2026-02-13T16:22:29-07:00 2023-12-31 381364333 Dickinson Wright 1825 I St NW 900 Washington DC 20006 990EZ 2023-12-01 990476345 The Small Business Relief Fund Inc SMAL 2026596932 1314 Rugby Road Charlottesville VA 22903 Peter Snyder Director and President 2026596932 2026-02-12 1 1 Lindsey Specht P03346898 2027407467 2026-02-12 2023 2025-03-06 01:10:19Z X X X X X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 The organization was formed to provide relief in the form of grants to small businesses impacted by disasters in the United States. The organization was formed on December 27, 2023 and had no program accomplishments during the 2023 tax year. 0 0 0 Peter Snyder Director and President 1 0 0 0 Burson Snyder Director 1 0 0 0 Generra Peck Director 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Leah Malone 1314 Rugby Road Charlottesville VA 22903 2026596932 0 0 0 0 0 0 0 0 0 0 0 NONE NONE 1 X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 X The IRS assigned the entity an EIN for a for-profit organization. After nearly a year of correspondence and phone calls with the IRS, we believe the error was rectified. The organization attempted to file a timely 990N in the spring of 2024, however could not submit the form because the EIN was not associated with a tax-exempt organization. Penalties for late filing are imposed under IRC section 6652(c)(1)(A)(i). However, paragraph 5 of subsection (c) under section 6652 provides that "No penalty shall be imposed under this subsection with respect to any failure if it is shown that such failure is due to reasonable cause." IRS Regulation 301.6724-1 states that the penalty for a failure relating to a reporting requirement is waived if the failure is due to reasonable cause. Reasonable cause may be demonstrated if the failure arose from events beyond the filer's control (impediment to filing) or if the filer establishes that there are significant mitigating factors with respect to the failure and that the filer acted in a responsible manner by exercising reasonable care. Reasonable care is that standard of care that a reasonably prudent person would use under the circumstances in the course of its business in determining its filing obligations and in handling account information such as account numbers and balances. The standard of reasonable care also demands that the filer undertake significant steps to avoid or mitigate the failure. The Regulations indicate that acting in a responsible manner includes rectifying the failure as soon as it is discovered. This reflects the understanding that a problem cannot be fixed until it is discovered. The Small Business Relief Fund Inc. acted responsibly by engaging a law firm and a compliance firm to assist with their 990EZ. Both firms attempted to timely file the form but were prevented from doing so due to the IRS error in assigning the EIN. As soon as the error was rectified, the organization filed the 990EZ. As provided in Treasury Regulation 301.6724-1, we believe the following significant mitigating factors are evidence of reasonable cause: the assignment of the EIN was done incorrectly by the IRS. This mistake was out of the control of the Filer and prevented the filer from filing its 990EZ in a timely fashion. As provided in Treasury Regulation 301.6724-1, we believe the following is evidence that the entity acted responsibly and exercised reasonable care: 1) The Small Business Relief Fund clearly made an effort every year to engage the services of competent professionals and made reasonable efforts to timely file; 2) as soon as it was discovered that the EIN was deficient the organization wrote to and called the IRS to resolve the issue; 3) the delinquent form was filed before receiving any notification from the IRS; 4) and the organization is now current on all of its filings. In addition to reasonable cause, the absence of "willful neglect" is mentioned in several places in the Code and in the Internal Revenue Manual as one factor to consider in determining if abatement of penalties is appropriate. Willful neglect may be understood as meaning a "conscious, intentional failure or reckless indifference." According to the U.S. Supreme Court in Church of the Holy Trinity v. U.S. 143 U.S. 457: "In common parlance, 'willful' is used in the sense of 'intentional' as distinguished from accidental or 'involuntary.' Whatever one does intentionally, he does willfully." According to the U.S. Court of Appeals, 8th Circuit, U.S. v Jack C. Rifen, "willfulness" is "an intentional violation of a known legal duty." Based on the facts and circumstances presented herein, it is clear that there was no intentional violation of a known legal duty; therefore willful neglect could not have been a factor contributing to the delinquency. Based on The Small Business Relief Fund's demonstration of the existence of significant mitigating factors with respect to the failure, especially the fact that the underlying cause was out of the control of the filer, that it acted responsibly and without willful neglect with respect to its filing obligations, and that it has put policies and procedures in place that it is sure will prevent future delinquencies, we respectfully request that the IRS abate all assessed penalties and interest under the reasonable cause provisions of IRC section 6652(c)(5).Thank you for considering our request. Under penalties of perjury, I declare that the facts presented here are, to the best of my knowledge and belief, true, correct, and complete. Pete Snyder.