2. The club misses a second consecutive year. For second years required to be filed after 2019, the Form 990-EZ instructions state that the IRS notifies the organization of how to comply. The notice goes to the address on file, often a former officer's home.
3. The club misses a third consecutive year. Revocation takes effect on the original due date of that third return or notice.
4. The IRS mails a revocation letter and adds the club to its public Auto-Revocation List, which it updates monthly and publishes through Tax Exempt Organization Search.

Example: a calendar-year club that did not file for 2023, 2024, or 2025 lost its exemption effective May 15, 2026, the due date of the 2025 filing.

## What Revocation Means

| Area | Effect |
|---|---|
| Federal income tax | The club is taxable and must file a federal income tax return (Form 1120 or Form 1041, as applicable) for periods it is not exempt |
| Donors | Gifts made after the revocation date are not tax deductible unless exemption is later reinstated back to that date |
| Public listing | The club is removed from the IRS list of organizations eligible for deductible contributions |
| State exemptions | State income, franchise, and sales tax exemptions that depend on 501(c)(3) status may lapse; varies by state |
| Partners | Grantors, employer matching programs, and many school districts require current 501(c)(3) status |

## How to Find Out Whether the Club Was Revoked

1. Search the club's Employer Identification Number (EIN) in IRS Tax Exempt Organization Search. The record shows the revocation date if there is one, and any reinstatement date.
2. Check the same tool for the club's past Form 990-N filings or returns.
3. Search the club's old email and mail for an IRS revocation letter.
4. If records are unclear, call IRS Tax Exempt and Government Entities Customer Account Services at 877-829-5500 with the EIN ready.

## The Four Reinstatement Paths

Revenue Procedure (Rev. Proc.) 2014-11 sets out four ways back. The 15-month clock runs from the later of the date of the revocation letter or the date the IRS posted the club on the Auto-Revocation List.

| Path | Who may use it | Deadline | What the club files | Exemption restored from |
|---|---|---|---|---|
| Streamlined retroactive (Section 4) | Clubs eligible to file Form 990-EZ or 990-N for each of the three missed years, never revoked before | Within 15 months | Form 1023 or 1023-EZ with the user fee; no reasonable cause statement | Revocation date (no gap) |
| Retroactive within 15 months (Section 5) | Clubs that cannot use Section 4, such as Form 990 filers or clubs revoked before | Within 15 months | Form 1023 with the user fee, a reasonable cause statement for at least one of the three years, and the missing returns | Revocation date (no gap) |
| Retroactive after 15 months (Section 6) | Any club past the 15-month window | None | Same as Section 5, but reasonable cause must be shown for all three years | Revocation date (no gap) |
| Postmark date (Section 7) | Any club | None | Form 1023 or 1023-EZ with the user fee | Postmark date of the application (gap remains) |

Most small booster clubs qualify for the streamlined path if they act within 15 months. Waiting past that point turns a routine application into a reasonable cause argument covering all three years.

### Missing Returns Under Each Path

- **Streamlined (Section 4).** The club does not file back Forms 990-N. For any missed year in which it was required to file Form 990-EZ, it files a paper Form 990-EZ marked "Retroactive Reinstatement" to the IRS at Ogden, UT 84201-0027, and the IRS will not impose the late-filing penalty for those years.
- **Sections 5 and 6.** The club files paper annual returns for all three missed years and any later missed years, marked "Retroactive Reinstatement," and includes a statement with the application confirming they were filed.

## Fees and Which Application to Use

The user fee is the same as an initial application: $600 for Form 1023 and $275 for Form 1023-EZ, paid through Pay.gov when the application is filed.

Form 1023-EZ may be used only for reinstatement under Section 4 or Section 7, and only by a club that passes the Form 1023-EZ eligibility worksheet. That worksheet requires, among other things, projected gross receipts of $50,000 or less in each of the next three years, actual gross receipts of $50,000 or less in each of the past three years, and total assets of $250,000 or less. A club seeking reinstatement under Section 5 or 6 must file the full Form 1023. Rev. Proc. 2014-11 asks applicants to write the name of the path at the top of the application, such as "Revenue Procedure 2014-11, Streamlined Retroactive Reinstatement."

## Writing a Reasonable Cause Statement

Sections 5 and 6 require a statement showing the club exercised ordinary business care and prudence in trying to meet its filing requirement. It must describe the facts that led to the failure, how the failure was discovered, and the steps taken to prevent it from happening again. Rev. Proc. 2014-11 lists factors that weigh in favor, including events beyond the club's control, prompt correction once discovered, new safeguards, and a history of compliance.

"The treasurer left and nobody knew" is a description of the failure, not a reasonable cause by itself. A strong statement adds what the club has changed: a written compliance calendar, a board report of each filing, an address that survives turnover. The statement must end with a declaration, signed under penalties of perjury by an authorized officer, in the form Rev. Proc. 2014-11 provides.

## Recovery Plan, Step by Step

1. Confirm the revocation date and the date of the revocation letter or list posting.
2. Calendar the 15-month deadline.
3. Stop describing gifts as tax deductible until the outcome is known, and tell major donors and sponsors the facts.
4. Determine the path and the application form.
5. Gather the articles, bylaws, financial records for the missed years, and any old IRS letters.
6. Prepare any paper returns the chosen path requires.
7. File the application on Pay.gov with the user fee.
8. Keep filing the annual Form 990-N or return each year while the application is pending.
9. If reinstatement is not retroactive, have a preparer review whether the club owes federal or state income tax returns for the gap.
10. Notify state agencies as the club's [state page](https://boosterclub.org/states/) requires.

## Common Mistakes

- **Missing the 15-month window.** Boards debate for a year, and the club loses the streamlined path that required no explanation.
- **Filing Form 1023-EZ for a Section 5 or 6 reinstatement.** The short form is not available for those paths, and the application is delayed or decided on the wrong basis.
- **Ignoring the gap under the postmark path.** Donors who gave during the gap may not be able to deduct their gifts, and the club may owe tax returns for that period.
- **Fixing the paperwork but not the cause.** A reinstated club that misses three more years is revoked again and cannot use the streamlined path the second time.
- **Promising deductibility during the application.** Sponsors and donors rely on the statement, and the club may have to retract it.

## Checklist

- [ ] Look up the club's EIN in IRS Tax Exempt Organization Search and record any revocation date (treasurer)
- [ ] Find the revocation letter date or list posting date and calendar the 15-month deadline (secretary)
- [ ] Pause all statements that gifts are tax deductible until status is resolved (president)
- [ ] Choose the Rev. Proc. 2014-11 path and the application form, and record the decision in the minutes (board)
- [ ] Prepare any paper Forms 990-EZ or other returns the chosen path requires (treasurer)
- [ ] Draft and sign the reasonable cause statement if using Section 5 or 6 (president)
- [ ] File Form 1023 or 1023-EZ on Pay.gov with the user fee (president)
- [ ] Continue filing the annual Form 990-N or return while the application is pending (treasurer)
- [ ] Notify state agencies and update state exemptions as required (treasurer)
- [ ] Adopt a compliance calendar and a standing board report on filings (board)

## Related Pages

- [How to Get 501(c)(3) Status for a Booster Club](https://boosterclub.org/start/501c3/) for completing Form 1023 or 1023-EZ
- [How to File Form 990-N for a Booster Club](https://boosterclub.org/taxes/form-990-n/) for staying current after reinstatement
- [Booster Club Compliance Calendar](https://boosterclub.org/taxes/compliance-calendar/) for the deadlines that prevent this
- [Booster Club Officer Transition](https://boosterclub.org/governance/officer-transition/) for handing off filing duties
- [Booster Club Records and Document Retention](https://boosterclub.org/governance/records/) for keeping the determination letter and filings

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*This page is general information for volunteer-run booster clubs. It is not legal,
tax, or accounting advice, and BoosterClub.org is not a law firm, accounting firm, or
government agency. Rules change and vary by state and district. Confirm current
requirements with the IRS, the relevant state agency, the school district, and a
qualified professional before acting. If a fact on this page is out of date, we want
to know.*

## Sources

1. IRS: https://www.irs.gov/charities-non-profits/automatic-revocation-of-exemption
2. IRS: https://www.irs.gov/charities-non-profits/charitable-organizations/automatic-revocation-how-to-have-your-tax-exempt-status-reinstated
3. IRS: https://www.irs.gov/pub/irs-drop/rp-14-11.pdf
4. IRS: https://www.irs.gov/charities-non-profits/form-1023-and-1023-ez-amount-of-user-fee
5. IRS: https://www.irs.gov/instructions/i1023ez
6. IRS: https://www.irs.gov/instructions/i990ez
7. IRS: https://www.irs.gov/charities-non-profits/annual-electronic-filing-requirement-for-small-exempt-organizations-form-990-n-e-postcard