Archive for ‘PLRs, TAMs, and Denial Letters’

EO Tax Journal 2017-130

Paul Streckfus, July 6, 2017 at 4:33 am

1 – Editor’s Notebook

2 – Pharma-Funded Charities Being Investigated by IRS

3 – Issuer’s Plan to Cease Status as a Qualified Scholarship Funding Corporation under § 150(d)(2) Will Not Affect Interest Exclusion on Its Bonds under § 103 (PLR 201726001)

4 – Agreement to Make Hospital Facilities Available for Students’ Clinical Practice Experience Will Not Result in Private Business Use under § 141(b) (PLR 201726007) Continue…

EO Tax Journal 2017-126

Paul Streckfus, June 28, 2017 at 4:11 am

1 – Editor’s Notebook

2 – Coalition Supports Free Speech Fairness Act of 2016

3 – RP Golf Can’t Convince 8th Circuit to Reverse Tax Court in Conservation Easement Case

4 – Ruling Addresses Issues in Section 501(c)(12) Cooperative’s Proposed Restructuring (PLR 201725017) Continue…

EO Tax Journal 2017-125

Paul Streckfus, June 27, 2017 at 4:15 am

Donations Made through Matching Donation Programs that Will Be Provided by Private Foundation for Corporation’s Employees Are Not Self-Dealing under Section 4941, Will Be ‘Qualified Distributions’ under Section 4942(g), and Will Not Be ‘Taxable Expenditures’ under Section 4945(d) Continue…

EO Tax Journal 2017-120

Paul Streckfus, June 20, 2017 at 4:58 am

1 – The EOTJ Mailbag

2 The Aspen Institute’s Program on Philanthropy and Social Innovation Hosts Nonprofit Datathon

3 – Correction Made to Earlier PLR to Reflect Need for Expenditure Responsibility (PLR 201724001) Continue…

EO Tax Journal 2017-115

Paul Streckfus, June 13, 2017 at 4:38 am

1 – Editor’s Notebook

2 – Testimony of Cleta Mitchell on DOJ’s Tax Division Attorneys

3Organization’s (c)(3) Status Revoked Because Primary Activity Was Operation of a Gaming Hall and for Paying Above-Market Rent to Gaming Hall Landlord (Revocation 201722029) Continue…