\documentclass[12pt]{letter}
\date{12 April 2013}

\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 \\
               {\em In reference to: Notice CP504B, tax period 2011}}

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

This letter is to request a waiver of the penalty (\$1930.29 including
\$5.54 interest) charged for our lateness in filing our 2011 990-EZ
tax return.

We previously sent this explanation and waiver request, together with
our late tax return, on 17 December 2012.  We were instructed to send
them together by the IRS representatives mentioned below.  However,
when I spoke today to Mr. Kelly Browning (ID 1867212), he explained
that sometimes such letters get separated from the return in
processing, so that the department responsible for determining the
penalty doesn't see the letter in time.  He seemed to think that's
what had happened here.

Thus, what follows is essentially the same letter we sent in December
2012, lightly edited and updated for clarity.

\begin{center}\noindent\rule{8cm}{0.4pt}\end{center}

[Please note that regarding this matter, we spoke in late 2012 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.]

We are a small organization and entirely volunteer-run: the board,
officers, and other 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 now
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 compiled a tax return
guidelines/checklist document that is specific to our organization,
and made the relevant officers and volunteers aware of it.  This will
help ensure we will not be late in the future, by making the process
much easier for those doing it.  Finally, we have completely revamped
our internal accounting system and donor records system so that the
process of gathering information for our tax filing will be simpler,
less dependent on the availability of someone who has done it before,
and 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 overhaul are publicly visible at
{\tt 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.

{\bf Request for waiver of penalty:}

As the above makes clear, we are a small organization run by
volunteers on a tiny budget.  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 currently 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
-- about \$18,000 as of the beginning of this year, for example, most
of which is already allocated to specific mission-directed projects.

Our failure to file a complete and timely tax return is entirely our
responsibility, and we will of course pay the penalty if the IRS
chooses not to waive it.  However, payment of this penalty 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 lateness in the
future, and therefore we respectfully request that the penalty for
filing our 2011 990-EZ late be waived.  We would be happy to clarify
or offer more information regarding any of the above, and can be
reached via the contact information at the top of this letter.

\closing{Sincerely,}

\end{letter}

\end{document}
