1 – Hospital Groups Seek Schedule H Reporting on Consolidated Basis
2 – Annual ABA Guidance Wish List
All I can say is, hope springs eternal.
Month: July 2010
EO Tax Journal 2010-107
1 – Lois Lerner Addresses NACUBO
2 – HFMA Weighs In on New Requirements
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1 – Lois Lerner Addresses NACUBO
According to Bloomberg News, the IRS’ Lois Lerner, Director, Exempt Organizations, told the National Association of College and University Business Officers that nonprofit colleges and universities may be failing to report the full extent of their unrelated business taxable income to the Internal Revenue Service.
EO Tax Journal 2010-106
1 – Correction
2 – Thorek Hospital and Medical Center
3 – Quote of the Week
4 – End of the World Postponed to October 15
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EO Tax Journal 2010-105
1 – It’s Back!
The ALI-ABA program on Tax Exempt Charitable Organizations is back, “after a short hiatus,” according to the promotional materials, and scheduled for October 21-22 in Washington, D.C. Co-chairs Joe Lundy and Suzie McDowell have clearly put a lot of effort into putting together an interesting and informative program, but I wonder about the size of the audience, in part because their program is similar to other EO programs currently being offered.
EO Tax Journal 2010-104
1 – More on Old, Old Business
In regard to Monday’s email update in which I belatedly ran Professor Ellen Aprill’s response to earlier comments by CPA Sarah Harlan, Sarah had this to say:
EO Tax Journal 2010-103
The IRS has become an enthusiastic user of questionnaires, so I figured it was time to turn the tables and do a questionnaire on them. All responses will remain confidential unless you indicate that you are willing to have your comments attributed to you. You need not respond to all questions. Please send your responses by July 31 to pstreckfus@aol.com and list subject as “IRS Questionnaire.” Responses will be tallied and summarized for an August report.
EO Tax Journal 2010-102
1 – Old, Old Business
2 – PLR 201028044
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While Gmail has been a great improvement over AOL, I’m still having trouble with what I call Gmail’s stacking. When I send out an email update, I may get five immediate responses, “stacked” on top of the email update that I just sent out. I of course read them. So far so good. But if a sixth response comes in a couple of days later, I have to notice that my “stack” has grown from five to six. Multiply this by numerous email updates and I have stacks all over the place, and not knowing which ones may contain a new response. As I suggested in the past, instead of hitting reply, if you start a new email to me, that will go to the head of the class and have its own separate entry. I know, that’s a pain. I once again give this long-winded explanation because I owe Professor Ellen Aprill of Loyola Law School an apology because I lost in a stack her response to an email update last month, and only recently came across it as I was doing a compilation of email updates for the print issue.
EO Tax Journal 2010-101
Today I’m sending along excerpts of three news items I found of interest, with my comments in CAPS.
1 – Praying or preying for Terri Schiavo
Gary Snyder’s Nonprofit Imperative (gary.r.snyder@gmail.com) had this item in a recent post. Hopefully the IRS has taken note:
EO Tax Journal 2010-100
Record Retention Requirements for Nonprofit Organizations, by Jay Rotz
Mr. Rotz was Assistant Director for the Exempt Organizations Division of the Internal Revenue Service before serving as Tax Manager for George Washington University.
EO Tax Journal 2010-99
I have been joking about the frequent bar quips to end EO Committee meetings, and have even suggested members bring their own doctored water bottles — and now I find this time-honored practice is even favored by royalty:
“The royal family is not without its quirks. When Prince Charles and Camilla, Duchess of Cornwall, came to visit us, they requested glasses of ice before we began a long receiving line. The staff dutifully produced them, and the prince removed a flask from his pocket and added to each a small splash of what I presume was straight gin, so that they might be fortified before the hour or more of shaking hands.”
Excerpt from Spoken from the Heart, by Laura Bush
Good news of two sorts today. One, if you don’t care about section 501(c)(6), you can skip today’s email. Two, if you do care about section 501(c)(6), you should find today’sBluetooth case of interest.
I’ve never considered myself a (c)(6) expert, but I have to wonder why Bluetooth appealed. It seemed to me that the district court had pretty much knocked down all of Bluetooth’s arguments. Of course I’m still wondering why VSP is still litigating. And I guess we shouldn’t be surprised if Free Fertility Foundation also decides to appeal. Maybe a recent comment by a baseball player explains the motivation: “I may strike out a lot but if I connect, it’s a home run.” I suppose hope springs eternal.
EO Tax Journal 2010-98
Today we are completing our transcripts of the May 7 meeting of the EO Committee of the ABA’s Tax Section. I’m including the panelists’ handouts, which greatly add to one’s understanding of the panel’s subject matter.
Bankruptcy and Creditors’ Rights in a Charitable Context
What follows are the May 7 remarks of Douglas M. Mancino, McDermott Will & Emery, Los Angeles, and Linda Manley, Lawyers Alliance of New York, New York, as delivered to members of the EO Committee of the ABA’s Tax Section. The moderator of the panel is Professor Evelyn Brody, Chicago-Kent College of Law, Chicago. Their handouts follow the transcript.
EO Tax Journal 2010-97
1 – Tax Court Decision in Free Fertility Foundation
2 – IRS Provides Information on Treatment of LLC whose Sole Member is a Tax-exempt Public Charity
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EO Tax Journal 2010-96
The New York Times has had two interesting articles in recent days, the second article following an earlier article from the Jewish daily newspaper, Forward. I’m running excerpts of these articles with my comments in CAPS. These articles raise difficult issues under the tax law.
EO Tax Journal 2010-95
1 – Old Business
In regard to last Thursday’s email in regard to Revocation 201025083, I have been informed by the IRS that it has been pulled and replaced with a corrected version. You are to pretend that you never read “Second Chance Foundation” in the earlier version.
EO Tax Journal 2010-94
I know folks are starting to bail out for the 4th of July, so I’ll just leave you with some tidbits to ponder over the long weekend.
One reader sent along these salary figures from a recent article on the University of Texas audit:
Mack Brown, head football coach, $5.1 million
Francisco Cigarroa, chancellor of the University of Texas System, $750,000
Rick Perry, governor, $150,000
My comment: If Mack Brown wins most, if not all, of his football games, his salary will probably be worth it to the University of Texas in terms of generating football revenue and pride in the university. If he doesn’t, he’ll be fired, and someone else will be receiving his $5 million.
Another reader wanted to know whatever happened to the Free Fertility Foundation case. It appears Tax Court Judge Maurice Foley has been sitting on this case since the reply briefs were filed in March 2008 (see EOTJ, vol. 13, no. 2, pp. 116-133, and vol. 13, no. 3, pp. 137-143). Productivity has never been a hallmark of the Tax Court.
Denial 201025078