Current News and Developments PLRs, TAMs, and Denial Letters

EO Tax Journal 2011-20

Today is catch-up day. Plus it’s the end of the month, time to clean off my desk. Could it be coincidental that there were no football games this past weekend? (The Pro Bowl — what one wag calls “the most pointless event in all of sports” — doesn’t count.) Tomorrow, unless we have another blast of snow, I’ll start sending out transcripts of the recent meeting of the EO Committee of the ABA’s Tax Section. I’ve already found the first two panels of interest — we even have a feisty Lois Lerner staring down the men. Stay tuned.

1 – Old Business

2 – More Old Business

3 – The Economist on Grassley and ECFA

4 – Another PACI Case?

5 – The Globalization of Philanthropy

6 – Potential Gift Tax Liability for Contributions to 501(c)(4)s

7 – IRS Denies Organization Seeking to Propagate the Genetic Integrity of Horses

Editor's Notebook Focus on Congress

EO Tax Journal 2011-19

1 – Endowment Study Shows 12% Return for FY 2010; Grassley’s Reaction

Senator Grassley continues to ask, are endowment payouts failing today’s students? A NACUBO-Commonfund Study of Endowments gives the latest investment returns.

2 – More on Catholic Hospitals

If religious beliefs trump standards of medical care in a hospital, should the hospital qualify as a hospital under section 501(c)(3) of the Internal Revenue Code for purposes of tax exemption? And does it qualify as a hospital under section 170(b)(1)(A)(iii) of the Code?

Focus on Courts

EO Tax Journal 2011-17

I see one of my jobs as telling readers what not to read. I’d put the Asmark Institute case, released on Monday by the Tax Court, in that category. (Because I know some of you will still want to read it, I’m reprinting it below.) It’s very factual and the result is what I think most of us would expect.

What’s less than satisfying is the sketchy rationale for the court’s decision.

First, let me once again blast the IRS Office of Chief Counsel for not releasing its Tax Court briefs. Since the judge mentions the IRS’ brief in passing, it would be of value to know exactly what the IRS said in its brief. Let me repeat — there is absolutely no reason why the IRS should not be routinely releasing its briefs filed in litigation. Unless a court were to seal all records in a case, there is no bar to the IRS releasing what are public documents.

I suppose I could track down this case in Tax Court — not always immediately available — and pay the court 50 cents a page to copy the IRS brief. Why can’t the IRS simply make an extra copy of all its briefs available to the tax services? I believe the IRS charges the tax services for its PLRs, so it could do the same for its legal briefs if cost is an issue.

Second, lest I forget, the case under consideration. The Tax Court in Asmark Institute cites as precedent B.S.W. Group, Inc., v. Commissioner:

“Under the operational test * * * the critical inquiry is whether * * * [an organization’s] primary purpose for engaging in its * * * activity is an exempt purpose, or whether its primary purpose is the nonexempt one of operating a commercial business producing net profits * * *.”

That appears to be the Tax Court’s rationale in a nutshell. I will just note that section 501(c)(3) does not specifically prohibit “operating a commercial business producing net profits.” While the regulations do allow commercial activities — in recognizing the possible imposition of the unrelated business income tax — business activities may not be the organization’s primary purpose.

Focus on Congress

EO Tax Journal 2011-16

1 – The EOTJ Mailbag

2 – CRS Report on Tax Issues Relating to Charitable Contributions and Organizations

This Congressional Research Service report provides an overview of recent changes affecting tax-exempt and charitable organizations. Experienced EO practitioners probably know of all these developments, but it’s probably worth a scan of the headnotes just to be sure.

Transcripts (Other)

EO Tax Journal 2011-15

1 – Selected IRS Training Materials now on eotaxjournal.com

2 – Transcript of Evangelical Council for Financial Accountability’s Briefing of January 14, 2011
___________________________

1 – Selected IRS Training Materials now on eotaxjournal.com

As part of our efforts to make this website even more useful to subscribers, we recently moved to the website IRS EO training materials for 2008 and 2009 (click “IRS Training Materials” under “Topics”). Below I have listed the EO training materials by modules. These IRS training materials are not available on the IRS website and, short of a lengthy and expensive FOIA request, are not available to EO practitioners.

The items listed under “Examinations CPE Materials” are directed to new revenue agents and hence of limited interest to experienced EO practitioners. Much of the information in these training materials is taken from the Code, Regulations, and Internal Revenue Manual, which you can access on irs. gov. However, practitioners new to the EO field may find these materials more user friendly and helpful in developing an understanding of basic concepts..

Experienced EO practitioners should find of more interest materials listed under “Miscellaneous Topics.” For example, I think anyone with a college or university client currently undergoing or concerned about an IRS audit will find of interest the IRS materials under “Colleges and Universities” since it provides a roadmap of IRS concerns. Similarly if you are involved in a gaming audit.

EO Examinations CPE Materials

A-1   Introduction to EO Audit Techniques (24 pages)
A-2   Tools of the Trade (19 pages)
B-1   Exemption Requirements for § 501(c)(3) (29 pages)
B-2   Prohibitions to Exemption under § 501(c)(3) (42 pages)
C-1   Introduction to Unrelated Trade or Business § 511 (7 pages)
C-2   Unrelated Trade or Business § 513 (38 pages)
C-3   Unrelated Business Taxable Income § 512(a)(1) (54 pages)
C-4   Unrelated Business Taxable Income § 512(a)(3) (39 pages)
C-5   Unrelated Debt-Financed Income § 514 (34 pages)
D-1   Public Charities, Private Foundations, and Private Operating Foundations (15 pages)
D-2   Determining Private Foundation Status § 509(a)(1) and 509(a)(2) (25 pages)
D-3   Supporting Organizations § 509(a)(3) (18 pages)
D-4   Net Investment Income §4940 (16 pages)
D-5   Self-Dealing § 4941 (22 pages)
D-6   Taxes on Failure to Distribute Income § 4942 (13 pages)
D-7   Excess Business Holdings § 4943 (9 pages)
D-8   Investments Which Jeopardize Exempt Purposes § 4944 (7 pages)
D-9   Taxable Expenditures § 4945 (10 pages)
D-10  Intermediate Sanctions § 4958 (77 pages)
D-11  § 4955 Overview (14 pages)
E       Gaming (36 pages)
F-1   Introduction to Exemption Forms and Form 990 (35 pages)
F-2   Reading Form 990 (33 pages)
F-3   Interacting with Taxpayers, Representatives and Return Preparers (10 pages)
F-4   Examination Specialist Support (10 pages)
F-5   Pre-Examination Planning and Appointment Scheduling (17 pages)
G-1   Financial Auditing Techniques (49 pages)
H-1   Evidence (10 pages)
H-2   Touring the Facilities (10 pages)
H-3   Interview Techniques (56 pages)
H-4   Information Sources (31 pages)
H-5   Disclosure (6 pages)
I-3    Statute of Limitations (18 pages)
J-1    Fraud (11 pages)
J-2    Fraud Referral (26 pages)

Miscellaneous Topics

K      Colleges and Universities (112 pages)
L       Current Developments (15 pages)
M      Determination of Fair Market Measurements (39 pages)
N      Return Preparer Penalties (67 pages)
___________________________

2 – Transcript of Evangelical Council for Financial Accountability’s Briefing of January 14, 2011

For background information, go to “Grassley Releases Review of Tax Issues Raised by Media-based Ministries” at finance.senate.gov. For earlier email updates, see 2011-4 and 2011-10. The moderator of the briefing is ECFA’s President, Dan Busby.

Current & Quotable Focus on IRS and Treasury

EO Tax Journal 2011-14

This weekend’s reading focuses on hospitals, but with two very different items. One is a submission by the American Bar Association regarding the application of new requirements imposed on tax-exempt hospitals by section 501(r). Pretty standard stuff. The other item is an article in the Washington Post that discusses medical restrictions imposed by Catholic hospitals.

I’m not aware that anyone has addressed in a law review article whether Catholic hospitals that restrict certain medical practices are not entitled to tax-exempt status based on a public policy argument. While the Post article does not raise this issue, it seems to me to be a lurking issue.

Query: If a hospital wants to be recognized as exempt under sections 501(c)(3) and 170(b)(1)(A)(iii), must it follow accepted medical practices? In the case of Catholic hospitals, can they deny medical care based on religious beliefs and still be exempt? If religious beliefs trump medical considerations, should Catholic hospitals be eligible for Medicare payments and other government benefits, the argument being that they are not following standard medical practices and hence in opposition to public policy?

While I have no answer, I think the issue is one of more than academic interest: Should hospitals have to follow accepted medical practices and standards of care in order to be described as a hospital under section 170(b)(1)(A)(iii)? Should theologians be making medical decisions? Should a Christian Scientist “hospital” that forbids surgical procedures be entitled to exemption? Should a homeopathic hospital be exempt? Should medical care that is being subsidized by the government be subject to restrictions based on scriptural interpretations? If anyone has any answers, I’m all ears.

Focus on IRS and Treasury

EO Tax Journal 2011-13

1 – Comments of Marc Owens on Yesterday’s Outline on EO Employment Tax Issues

2 – Hot Rod Association Getting Some Heat
______________________

1 – Comments of Marc Owens on Yesterday’s Outline on EO Employment Tax Issues

“Paul, it’s useful to put Michael Glass’ comments on the employment tax project in the larger context of the FY 2011 EO Workplan [available at www.irs.gov/eo]. On page 24 of the Workplan, the National Research Program project is described as involving 1500 randomly selected organizations, not returns, with 500 organizations to be examined in each of the three years of the project’s life. This is in contrast to the reporting of EO audit statistics in the IRS’ Databook, which reports numbers based on returns, not entities.

Current & Quotable

EO Tax Journal 2011-12

About a month ago I noted the upcoming January 21 meeting of the EO Committee of the ABA’s Tax Section. While in due course I’ll have transcripts of the six sessions, I’m printing today the outline prepared by one of the IRS speakers, Michael Glass, an EO Group Manager, for those who won’t be in Florida on Friday, and as a canape for those who will. 

Exempt Organizations & Employment Tax Issues

Focus on IRS and Treasury

EO Tax Journal 2011-11

It’s a shame so much bad blood has developed over the running of the Hershey School. Clearly an independent investigation is needed, and it does not appear it can or will happen in Pennsylvania. Alumni of the School would like the IRS to get involved. I doubt if the EO function of the IRS is up to such a daunting task plus a Democratic Administration investigating what seems to involve mostly Republicans in Pennsylvania may lead to a counter-investigation by the House Ways and Means Committee. Now that Senator Grassley has handed off, at least for the time being, his investigation of media-based ministries, I think he would be the ideal person to look into and report on the situation at the Hershey School. His Republican credentials should shield him from charges of partisan bias, and his reputation for being a man of integrity should shield him from charges of a cover-up if he ends up siding with the current trustees of the school.

For earlier reporting, see Email Updates 2010-147, -149, -156, and -157.

Current News and Developments

EO Tax Journal 2011-10

On Friday, the Evangelical Council for Financial Accountability (ECFA) held a briefing on Senator Grassley’s Staff Report and its implications featuring Dan Busby, ECFA President, and Michael Batts, Chair of ECFA’s Commission on Accountability and Policy for Religious Organizations. For information on the Staff Report, see Email Update 2011-4. For information on ECFA and its Commission, see the ECFA website (www.ecfa.org).

The purpose of the briefing was to address issues contained in the Grassley Staff Report that will be considered by the Commission. Each issue was introduced by Busby for comment by Batts.

Editor's Notebook Focus on Courts

EO Tax Journal 2011-7

In regard to Monday’s email update, Theresa Pattara, in her personal capacity, has this to say:

“Paul, I write with the usual disclaimer that I make when I speak publicly, i.e., I am not speaking, or in this case, writing, on behalf of Senator Grassley or his office. But I couldn’t help but write since I got a chuckle out of reading your post on Monday — it made me think of Goldilocks and The Three Bears. I’d put you in the ‘porridge is too cold’ category because you don’t think the Senator went far enough. Of course there are plenty who think the ‘porridge is too hot’ because the Senator shouldn’t be considering these issues at all. It’s the same criticism he received in 2004 when the staff proposals regarding general charity reform were issued and then again when the hospital proposals were issued.

“Many thought that the 2005 report issued by the Panel on the Nonprofit Sector, convened to respond to the 2004 staff proposals, wouldn’t result in anything. Yet, many of the ideas addressed in it — and some that weren’t in the Panel’s report — were included one year later in the Pension Protection Act of 2006. This despite the fact that many thought the provisions, particularly those regarding supporting organizations and donor advised funds, would be removed in conference.

“With respect to hospitals, Senator Grassley had a longer timeframe. He wrote to ten hospital systems in 2005, issued the staff summary of those responses and held a hearing in 2006, issued staff proposals and sponsored a roundtable in 2007, and then negotiated common sense reforms into the 2009 Senate version of the health care bill. Many thought the hospital provisions would similarly be on the chopping block since he ultimately wound up not supporting the larger package.  Yet, the provisions stayed in because both the Catholic Health Association (CHA) and Congress agreed they were common sense reforms. And, unlike other provisions of the healthcare bill, they will not be subject to repeal.

Focus on Courts Focus on IRS and Treasury

EO Tax Journal 2011-6

Today, I’m reprinting the Supreme Court’s decision in Mayo Foundation v. U.S. I’ve always seen the never-ending litigation involving medical residents as an attempt by hospitals to deprive their residents of the benefits and protections of Social Security coverage. Congratulations to Cathy Livingston and her folks for pursuing these cases as well as the attorneys at the Department of Justice.

I’m also reprinting from the National Taxpayer Advocate’s 2010 Annual Report to Congress — Most Serious Problem #8 — “The Failure of the Office of Appeals to Adequately Document Prohibited Ex Parte Communications May Violate Taxpayer Rights and Damage the Public’s Perception of its Independence.”

In the discussion of Most Serious Problem #8, there is an interesting dissertation on the appeals process, which should be of interest to EO practitioners considering same. In addition, there is expressed in the report a rather strong disagreement between the Taxpayer Advocate and the Office of Appeals.

Since we’re talking bureaucratic legalese here, the back-and-forth is not on a par with those late seventies exchanges on SNL between Jane Curtin and Dan Aykroyd (“Jane, you ignorant slut” and “Dan, you pompous ass”), but I wouldn’t be surprised if the two sides weren’t thinking along those lines. To quote the new philosopher king, Rex Ryan, “This is personal.” Here are parts of the report I found amusing:

Editor's Notebook

EO Tax Journal 2011-5

No ‘Hail Mary’ Pass by Grassley to End the Game

Okay, football fans, it’s fourth and 27, with only a few minutes left to play, and your team is behind by five points. Do you punt and hope your team gets the ball back before time runs out or do you throw the ‘Hail Mary’ pass? If Senator Chuck Grassley (R-Iowa) were the coach, I’m guessing he would punt.

On Friday, I had Grassley’s news release on his review of media-based ministries and on his request to the Evangelical Council for Financial Accountability (ECFA) to consider the issues raised by his investigation and to spearhead a discussion about how to address those issues.

Today I’m adding my thoughts as to these developments. I’m assuming folks have reviewed the related materials on the Senate Finance Committee website (www.finance.senate.gov) and the ECFA website (www.ecfa.org). My conclusion is that Grassley has essentially walked away from the results of his investigation after clearly biting off more than he could chew in taking on these media-based ministries. For anyone coming to this party late, the focus of the investigation was on six media-based ministers preaching a gospel of prosperity which, to one such as myself raised as a Roman Catholic, sounds like an effort to turn the biblical Sermon on the Mount on its head. Evidence uncovered by Grassley’s investigation indicates that much of the prosperity generated by this preaching redounded to the personal financial benefit of the preachers.

Focus on Congress

EO Tax Journal 2011-4

Latest Developments re Six Media-based Ministries

In addition to issuing a press release late yesterday (reprinted below), Senator Chuck Grassley (R-Iowa) has announced the formation of a commission to go over the tax policy issues involved in media-based ministries. The commission, to be spearheaded by the Evangelical Council for Financial Accountability (ECFA), will be called the Commission on Accountability and Policy for Religious Organizations.

The commission will be chaired by Michael Batts, founder and managing shareholder of Batts Morrison Wales & Lee, P.A., an Orlando-based CPA firm exclusively serving nonprofit organizations and their affiliates. Dan Busby, the ECFA’s president, will serve on the commission in an ex-officio capacity. The commission will have seven-to-nine members and other members will be named in the coming days.

The ECFA will hold a press conference at 10 a.m. Eastern Standard Time on January 7 at the National Press Club in Washington, D.C. in the Murrow Room. The ECFA will post information about the commission’s work on its website at: www.ECFA.org/commission.

Focus on IRS and Treasury

EO Tax Journal 2011-3

1- Proposal to Limit Retroactive Effect of Revocation

The IRS folks in EO should be happy that they mostly escaped the attention of Nina Olson, the Taxpayer Advocate, last year. Legislative Recommendation #6, reprinted below, appears at pages 391-395 of the National Taxpayer Advocate’s 2010 Annual Report to Congress.

2 – Comments on Bond-Financed Grants

Our friends in the tax-exempt bond community give us one more thing to worry about. For their letter to the IRS, see below.

Current & Quotable

EO Tax Journal 2011-1

Seems appropriate we should be talking about football bowl games this time of year, but first some roster changes for the EO Division.

1 – As 2011 Begins, Lots of Actors in EO Division at the IRS

2 – Playoff PAC Provides IRS with Additional Information on BCS Organizations

3 – Bowl-bound Schools Spend Millions on Football