2023-10-16T10:33:38-05:00 2022-12-31 BDO USA 200 OTTAWA AVE NW STE 300 GRAND RAPIDS MI 49503 990 2022-01-01 752589033 Allied Pilots Association Welfare Benefits Plan Master Trust % MARCY SCOTT ALLI 8173022147 14600 TRINITY BLVD Suite 500 FORT WORTH TX 761552599 PATRICK CLARK SECRETARY-TREASURER 8173022147 2023-10-10 true PATRICK CLARK 999009999 Jacob Cook P01240455 6167747000 2023-10-10 3 2022 2023-04-26 12:10:37Z ED SICHER 14600 TRINITY BLVD500 FORT WORTH TX 761552599 77175525 false X N/A X 1994 TX PROVISION OF WELFARE BENEFITS TO MEMBERS OF THE ALLIED PILOTS ASSOCIATION AND THEIR DEPENDENTS. 1 1 0 0 0 0 0 0 45075200 24742425 9013007 22510218 0 0 54088207 47252643 0 0 26765464 30300126 115991 122828 0 0 0 4059338 10104042 30940793 40526996 23147414 6725647 221269807 170550178 0 0 221269807 170550178 PROVISION OF WELFARE BENEFITS TO MEMBERS OF THE ALLIED PILOTS ASSOCIATION AND THEIR DEPENDENTS. false false WELFARE BENEFITS FOR ALLIED PILOTS ASSOCIATION MEMBERS ("APA"), DEPENDENTS, AND STAFF THROUGH THE FOLLOWING BENEFIT PLANS: - ALLIED PILOTS ASSOCIATION SURVIVOR BENEFIT PLAN - ALLIED PILOTS ASSOCIATION VOLUNTARY SUPPLEMENTAL MEDICAL AND CUSTODIAL CARE BENEFIT PLAN - ALLIED PILOTS ASSOCIATION PILOT OCCUPATIONAL DISABILITY PLAN - ALLIED PILOTS ASSOCIATION PILOT MUTUAL AID PLAN - ALLIED PILOTS ASSOCIATION RETIREE HEALTH BENEFIT PLAN false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false true false false true 0 0 0 false false false false false false false 1 1 false false false false false false false true true false false true false false false false false false X MARCY SCOTT 8173022147 14600 TRINITY BLVD SUITE 500 FORT WORTH TX 76155 STATE STREET BANK TRUST CO TRUSTEE 1.0 0.0 X 122828 0 0 ED SICHER PRESIDENT 0.0 0.0 X 0 0 0 PATRICK CLARK SECRETARY-TREASURER 0.0 0.0 X 0 0 0 122828 0 0 1 false false false NGS INSURANCE AGENCY INC 508 TWILIGHT TRAIL SUITE 201 RICHARDSON TX 75080 PLAN ADMINISTRATION 6655157 WEB TPA PO BOX 99906 GRAPEVINE TX 760999706 PLAN ADMINISTRATION 1283342 GUARDIAN LIFE INSURANCE PO BOX 981590 EL PASO TX 799981590 PLAN ADMINISTRATION 392451 THE SEGAL COMPANY 901 MOPAC EXPRESSWAY S BLDG 1 STE AUSTIN TX 78746 ACTUARIAL SERVICES 346444 BENEFIT ELECT 855 SW YATES DR SUITE 201 BEND OR 977021090 PLAN ADMINISTRATION 261960 6 0 PARTICIPANT CONTRIBUTIONS 525100 24742425 24742425 24742425 3221893 3221893 0 0 0 0 0 49211207 29922882 19288325 19288325 19288325 0 0 0 0 0 0 0 0 0 0 47252643 24742425 22510218 0 0 0 30300126 122828 0 0 0 0 0 75000 42699 528497 0 0 251658 8679757 0 0 0 0 0 0 0 0 0 0 0 526431 40526996 0 0 12675499 12789544 0 0 315501 346502 0 0 0 0 0 0 0 0 0 0 0 0 208278807 157414132 0 0 0 0 0 0 0 0 221269807 170550178 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 X 221269807 170550178 0 0 0 0 221269807 170550178 221269807 170550178 6725647 -57445276 X false false false FORM 990, PART VI, SECTION B, LINE 11B: A COPY OF THE ORGANIZATION'S FORM 990 IS PROVIDED TO ALL MEMBERS OF ITS GOVERNING BODY BY THE ORGANIZATION'S FORM PREPARER FOR REVIEW. ANY CHANGES NEEDED AND SUGGESTED BY MEMBERS OF THE ORGANIZATION'S GOVERNING BODY ARE MADE PRIOR TO THE FILING OF THE FORM 990. FORM 990, PART VI, SECTION C, LINE 19: GOVERNING DOCUMENTS AND FINANCIAL STATEMENTS ARE AVAILABLE TO PLAN PARTICIPANTS UPON REQUEST AND POSTED ON THE ALLIED PILOTS ASSOCIATION ("APA") WEBSITE. FORM 990 PART IX LINE 11G DESCRIPTION:PLAN ADMINISTRATION TOTAL FEES:8679757 ALLIED PILOTS ASSOCIATION 14600 TRINIITY BLVD SUITE 500 FORT WORTH TX 76155 131982245 LABOR UNION TX 501(C)(5) N/A NA false false false false false false false false false false false false false false false false false false false false October 16, 2023 RE: PENALTY ABATEMENT REQUEST Taxpayer: Allied Pilots Association Welfare Benefits Plan Master Trust EIN: 75-2589033 Tax Form: 990 Tax Period: 2022 To Whom it May Concern: We represent Allied Pilots Association Welfare Benefits Plan Master Trust ("Taxpayer"). For 2022 Form 990, an extension was inadvertently not filed by May 15, 2023. For the reasons stated within, Taxpayer respectfully requests abatement of any assessed penalties. Taxpayer is a 501(c)(9) Voluntary Employees' Beneficiary Association and has been in existence since 1994. Taxpayer provides welfare benefits to members of the Allied Pilots Association, a 501(c)(6) tax-exempt organization, and their dependents. A penalty would cause a financial hardship and harm the members it seeks to provide benefits. The taxpayer's operations would certainly be negatively impacted. Taxpayer has met the reasonable cause standard by demonstrating it exercised ordinary business care and prudence, therefore qualifies for abatement of penalty. Treas. Reg. 301.6652-1(f), Showing of reasonable cause states, "The amount imposed by subsection (a), (b), or (c) of section 6652 shall not apply with respect to a failure to file a statement within the time prescribed if it is established to the satisfaction of the district director or the director of the Internal Revenue Service Center that such failure was due to reasonable cause and not to willful neglect." In addition, IRM 20.1.1.3.2.1 Standards and Authorities cites, "Any reason that establishes a taxpayer exercised ordinary business care and prudence but nevertheless failed to comply with the tax law may be considered for penalty relief." Further, IRM 20.1.1.3.2.2 Ordinary Business Care and Prudence discusses that, "A taxpayer may establish reasonable cause by providing facts and circumstances showing that he or she exercised ordinary business care and prudence (taking that degree of care that a reasonably prudent person would exercise), but nevertheless were unable to comply with the law." The failure to file 2022 Form 990 in a timely manner was due to a miscommunication with the Taxpayer and their new accountants. Taxpayer has consistently engaged a professional tax preparer to file its required federal returns and for 2022 changed to a new tax preparer. During this transition, the Form 990 for this entity was inadvertently not included in the scope of work with all of the other Form 5500 tax filings and financial statement audits. Historically, Taxpayer has timely filed Form 8868 to request a 6-month extension and then filed its Form 990 timely within that extension period. Although an extension was not filed for tax period 2022, we are filing the return by what would have been the extended due date. Taxpayer acted in good faith, as well as in a responsible manner relative to Form 990 by filing the return with the IRS as soon it became aware that the return had not been extended. The late filing was not intentional or due to willful neglect, nor was there any deliberate attempt to disregard the rules and regulations of the filing requirement; it was simply an inadvertent error. It is also important to note that there is no outstanding tax. Further, IRM 20.1.1.2 Purpose of Penalties states, "Penalties exist to encourage voluntary compliance by supporting the standards of behavior required by the Internal Revenue Code. For most taxpayers, voluntary compliance consists of preparing an accurate return, filing it timely, and paying any tax due. Efforts made to fulfill these obligations constitute compliant behavior." Taxpayer made every effort to timely file its return. Taxpayer is historically compliant in its tax obligations, having never been assessed a late penalty and is committed to meeting all tax law requirements. Taxpayer has satisfied the requirement for reasonable cause by confirming it acted in a prudent and reasonable manner and was neither willful nor neglectful. Taxpayer respectfully requests that any penalties assessed by the IRS for the 2022 Form 990 be abated. I am submitting this on behalf of Taxpayer and I have conveyed the facts stated in this correspondence as told to me including any accompanying documents and to the best of my knowledge and belief they are true, correct and complete. Thank you for your consideration. If you require further information, please contact me at 616-802-3493. Respectfully, Jacob Cook