| Return Reference | Explanation |
|---|---|
| Form 990, Part VI, Section B, Line 11b | A PDF copy of Form 990 is provided to the Board of Directors for review prior to filing with the IRS. |
| Form 990, Part VI, Section B, Line 12c | When voting on matters where a potential conflict of interest may exist, Board members are required to disclose any possible conflicts. |
| Form 990, Part VI, Section B, Line 15a | The Organization has no employees. Compensation for independent contractors is reviewed and approved during the annual budgeting process. Amounts paid by comparable organizations are taken into consideration when determining compensation. |
| Form 990, Part VI, Section B, Line 15b | The Organization has no employees. Compensation for independent contractors is reviewed and approved during the annual budgeting process. Amounts paid by comparable organizations are taken into consideration when determining compensation. |
| Form 990, Part VI, Section C, Line 19 | Governing documents, policies and financial statements are made available upon request. |
| Reasonable Cause Statement for Late Filing of Form 990 | We respectfully request that any penalties and interest related to late filing of 2025 Form 990 be abated due to reasonable cause. Penalties for late filing of Form 990 are imposed under IRC section 6652(c)(1 )(A). 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." Reg. 301.6652-2(f) also states ...no amount imposed by section 6652(d) shall apply with respect to a failure to file or comply under this section if it is established to the satisfaction of the district director or director of the internal revenue service center that such failure was due to reasonable cause.Although not defined in the Regulations under 301.6652, reasonable cause is defined in Reg. 301.6724-l(a)(2) as significant mitigating factors, of which Reg. 301.6724-1(b)(ii) notes one such factor as [i]f the filer has incurred any such penalty in prior years, the extent of the filers success in lessening its error rate from year to year.When it was discovered that the 2025 return had not been filed, the Board of Directors took corrective actions and hired a professional consulting firm to manage its business operations. Additional actions included hiring a third-party accounting firm to handle preparation of financial statements and a CPA to electronically file Form 990 in a timely manner beginning with the Form 990 for the year ended December 31, 2025.Since we have a history of complying with the information return reporting requirements and have no prior penalties for at least the last three-years, we believe that these factors, as prescribed in Treasury Regulation section 301.6724-1, indicate that Association of Commercial Real Estate acted in a responsible manner by exercising reasonable care. We believe 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 late filing.Furthermore, the Board of Directors is in the process of adopting a whistle-blower policy and a document retention and destruction policy.Under penalties of perjury, we declare that the facts presented here are, to the best of our knowledge and belief, true, correct, and complete. |
| Software ID: | 25022934 |
| Software Version: | 2025v4.1 |