Month: November 2015

Current News and Developments Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 2015-230

Paul StreckfusComments Off on EO Tax Journal 2015-230

1 – Editor’s Note

2 – Future Pulitzer Prize Winner? 

3 – IRS Complaint Filed Against GMU Professor Shukla’s Nonprofit For Abuse Of Funds

4 – New IRS Guidance to Simplify ABLE Program Administration

5 – TAM Says Standards for Imposition of Section 4945 Initial (First Tier) Taxes Different from Standards for Penalties and Additional (Second Tier) Taxes; TAM Also Discusses Reliance on Advice of Counsel (TAM 201547007).

Current News and Developments Focus on Courts Focus on IRS and Treasury

EO Tax Journal 2015-227

Paul StreckfusComments Off on EO Tax Journal 2015-227

1 – Quote of the Week

2 – Editor’s Note

3 –  More on GameHearts v. Commissioner

4 – Nonprofit Oversight Under Siege

5 – Private Foundation Updates: Recent Guidance and Investing for Charitable Purposes (Outline)

6 – Deletions From Cumulative List of Organizations, Contributions to Which are Deductible Under Section 170 of the Code

7 – EO Litigation Update

8 – National Society of Accountants: IRS Budget Cuts a Disservice to Taxpayers

Current News and Developments Focus on Courts Focus on IRS and Treasury

EO Tax Journal 2015-226

Paul StreckfusComments Off on EO Tax Journal 2015-226

1 – Screwed Again by the D.C. Bar

2 – In Memory of Rick Cohen

3 –  A Single Substantial Nonexempt Purpose Will Outweigh Other Exempt Purposes (GameHearts v. Commissioner)

4 – Treasury’s Response to Rep Dave Brat’s Letter Seeking Changes to Supporting Organizations Regulations

5 – IRS Seeks Information about Professional Employer Organizations

6 – Clinton Foundation Details Changes in Amended Form 990s

7 – My Latest D.C. Bar Complaint Letter

Focus on Courts

EO Tax Journal 2015-220

Paul StreckfusComments Off on EO Tax Journal 2015-220

1 – Editor’s Note

2 – Supreme Court Won’t Hear CCP Case

3 – District Court Finds that a Charitable Deduction under Code § 642(c)(1) for Donated Real Property Purchased out of Gross Income Should Be Calculated Based on the Property’s Fair Market Value (Green v. U.S.)

4 – Cult Case Ends in Stipulated Opinion (Dr. R.C. Samanta Roy Institute of Science and Technology v. Comm’r)

Editor's Notebook PLRs, TAMs, and Denial Letters

EO Tax Journal 2015-219

Paul StreckfusComments Off on EO Tax Journal 2015-219

1 – Editor’s Notebook

2 – Applicant Formed to Benefit Its Founder and His For-Profit LLC Using His Invention and Patent Denied (c)(3) Exemption (Denial 201545028)

3 – Applicant Promoting Entrepreneurial Children Denied (c)(3) Exemption (Denial 201545029)

4 – Transfer of Remaining Trust Assets from VEBA to Charitable Organizations Will Not Result in UBTI (PLR 201545027)

Current News and Developments Focus on Congress Focus on Courts The EOTJ Mailbag

EO Tax Journal 2015-216

Paul StreckfusComments Off on EO Tax Journal 2015-216

1 – The EOTJ Mailbag

2 – Kevin Brady New Ways and Means Chair

3 – RNC Files Complaint with IRS over Clinton Foundation 990 Reporting

4 – Clinton Foundation Says It Will Now File Amended 990s

5 – Foundations Providing Free Online Courses on PF Law

6 – Revocation Case Involving Significant Alleged Inurement and Private Benefit Now in Tax Court (American Housing Foundation v. Commissioner)

Current News and Developments PLRs, TAMs, and Denial Letters State Tax Developments

EO Tax Journal 2015-215

Paul StreckfusComments Off on EO Tax Journal 2015-215

1 – Schneiderman Announces $700K Settlement with Operator of Clothing Donation Bin Charity Scam

2 – The Charitable Gift Economy Explained

3 – Operation of a Public Market Is Not Substantially Related to (c)(3)’s’s Exempt Purpose and Fees Paid by Vendors Are Not Rents from Real Property (TAM 201544025)