It is important to answer each line of Form 990 in a manner consistent with filing a complete and accurate return, even though some items may seem immaterial.
Troas Bible College (TBC) is a private college exempt under Internal Revenue Code section 501(c)(3) and 170(b)(1)(A)(ii). They are required to file Form 990 annually.
TBC’s Controller is pulling together the data for their Form 990. She asks about Form 990, Part VI, Line 20 that asks, “State the name, address, and telephone number of the person who possesses the organization’s books and records.” She says, “I have some friends at other schools who say that they enter only, ‘THE ORGANIZATION’ on this line. That’s what we’d like to do this year.”
We explain that, although other institutions may answer this line in that manner, it is not within the scope of the Form 990 instructions.
2017 Form 990 Instructions (Part VI, Line 20 – page 24):
Line 20. Provide the name of the person who possesses the organization’s books and records, and the business address and telephone number of such person (or of the organization if the books and records are kept by such person at a personal residence). If the books and records are kept at more than one location, provide the name, business address, and telephone number of the person responsible for coordinating the maintenance of the books and records. The organization isn’t required to provide the address or telephone number of a personal residence of an individual. If provided, however, such information will be available to the public.
- As noted in previous “Tax Tips,” it is more important than ever to adhere to the IRS’ Form 990 instructions.
- The instructions clearly state that the “name of the person” should be entered at Part VI, Line 20. If appropriate, the business address and phone number of the organization may be entered.
- Do not include personal information about the “person who possesses the organization’s books and records.”
- Throughout Form 990, just because other schools take an erroneous approach to line item answers does not mean that we can/should.
Specific questions? Email Dave Moja
The information provided herein presents general information and should not be relied on as accounting, tax, or legal advice when analyzing and resolving a specific tax issue. If you have specific questions regarding a particular fact situation, please consult with competent accounting, tax, and/or legal counsel about the facts and laws that apply.
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