\documentclass{letter}
\date{17 Dec 2012}

\address{Karl Fogel \\
        QuestionCopyright.org (EIN: 26-1798415) \\
        P.O. Box 20165 \\
        Stanford, CA  94309-0165 USA \\
        +1 (312) 772-2726 \\
        {\tt kfogel@questioncopyright.org}}

\signature{Karl~Fogel \\
          President,~QuestionCopyright.org}

\begin{document}

\begin{letter}{Internal Revenue Service, Exempt Organizations Division \\
               In reference to: 0425876271 (LTR 2695C)}

\opening{To Whom it May Concern,}
\parindent 0in

This letter is regarding two issues: the omission of Schedule B from
our 2010 990-EZ tax return, and our lateness in filing our 2011 tax
return.  Note that regarding both matters, we recently spoke by phone
with a Mr. Scow (sp?), ID 10000144901, and with Ms. Annette Eddie, ID
0145184.  They were extremely helpful, for which we are grateful.

Regarding the 2010 Schedule B:

We neglected to check the box on line H of our 2010 990-EZ to indicate
that we didn't need to file a Schedule B.  We didn't check the box
because we were unaware that we were required to check it to make that
indication.  We are now responding to LTR 2695C with a declaration
that we do not need to file Schedule B for 2010.  Furthermore, to
avoid this mistake (and others) in the future, we have compiled a tax
return guidelines/checklist document that is specific to our
organization, and made the relevant officers and volunteers aware of
it.  This document covers the sorts of errors we have made in the past
or are most likely to make.  It should help prevent future incomplete
returns, and at the very least ensure that we don't repeat mistakes.

Regarding our lateness in filing a 2011 return:

We are a small organization and entirely volunteer-run: the board,
officers, and volunteers are all unpaid.  As President, I normally
file our tax returns, in consultation with our Treasurer and our {\em
  pro bono} counsel.  I should have filed our 2011 return in early
2012, but due to personal circumstances I did not: in January 2012 I
moved between cities, a complicated move that involved selling an
apartment at an unexpectedly high, though manageable, loss.  In
dealing with the fallout from that move, I first put off filing our
organization's taxes (neglecting even to file an extension) and
confess that I then simply forgot after the move was complete, for
which I apologize.

Obviously our organization should have enough redundancy to not be
vulnerable to one person's circumstances like this, and we have
established procedures to avoid such a situation in the future.
Specifically, we have now set up an automated reminder system online
that reminds three people (myself, the Treasurer, and one of our
volunteer staff) in mid-January of each year that it's time to start
on our tax return.  We have also created the guidelines/checklist
document mentioned earlier.  Finally, we have completely revamped our
internal accounting system and donor records system so that the
process of filing our taxes will be easier overall from now on, will
be less dependent on the availability of someone who has done it
before, and will be easier for other members of the organization to
assist with or, when necessary, take over entirely.

Because our organization is committed to maximum possible transparency,
to the extent compatible with our published privacy policy, some of
the results of that accounting system overhaul are publicly visible at

\hspace{1cm}{\bf\tt http://questioncopyright.org/finances}

The information there is now generated in a fully automated manner
from the accounting system, which should make it much easier for us to
complete our tax returns in a timely manner in the future.

Regarding potential penalties:

As the above makes clear, we are a small organization, almost entirely
volunteer-run from the board of directors on down; we pay only our
artist-in-residence and, on rare occasions, other artists, for
mission-related work, usually at below-market rates.  While we attract
a fair number of small individual donations, and occasional foundation
grants, the total is not enough to afford paid staff even on a
part-time basis.  Our net assets tend to hover in the low tens of
thousands of dollars; right now around \$18,000, for example, most of
which is already allocated to specific mission-directed projects.

Our failure to file complete and timely tax returns is entirely our
responsibility, and we will of course pay any penalty assessed.
However, a penalty of more than a very small amount would inevitably
have an impact on our ability to fulfill our tax-exempt purpose.  We
have done our best to improve our accounting system and our tax filing
procedures, so that we can avoid such problems in the future, and
accordingly respectfully request that any penalties be waived.

We would be happy to clarify or offer more information regarding any
of the above, and we can be reached via the contact information at the
top of this letter.

\closing{Sincerely,}

\end{letter}

\end{document}
