2021-05-17T23:11:20-07:00 2019-12-31 990 2019-01-01 462368538 SDG IMPACT FUND INC SDGI 4048259529 475 E MAIN STREET 154 CARTERSVILLE GA 30121 ANTHONY SUBER EXECUTIVE DIRECTOR 4048259529 2021-05-17 2019 2022-09-23 18:48:47Z X ANTHONY SUBER 475 E MAIN STREET 154 CARTERSVILLE GA 30121 12985087 0 X www.sdgimpactfund.org X 2013 GA A donor advised fund in support of the 17 United Nation's Sustainable Development Goals (SDGs). 4 4 0 0 0 0 1390000 12985087 0 0 0 0 0 0 1390000 12985087 0 1010652 0 0 0 255122 0 0 0 0 70068 0 1335842 1390000 11649245 1507475 15095576 0 1010652 1507475 14084924 A donor advised fund in support of the 17 United Nation's Sustainable Development Goals (SDGs). 0 0 1335842 0 0 A donor advised fund in support of the 17 United Nation's Sustainable Development Goals (SDGs). 0 0 0 A donor advised fund in support of the 17 United Nation's Sustainable Development Goals (SDGs). 0 0 0 A donor advised fund in support of the 17 United Nation's Sustainable Development Goals (SDGs). 0 0 0 1335842 1 1 0 0 0 1 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 0 0 1 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 X 4 4 0 0 0 0 0 0 0 1 1 0 0 0 1 1 0 1 1 0 0 0 GA X X X ANTHONY SUBER 4048259529 475 E MAIN STREET 154 CARTERSVILLE GA 30121 X ANTHONY SUBER EXECUTIVE DIRECTOR & CHAIRMAN 40 0 X X 0 0 0 VINCENT MOLINARI DIRECTOR 4 0 X 0 0 0 AMBER NYSTROM DIRECTOR & COO 40 0 X X 0 0 0 COLBORN BELL DIRECTOR & CFO 4 0 X X 0 0 0 DR BRYAN DOREIAN CHIEF DEVELOPMENT MAGUS 40 0 X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 12985087 10377842 12985087 0 0 0 0 0 0 0 12985087 0 0 0 1010652 1010652 0 0 0 0 0 0 0 0 0 0 0 0 0 0 255122 255122 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 26500 26500 0 0 6000 6000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 24761 24761 0 0 3600 3600 0 0 460 460 0 0 0 0 0 0 0 0 0 0 5930 5930 0 0 0 0 0 0 500 500 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2317 2317 0 0 0 0 0 0 1335842 1335842 0 0 0 2607244 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2110490 1507475 10377842 1507475 15095576 0 0 0 1010652 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1010652 X 1507475 14084924 0 0 1507475 14084924 1507475 15095576 11649245 928204 0 0 0 0 X 0 0 0 X 5000 45000 117475 1390000 12985087 14542562 0 0 0 0 0 0 0 0 0 0 0 0 5000 45000 117475 1390000 12985087 14542562 0 14542562 0 0 0 0 1099836 1099836 0 0 0 0 0 0 0 0 0 0 0 0 15642398 15642398 0.92969 0.95 X Schedule A, Part I, Line 10 No other income to report. Schedule A, Part III, Line 12 No net income from unrelated business to report. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 78 0 12985087 0 1010652 0 13074272 0 1 1 DIGITAL ASSETS 10377842 10377842 1 SEE ATTACHMENT SEE ATTACHMENT SEE ATTACHMENT GA 30121 000000000 502(c)(3) 786526 224126 FAIR MARKET VALUE VARIOUS 174 0 Schedule I, Part I, Line 2 GRANTS - GRANTS ARE AWARDED TO ORGANIZATIONS BASED ON DONOR RECOMMENDATIONS AND IN CERTAIN CIRCUMSTANCES, A COMPREHENSIVE APPLICATION PROCESS IS REQUIRED, FUNDS ARE GRANTED TO 501(C)(3) ORGANIZATIONS THAT ADDRESS A VARIETY OF ISSUES THAT FIT WITHIN THE UNITED NATIONS 17 SUSTAINABLE GOALS (SDGs) AND GUIDELINES. X DIGITAL ASSETS 17 0 FAIR MARKET VALUE 0 0 1 0 Schedule M, Part I, Lines 25-28 DIGITAL ASSETS Form 990, Part VI, Section B, Line 11b THE BOARD OF DIRECTORS HAS DESIGNATED THE EXECUTIVE DIRECTOR TO PRELIMINARILY REVIEW THE ANNUAL FORM 990. ONCE REVIEWED AND APPROVED BY THE CFO THE FORM 990 IS FORWARDED TO THE FULL BOARD FOR REVIEW, APPROVAL PRIOR TO FILING. Form 990, Part VI, Section C, Line 19 FORM 990, PART VI, SEC. C DISCLOSURE, QUESTION 19: THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS DURING THE TAX YEAR UPON REQUEST. This is a request for abatement of daily delinquency penalties assessed against SDG Impact Fund for filing a late Form 990. We are requesting abatement under the reasonable cause provisions IRC section 6652. SDG Impact Fund (SDGIF), acknowledges that it filed the return after the due date. However, we believe we can show that there was reasonable cause for filing the return after the due date. About the SDG Impact Fund SDGIF is a donor advised fund in support of the 17 United Nation's Sustainable Development Goals (SDGs) in Cartersville, Georgia which began in 2013 as the Bartow Family Promise. The organization grew rapidly due to community support and in 2016 the active serving Board of Director Members became non-compliant in the quarterly meetings, financial record keeping, and operational record keeping. The new Board Members made swift adjustments in all of these areas, renamed the organization the SDG Impact Fund, and a new Board of Directors was ushered in. Since that time, SDGIF has flourished under new leadership, and all of this was accomplished with no annual budget. Facts and Circumstances Contributing to the Late Filing SDGIF received recognition of its tax-exempt status in 2013. Since formation, it has always filed its Form 990 on time. In 2013, right after receiving its determination letter, Dee Anne Wyse served as bookkeeper, which was essentially a volunteer position. Her responsibilities also included the preparation of the annual Form 990. Ms. Wyse was a well-known community leader looking for a meaningful way to contribute to the community when she volunteered with SDGIF. As the years passed, Ms. Wyse took on more and more operational duties in addition to keeping the books and preparing the Form 990. With her background in operations, Ms. Wyse contributed her valuable skills to the overall operations and fiscal duties of the organization In 2018, the year that the 2017 Form 990 was due, Ms. Wyse found herself overextended with her responsibility to SDGIF. She and the remaining members of the Board were unable to meet, review financials, or bring the directors to a quorum to vote on resolutions. This circumstance was compounded by a turnover in management and by challenges to her own health, causing Ms. Wyse to inadvertently miss the filing deadline of the Form 990. Following is a timeline of relevant events: * 2013 - SDGIF obtains its determination letter and Ms. Wyse joins the organization as volunteer bookkeeper and tax return preparer. * 2015 - The 2014 Form 990 was filed on time. * 2016 - The 2015 Form 990 was filed on time. * 2017 - The 2016 Form 990 was filed on time. * January 2017 - The part-time executive director announces her intent to phase out her involvement with SDGIF. * February 2017 - Five members of the Board of Directors resign. The Board now has only three members. * March 2017 - Four new members are added to the Board of Directors. The Board now has seven members. * April 2017 - The remaining three Board of Directors resign. Leaving the Board with four members that remain today. * May 2017 - Due to the increased responsibilities, the turnover in management, the lack of a CFO, and health challenges, Ms. Wyse inadvertently failed to prepare and file the organization's Form 990 by the May 15th due date and did not think to file an extension. * April 2019 - SDG began the construction of a proprietary online software to manage all donor files, bookkeeping, and related financial documentation. * April 2020 - SDG completed the built out of its proprietary online software with reconciled financial documentation from 2017 and 2018 data secured from the old board of directors. Discovery and Correction of the Late Filing Error Because of the many changes in personnel and shift in responsible party, the organization never received a notice that their annual charity registration form was delinquent. Significant Mitigating Factors As provided in Treasury Regulation 301.6724-1, we believe the following significant mitigating factors are evidence of reasonable cause: * Turnover in management and increased duties for the volunteer who was responsible for meeting the filing deadline created unusual conditions that resulted in the missed deadline. * SDGIF missed the filing deadline, also for the first time, indicating that the circumstances that led to the late filing of Form 990 also affected other filing obligations of the organization. Responsible Actions As provided in Treasury Regulation 301.6724-1, we believe the following are evidence that SDGIF acted responsibly and exercised reasonable care: * The fact that SDGIF normally always filed its tax returns before the due date indicates that SDGIF conducts itself in a responsible manner. * After three years of preparing and filing the organization's Form 990 on time, volunteer Ms. Wyse earned the trust of the management of SDGIF. It was reasonable that SDGIF trusted and relied on Ms. Wyse, given her exemplary record of performance and her contribution to the organization. Ms. Wyse feels bad about her error, but given the totality of the circumstances, both her actions and those of SDGIF are reasonable and responsible. * As soon as the error was discovered, necessary materials were retrieved by the new directors, the return was prepared and filed. Absence of Willful Neglect 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 a factor to consider in determining if abatement of penalties is appropriate. Since SDGIF has an excellent filing history, and since it prepared and filed the 2019 Form 990 within a reasonable period of time given the turnover of management and the new directors inability to find old files, willful neglect is clearly not a factor in the late filing. The absence of willful neglect weighs in favor of the existence of reasonable cause. Preventing Future Delinquencies Management and Ms. Wyse have determined the reasons for the late filing and have requested that the new board of directors take a supervisory role in the monitoring of Form 990 due dates and the meeting of the deadline. The board has agreed to do so, as follows: * The board will educate itself as to the due dates of the Form 990, including the availability of requests for extension of time to file. * The board will actively monitor the due dates of its federal filing obligations and will include discussion of the Form 990 filing on the agenda of the board meetings following the end of the year and before the due date. * The board will direct that the necessary resources be dedicated to the preparation and filing of the Form 990 such that the entire filing responsibility does not rest on a single person, and that new members of the board and management will be apprised of the annual return requirements. * The board or an appointed committee thereof will review the Form 990 before filing and will expect to receive from the preparer proof of timely mailing of the return or proof of timely mailing of a request for extension of time to file when necessary. Proof of timely mailing will be a USPS Certified Mail Receipt, or the equivalent from a private delivery service, or a printed, dated confirmation of electronic filing and acceptance of the return or of the extension by the IRS. Appeal to Fairness Based on the foregoing facts and circumstances, we are appealing to the sense of fairness and purpose as set forth in IRS Policy Statement 20-1 regarding penalty and interest assessments. IRS Policy Statement 20-1, as presented in the Internal Revenue Manual section 1.2.1.12.1, paragraph 1 states that "Penalties are used to enhance voluntary compliance." There can be no question that the 2019 Form 990 was prepared and filed voluntarily when it was discovered that a filing error had been made, and that the intent was and always has been to file on time. Paragraph 5 of IRS Policy Statement 20-1 goes on to say "Abusive transactions, frivolous returns, and other abusive taxpayer conduct undermine the fairness and integrity of the federal tax system and undercut voluntary compliance." In the situation at hand, there have been no abusive transactions, no frivolous returns, and no abusive taxpayer conduct. The filing of a late Form 990 by a normally on-time and fully compliant taxpayer does not in any way endanger or undercut voluntary compliance. Thus, punishing an error resulting from an isolated occurrence of an unintentional oversight does not appear to be in line with IRS Policy Statement 20-1. Request for Abatement of Penalties Based on the organization's demonstration of the existence of significant mitigating factors with respect to the failures, and that it acted responsibly and without willful neglect with respect to its filing obligations, we respectfully request that the IRS abate all assessed penalties and interest assessed against the 2019 Form 990.