If the Internal Revenue Service receives an application for recognition of tax-exempt status for any organization and the Internal Revenue Service responds to such application with a request for additional information—
(1)
such request shall include a due date for providing such additional information which shall be expressed as a number of days (not less than 30 days) from the date on which such request is sent,
(2)
if no response from the applicant is received by the Internal Revenue Service by such due date, the Internal Revenue Service shall conclude that the applicant has not taken the steps necessary to file for tax-exempt status,
(3)
if a response from the applicant is received by the Internal Revenue Service by such due date, the Internal Revenue Service shall have the same number of days to provide a written substantive response to the applicant’s response as the number of days referred to in paragraph (1), and
(4)
if the Internal Revenue Service fails to provide such written substantive response before the deadline under paragraph (3), the applicant’s application for tax-exempt status shall be deemed to have been approved unless the Internal Revenue Service demonstrates to a court of competent jurisdiction that the organization does not qualify for such status.