The Internal Revenue Service has released more documents in response to a Freedom of Information Act request from Tax Analysts for training materials used in guidance for the IRS Exempt Organizations determinations office.

Tax Analysts, a nonprofit provider of federal, state and international tax news and analysis, requested the documents in May of last year following the controversy regarding the determinations office's handling of exemption applications from conservative organizations.

Tax Analysts filed suit against the IRS in August, seeking expedited processing of the request. The IRS released roughly 1,000 pages in September, followed by another 1,800 pages in November (see IRS Releases Tax-Exempt Training Materials to Tax Analysts). A judge for the U.S. District Court for the District of Columbia ordered on January 7 that the IRS produce the remaining documents to respond to Tax Analysts' FOIA request by January 15.

The latest materials, which total just under 1,200 pages, include student guides for exempt organizations determinations; learning objectives and course requirements; sample case processing forms for exemption applications; teaching materials and objectives for instruction on section 501(c)(4) organizations; definitions of relevant EO measurement terms such as "solely" and "primarily" and their corresponding activity percentages; and training materials for EO determinations specialists. The documents released on January 15 primarily date from 2009, before the controversial application review policies for the determinations office were in effect.

“Retrieving these documents was a small victory in our continuous and ever-growing fight for transparency,” said Christopher Bergin, president and publisher of Tax Analysts, in a statement. “But it should be noted that what Tax Analysts asked for were training materials, which should be publicly available to begin with. The fact that it took us eight months, a lawsuit and a court order to get the training materials the agency released is not, I believe, a positive sign on how the IRS is dealing with its problems.”