ISSUE:
The samp_cd code found on most SOI files indicates the organization 'type' and 'size.' Most files also include the subsection code (e.g. e050 on more recent SOI990/EZ files). These two codes may have conflicting values for a handful of records. For example: A cross tab of samp_cd vs subsection code will contain a few records that are non-c3s per samp_cd, but the e050 subsection code indicates otherwise.
FINDINGS:
A sample of these returns indicates that samp_cd is return-specific, and e050 (subsection code) matches the value found in the BMF. In other words, the samp_cd reflects the exemption status that is reported by the organization each year on Form 990, 990-EZ, or 990-PF, while the subsection code is the exemption status that the IRS has on file.
The conflict can occur in several ways. Some organizations in the sample obviously filed the 'wrong' form (e.g. a foundation will file Form 990 instead of 990-PF) and some organizations filed the correct form, but apparently claimed the wrong exemption status (e.g. a 501(c)(4) claims to be a 501(c)(3) on line J of Form 990). Some organizations repeated the error year after year, and some errors occurred once within a 3-4 year timeframe.
Data entry is another possible source of error, however no keypunch errors were found in the sample. Exemption status can change over time, which can also explain conflicts between samp_cd and subsection. An organization may file under the new status before the change is fully processed in BMF, or an organization may change from public charity to private foundation status and file a final Form 990 and initial Form 990-PF return in the same year.