On May 11, 2007, Clifford Gannett, director of the Tax Exempt Bonds division of the Internal Revenue Service (IRS), announced plans to survey thousands of nonprofits with outstanding tax exempt bonds. The survey will be sent this summer to selected 501(c)(3) organizations chosen randomly from among those that reported having tax exempt bonds outstanding on their most recent Form 990. The survey will contain questions related to institutional record-keeping and other post-issuance compliance matters.
This survey will compile general information to help the IRS design official record-keeping requirements and compliance guidance for 501(c)(3) organizations with tax exempt bonds and bond issuers. Explicit documentation guidance currently does not exist. The survey will consist primarily of "yes-no" questions, although other formats, including multiple-choice questions, may be used as well. Because the survey is intended to gather information broadly, the IRS will likely request that responding organizations not include explanatory attachments to their survey answers.
Once Mr. Gannett's office finalizes the survey, the compliance unit of the IRS Exempt Organizations division will send it to between 2,000 and 5,000 nonprofits. While the IRS has stated that it will not use survey answers to further scrutinize particular nonprofits, failure to respond to the survey is not recommended. Although this first batch of surveys is targeted toward 501(c)(3) organizations, the IRS plans to survey government issuers shortly thereafter.