IRS 990 Nonprofit Audit: Revoked Status & Deductibility

Form 990 data tells you what a nonprofit filed. It does not tell you whether the IRS still recognises it as tax-exempt.

Those are different questions, and they disagree more often than you would expect.

The problem, with a real example

Truechild Inc (EIN 13-4087914) has twelve years of Form 990 filings on record, a 501(c)(3) subsection code, and IRS deductibility code 1 — contributions to this organisation are deductible. Every tool that reads the Form 990 dataset reports exactly that.

The IRS automatically revoked its tax-exempt status on 15 November 2025.

The revocation is not in the Form 990 data. It is in a separate file — the Automatic Revocation of Exemption List — that the Form 990 record does not link to and does not reflect. The organisation is also absent from Publication 78, the IRS list of organisations eligible to receive deductible contributions.

This is not a rare edge case. In a random sample of 40 recently revoked 501(c)(3)s, 19 still had a full Form 990 filing history on the public record.

What this Actor does

For each organisation you give it, it reconciles three official sources and reports where they disagree:

Source	What it answers
ProPublica Nonprofit Explorer (IRS Form 990 extract)	What the organisation filed, and what the Business Master File says about it
IRS Automatic Revocation of Exemption List	Whether the exemption was revoked, when, and whether it was reinstated
IRS Publication 78	Whether the IRS lists it as eligible for deductible contributions

No API key is needed for any of them, and nothing is scraped — all three are published for programmatic use.

The checks

Code	Severity	What it means
exemption_revoked	high	On the IRS auto-revocation list with no reinstatement. The IRS's own statement.
deductibility_claim_contradicted	high	The Form 990 record still says contributions are deductible while the exemption is revoked. The two official sources contradict each other.
revoked_then_reinstated	medium	Exemption was lost and restored. Contributions in the gap may not be deductible.
filing_gap	medium / low	Returns appear unfiled. This is inferred from an absence, not stated by the IRS.
no_filings_on_record	low	No Form 990 of any kind on record.
not_in_pub78	low	Absent from Publication 78 without an obvious reason.
ein_not_found	medium	No such organisation in the Form 990 dataset.

What it deliberately does not do

A tool that shouts about healthy organisations is worse than no tool, because the real findings drown. Four rules keep it quiet:

A revocation and a filing gap are never treated as the same kind of fact. The first is the IRS saying an exemption is gone. The second is this Actor noticing that filings are missing. They get different codes, different severities, and different wording, because acting on the second as though it were the first means telling a donor that a live charity is dead.

Absence from Publication 78 is treated as weak evidence, not proof. Churches are exempt without applying and are frequently unlisted; subordinates under a group exemption ruling are covered by the parent's listing. Measured against a sample drawn from ProPublica: 5 of 12 churches and 4 of 12 universities were absent from Publication 78 while in perfectly good standing. So it is the lowest severity, it carries the reason, and for religious organisations it is suppressed entirely.

A 501(c)(4) is not defective for being absent from a list of 501(c)(3)s. Contributions to it are not deductible by design. That is reported as a fact about the organisation type, never as a warning.

The filing gap is measured against the extended deadline, not the calendar. A Form 990 for tax year Y is not late until 15 November of Y+1. Counting calendar years since the last filing — the obvious way — flags organisations that have filed everything they owe.

If a source could not be read, the answer is unknown, never ok. Half a revocation list looks exactly like a clean one. A truncated download is treated as fatal to the index rather than as an empty result.

Input

{
  "eins": ["13-4087914", "53-0196605"],
  "checkRevocationList": true,
  "checkPublication78": true
}

Hyphenated and bare EINs both work, and a leading zero lost to a spreadsheet's numeric column is restored. Instead of a list you can pass searchQuery, searchState, searchNteeCode or searchSubsection to audit everything a search matches.

Output

One row per organisation. The fields that carry the verdict:

Field	Values
exemptStatus	revoked · reinstated · listed · not_listed · not_applicable · unknown
deductibilityVerdict	not_deductible · deductible · deductible_now · not_deductible_by_type · unconfirmed · unknown (EIN not in the dataset)
exemptStatusReason	Why, in a sentence
issues[]	{ code, severity, message, evidence }
highestSeverity	high · medium · low · ok

Alongside them: revocationDate, reinstatementDate, revocationGapDays, pub78Listed, pub78DeductibilityCode, propublicaDeductibilityCode, latestFilingYear, missedFilingYears, filingCount, totalRevenue, totalExpenses, totalAssets, officerCompensation, latestFilingPdf, and the sources consulted.

Three key-value records are written as well: SUMMARY (counts for the whole run, including which sources were readable), REVOKED (revoked organisations, largest first) and NEEDS_ATTENTION.

Limits, stated plainly

• US organisations only. These are IRS datasets.
• The IRS files are point-in-time. They are refreshed periodically; a revocation from last week may not be in them yet. For a decision with money attached, confirm through the IRS Tax Exempt Organization Search.
• Reinstatement can be retroactive. The bulk file gives one reinstatement date and does not say whether it was retroactive to the revocation, so the reported gap is an upper bound.
• 990-N e-Postcard filings are largely absent from the Form 990 dataset. Small organisations therefore show no filings; the filing-gap check is suppressed for them rather than guessing.
• Each run downloads about 76 MB of IRS bulk data, regardless of how many EINs you ask about. That is the run's fixed cost; the per-organisation cost is one small JSON request. Switch either file off if you do not need it — but with the revocation list off, every status becomes unknown.

Sources

• ProPublica Nonprofit Explorer API — https://projects.propublica.org/nonprofits/api/
• IRS Automatic Revocation of Exemption List — https://apps.irs.gov/pub/epostcard/data-download-revocation.zip
• IRS Publication 78 data — https://apps.irs.gov/pub/epostcard/data-download-pub78.zip

This Actor reports what those sources say. It is not tax advice, and it does not replace the IRS Tax Exempt Organization Search for a decision you are about to act on.