Transcripts (ABA EO Committee)

EO Tax Journal 2010-175

Last week I sent out the EO Subject Matter Directory (Email Update 2010-174) and, before that, the EO Division roster (Email Update 2010-171). In response, I got this missive from an IRS employee:

“Don’t cite my name (just call me T), but your information is outdated. Several of the individuals listed are managers and do not answer questions and others no longer work in EO.”

My response: The roster information is based on a listing of EO Division personnel dated September 7, 2010, sent to me by the IRS in response to a FOIA request. If managers do not answer questions, this is a new development. Unfortunately, my efforts this year to get information from Rob Choi about how the IRS handles practitioner phone calls has been met with overwhelming silence. As far as I can tell, there is no policy. Some folks return phone calls, some don’t. I say call and hope for the best.

Today I’m sending out phone numbers of EO field personnel. Here I’ll agree with T that some percentage of the information is outdated. Getting information out of the IRS about personnel in Determinations and Examinations is very difficult. My choice is to publish nothing or publish what I have. Here I believe something is better than nothing, but don’t expect 100% accuracy — maybe 80% accuracy is what I have.

Transcripts (ABA EO Committee)

EO Tax Journal 2010-174

Even though the IRS won’t confirm whether or how it will respond to phone calls, the EO Subject Matter Directory is a valuable resource, but those of us who have worked at the IRS know that some practitioners abuse the opportunities presented. Here are six rules of the road that everyone should abide by. Observing these rules might make the IRS folks more willing to return phone calls:

One, don’t call if you haven’t done your homework. It is not the IRS’ job to explain the basic intricacies of a Code section and the accompanying regulations.

Two, don’t expect to get definitive answers. If you’re lucky, someone at the IRS will make suggestions as to how you might proceed or warn you off certain approaches.

Three, do not later tell revenue agents someone at the IRS National Office has approved a course of conduct or a transaction during a telephone call. If you need a ruling, spend the $10,000.

Four, do not shop around among tax law specialists for a better opinion. The folks at the IRS usually become aware of someone going down their phone list.

Five, limit your phone calls. Calling more than once a month is probably too much.

Six, don’t push your weight around if you are a big shot as this often backfires either immediately or in the long run.

Current & Quotable Editor's Notebook

EO Tax Journal 2010-173

1 – More on EO Compliance

2 – Some of This Stuff You Just Can’t Make Up — They Oughta Make a Movie

The St. Petersburg Times should get a Pulitzer Prize for its continuing investigation of the U.S. Navy Veterans Association. It’s really an unbelievable story — maybe not on a par with Bernie Madoff, but close, and the chutzpah — out of this world.

Editor's Notebook Transcripts (Other)

EO Tax Journal 2010-172

1 – More on EO Compliance

2 – Report from the Director, EO Examinations

We’ve been discussing or learning about EO audits in these pages recently. We had Peter Lorenzetti’s remarks (Email Update 2010-161), Ann Batlle and Marc Owens’ remarks (Email Update 2010-163), and this week’s discussion (Email Updates 2010-170 and 171), with more commentary today.

With all of this, it seems very appropriate that we should hear from Nan Downing, Director of EO Examinations. Her November 18 remarks at the Western Conference on Tax-Exempt Organizations are reprinted below. If you have suggestions for her, I’m sure she’d be glad to hear from you at nanette.m.downing2@irs.gov.

I think we all have the same objective in these discussions. We all want an EO sector that we can be proud of, one where good guys thrive and bad guys are sent packing, one where charitable beneficiaries come first, one where those who are mission-directed are encouraged and those who are selfishly-directed are discouraged. Did I miss anything?

Editor's Notebook

EO Tax Journal 2010-171

1 – More on EO Compliance

2 – IRS Phone Numbers

Over the next few days, I will be sending out more IRS phone numbers and email addresses, but today I’m resending the EO Division roster that I emailed on October 20. I neglected to add email addresses to go with the phone numbers, so consider this a correction. I’ve also added EO Division Counsel who are located in Washington.

Editor's Notebook

EO Tax Journal 2010-170

The following sentences appeared in an article I reprinted yesterday from the Philanthropy Journal, a publication of the Institute for Nonprofits at N.C. State University:

“Most of the sector cooperates willingly with the IRS in its efforts to ensure nonprofits are complying with federal regulations, [Lois Lerner] says, while a handful are confused about how to comply and an even smaller number have ‘bad intentions.’

“‘The nonprofit sector wants to do the right thing, and if they know what to do they will do it,’ she says. ‘The combination of greater transparency, governance and accountability are absolutely necessary.’ And with the new Form 990, and the oversight role of a handful of watchdog agencies, nonprofits have been doing a better job of ‘self-regulating,’ which could prevent further regulation by lawmakers at the federal level.”

Sparkle Plenty had this reaction to Lois’ remarks:

“It may be the case (though this is debatable) that MOST organizations cooperate willingly. However, plenty of organizations ask their lawyers and CPAs who they are consulting on EO tax mandates, ‘what do I need to do to stay below the radar screen?’, which translates to ‘how much of this crap can I ignore’? Regardless, there can be no debate that way more than a handful (or is that the hand of ‘he’s got the whole world in his hands’?) are indeed confused. With no precedential guidance on tons of things — what is UBIT-reachable, what is ‘electioneering’, what comprises ‘private benefit’?  — the c3 sector (and plenty of advisors) have no choice but to be confounded….”

I will add Gary Snyder, editor of Nonprofit Imperative (www.garysnyder.com), as another who probably suspects Lois’ rosy scenario may be too rosy. His newsletter is dedicated to “exposing the crisis in nonprofit fraud leadership … a crisis of pervasive and monumental waste, fraud, abuse, mismanagement, and malfeasance throughout the charitable sector which costs taxpayers and contributors tens of billions of dollars annually.”

My take: So who is right? Was it Don Rumsfeld who said we don’t know what we don’t know? That may be the case here. On what does Lois base her rosy scenario? Has the IRS done a project on compliance in the EO sector? How has Lois divined that “an even smaller number have ‘bad intentions’?” Perhaps we need a new question on the Form 990, “Does the organization (and its managers) have bad intentions, or is the organization just confused?”

I vaguely recall the IRS once reporting on which types of organizations they had audited in a given fiscal year, what areas of noncompliance were discovered, and the number of organizations in each category: (c)(3)s, (c)(4)s, (c)(5)s, etc. I’m not aware of the IRS releasing a report of this nature in recent years. If this is true, why not? A reader recently asked me how many private foundations had been audited in the last few years. I said I had no idea, although we both agreed zero might be a good guess. I assume Nan Downing, Director of EO Examinations, has reports on her desk telling her which types of organizations are being audited, what the issues being uncovered are, and the number of each type of organization being audited. Unless I have somehow missed these reports, why aren’t they being released to the public? No names, just data.
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Current & Quotable

EO Tax Journal 2010-169

Over the years I have suggested to the IRS that they keep the tax press informed of speaking engagements of their top tax officials. Since the answer has always been no-can-do, we in the tax press are forced to troll the internet. When an organization lands a big fish from the IRS to speak at one of their gatherings, they usually put it on their website, and that information then ends up on the internet.

Checking the internet this past weekend I came up with a summary of Lois Lerner’s recent remarks in North Carolina, reprinted herein. I also came up with a fun article on Lois in her alumni magazine. It’s a couple of years old, but it gives us new insights into Lois’ “meteoric rise to the top levels of the federal government.” (The author of the article may have been a little star-struck.) I’m just sorry I’m not able to reproduce all the photos of Lois — and to think she once told me she was camera shy!

1 – Lois Lerner: No More Business As Usual

2 – EO Director Has Reached ‘Rock Star Status’ with the IRS

Current & Quotable Current News and Developments

EO Tax Journal 2010-168

I’ll begin the week by surveying the latest news for those of you who have been away traveling with President Obama.

1 – Not Another Cat Story

This story should give all cat lovers a warm feeling.

2 – The Chronicle of Higher Education’s Annual Salary Report

The New York Times and Washington Post — and I’m sure numerous other newspapers — weigh in on the The Chronicle of Higher Education’s latest salary report.

3 – Who Needs To Be a College President to Make Big Bucks?

The Baltimore Sun continues to do eye-opening exposes. Has anyone ever seen a Maryland state charity regulator? I haven’t, and I’ve lived in the state my entire life. The article notes that Maryland has a law that governs the composition of boards at nonprofits that receive public mental health funds, which says that no one can serve on the board of such an organization if an “immediate family member” works for that organization. I think that’s a great rule that should apply to all section 501(c)(3) public charities nationwide.

Transcripts (ABA EO Committee)

EO Tax Journal 2010-167

Today we have the intricacies of expenditure responsibility. Now if only the U.S. Government practiced expenditure responsibility, we wouldn’t need a national debt commission!

Expenditure Responsibility: Ten Puzzling Practical Problems

What follows are the September 24 remarks of Jerry McCoy, Law Office of Jerry J. McCoy, Washington, and Andrew C. Schulz, Council on Foundations, Arlington, Virginia, as delivered to members of the EO Committee of the ABA’s Tax Section. The moderator of the panel is Robert A. Wexler, Adler & Colvin, San Francisco.

Transcripts (Other)

EO Tax Journal 2010-165

The focus today is on filing requirements — for those who never filed, for those who can’t keep up with the latest Form 990 changes (chiropractic adjustments, rather than major surgery, according to the IRS’ Steve Clarke), and how new section 501(r) affects filing for this year.

1 – Post-October 15 Blues

Unless the IRS has another “Get out of jail free” card up its sleeve, small organizations that missed the October 15 final filing date are now in the soup (but don’t be surprised if Congress later comes to the rescue). For now, Alaska’s Sandy Deja has put together a 41-page ebooklet: Regain Your Tax Exempt Status and Other Options after IRS Automatic Revocation. It’s available atwww.501c3book.com for the low, low price of $8.95.

Contents of Regain Your Tax Exempt Status, by Sandra L. Deja, P.O. Box 10525, Fairbanks, AK 99710:

How To Use This Book
Introduction
Section I – Regain Your Exempt Status – New Application
Chapter 1 – Specific IRS Guidance
Chapter 2 – Re-application Advice
Section II – Regain Your Exempt Status – IRS Revoked In Error
Chapter 3 – No Return Was Required
Chapter 4 – Return Was In Fact Filed
Section III – Information About Group Exemptions
Section IV – Terminate Your Exempt Status
Section V – Do Nothing
Section VI – Links
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2 – Form 990 and Section 501(r) Developments

What follows are the October 12 remarks of Stephen Clarke, EO Project Manager, IRS, and Garrett Gluth, EO Tax Law Specialist, IRS, as delivered at the annual tax program of the American Health Lawyers Association.

Current & Quotable Editor's Notebook

EO Tax Journal 2010-164

1 – Old Business

In regard to critiques of the EO function in these pages in recent days, Tex writes that the IRS folks are starting to remind him of his beloved Dallas Cowboys. Switching analogies, Tex gives the IRS until the end of the year before he says three strikes and you’re out.

Strike One is no FY 2011 workplan: “We haven’t seen one for two years,” he says. Strike Two is no PACI report. Tex notes that the 2008 PACI report is now over a year-and-a-half late. Strike Three is the 7611 regs, proposed in July 2009. “That should have been a two-minute drill,” he says. He wants to know why the IRS can’t make a couple of decisions and be done with this mini-project, especially at a time when some churches are openly challenging the IRS on politicking.

My view: The IRS has about three weeks to accomplish any of these objectives this year. Once December arrives, the IRS pretty much shuts down as people start using their accumulated leave time.

2 – Medical Residents Have Their Day in Supreme Court

Kudos to the New York Times for having the Supreme Court briefs filed in Mayo Foundation for Medical Education and Research, et al. v. U.S. Just go online (www.nytimes.com) to the story below and click on the briefs.

Transcripts (Other)

EO Tax Journal 2010-163

Ann Batlle and Marc Owens discussed IRS audits at the recent ALI-ABA conference, and today I have a transcript of their remarks. Last Thursday (Email Update 2010-161) I had the remarks of Peter Lorenzetti on EO audits from the IRS’ perspective.

Current & Quotable Editor's Notebook Transcripts (Other)

EO Tax Journal 2010-161

Lots of good stuff is piling up on my desk, so I need to catch up over the next few days and my apologies for any delayed responses to incoming emails. Today, because of taping problems, I have abbreviated comments of Peter Lorenzetti, an IRS area manager, who discusses EO examinations. Most of the discussion should be familiar to those of you who are regularly engaged in audits, but he does mention a recent IRS move to a national EO closing agreement coordinator, Lisa Schultz, so that may be new news even for experienced hands. A recent letter from an EO revenue agent to me may add perspective to Peter’s comments. Tomorrow I will be commenting on the state of the EO function, and as homework I recommend, if you have time, reading Pablo Eisenberg’s article, “State and Federal Regulators Must Do More to Police Nonprofits,” that appears in the current issue (Nov. 4) of The Chronicle of Philanthropy.

I’m also including today an article from the Christian Science Monitor, “Advocacy Groups Won’t Get Supreme Court’s Ear on Campaign Finance,” that has been getting attention. If you can stand one more article on campaign finance, it’s recommended reading.

Transcripts (ABA EO Committee)

EO Tax Journal 2010-159

A lot of fans of the Washington Redskins are going to be grumpy today, with the wheels coming off the bus after a loss that had been already counted as a win when the weekend began. I’m sure the Republicans aren’t expecting any such result tomorrow. To mark election day, I’m sending along the transcript of the recent ABA panel on the implications of Citizens United on exempt organizations. 

Citizens United: Implications of Corporate Political Free Speech for the EO Sector

What follows are the September 24 remarks of Greg Colvin, Adler & Colvin, San Francisco, Beth Kingsley, Harmon Curran Spielberg & Eisenberg, Washington, and Holly Schadler, Lichtman Trister & Ross, Washington, as delivered to members of the EO Committee of the ABA’s Tax Section. The moderator of the panel is Rosemary E. Fei, Adler & Colvin, San Francisco.