1 – Editor’s Notebook
2 – Latest Development in College Athletics
3 – Rev. Proc. 2025-28 Provides for Filing-and-Furnishing Extensions for Form 990-T
4 – Can Private Benefit Also Be Public Benefit, or How to Measure?
5 – Denial Letter 202533011
PLRs, TAMs, and Denial Letters
EO Tax Journal 2025-137
1 – Editor’s Notebook
2 – Community Foundation and Corporation Get Single Entity Ruling under Section 1.170A-9(f)(11) (PLR 202533005)
3 – Congress Has Increased the Tax on College and University Endowments: How Should We Think about This Policy Change?
EO Tax Journal 2025-133
1 – In the News
2 – Editor’s Notebook
3 – Applicant Planning Construction and Operation of a Renewable Energy Facility Denied (c)(3) Status (Denial 202531014)
4 – IRS Releases Section 115 Private Letter Ruling (PLR 202532004)
EO Tax Journal 2025-131
1 – Quote of the Week
2 – The EOTJ Mailbag
3 – Open Source Software Denials Continue
4 – OSS Application Denied (Denial 202530014)
EO Tax Journal 2025-130
1 – Editor’s Notebook
2 – Senator Wyden’s Statement on Long’s Ouster from the IRS
3 – Employment Opportunity
4 – Integrated Auxiliary of a Church Not Required to File Form 990 (PLR 202531015)
5 – Latest Development in Family Office Foundation Case
EO Tax Journal 2025-127
1 – Second Quote of the Week
2 – Editor’s Notebook
3 – Campaign Legal Center’s Amicus Brief in NRB Case
4 – Attorney General Pam Bondi Clarifies Guidance on Unlawful Discrimination
EO Tax Journal 2025-126
1 – Quote of the Week
2 – Editor’s Notebook
3 – The EOTJ Mailbag
4 – Likely (c)(4) Denied (c)(3) Status
5 – House Ways and Means Committee Investigating Exempt Organ Procurement Organization
6 – NRB Objects to Campaign Legal Center Entering Case as Amicus
7 – Court Permits Campaign Legal Center, Public Citizen, and Common Cause to File Amicus Brief in NRB Case
EO Tax Journal 2025-116
1 – Quote of the Week
2 – Editor’s Notebook
3 – Recent Denial Letter Lacks Clarity
4 – Text of Denial 202527014
5 – Donor Intent, Restricted Funds & Endowments –
Documentation, Audits & Best Practices (Part 2)
EO Tax Journal 2025-86
1 – How to Reach Us
2 – In the News
3 – The EOTJ Mailbag
4 – Applicant Assisting Small Technology Businesses Denied (c)(3) Status (Denial 202520011)
EO Tax Journal 2025-73
1 – IRS Workforce Reductions and Not Waiting for Long
2 – Upcoming Program
3 – Article of Interest
4 – Latest Work Product Coming Out of EO Division
5 – Group Seeking to Protect Lake Denied (c)(3) Status (Denial 202516007)
________________
EO Tax Journal 2025-62
1 – The EOTJ Mailbag
2 – In the News
3 – The Nonprofit Story of OpenAI (Part 1)
4 – IRS Releases Chief Counsel Advice on Section 4960 (CCA 202515014)
EO Tax Journal 2025-61
1 – In the News
2 – The EOTJ Mailbag
3 – American Alliance for Equal Rights Sues American Bar Association for Racial Discrimination in Scholarship Program
4 – IRS Reviews Church Criteria in Recent Revocation (202514006)
EO Tax Journal 2025-56
1 – Editor’s Notebook
2 – In the News
3 – Attention All Fiscal Sponsorship Aficionados
4 – Applicant Developing a Blockchain Standard for Representing Items as Non-Fungible Tokens (NFTs) Denied (Denial 202514008)
EO Tax Journal 2025-55
1 – The EOTJ Mailbag
2 – Editor’s Notebook
3 – New Sheriff in Town
4 – Public Recommendations Invited on Items To Be Included on the 2025-2026 Priority Guidance Plan (Notice 2025-19)
5 – Applicant Can’t Pay for Founder’s Heart Transplant (Denial 202514005)
EO Tax Journal 2025-48
1 – Editor’s Notebook
2 – Items of Interest
3 – In the News
4 – IRS Approves Grant Procedures under Section 4945(g)(3) (Letter 202512006)
EO Tax Journal 2025-39
1 – Quote of the Week
2 – Amy Coney Barrett’s Message to Donald Trump?
3 – The EOTJ Mailbag
4 – Program of Interest
5 – Editor’s Notebook
6 – Open Source Software Promoter Denied (c)(6) Status (Denial 202507012)
EO Tax Journal 2025-35
1 – Comings and Goings
2 – Editor’s Notebook
3 – In the News
4 – Opinion Writer Contends Trump Is Existential Threat to Nonprofit Sector
5 – Community Association Denied (c)(3) Status (Denial 202508006)
EO Tax Journal 2025-15
1 – In the News
2 – Article of Interest
3 – Editor’s Notebook
4 – IRS Finds Private Benefit, Self-Dealing, and Jeopardizing Investments in Loans and Promissory Notes (CCA 202504014)
EO Tax Journal 2025-4
1 – Program Reminders
2 – The EOTJ Mailbag
3 – Editor’s Notebook
4 – In the News
5 – Focus on IRS (Annual Revenue Procedures)
6 – IRS Rules Activities of Disregarded Entities of Taxpayer Are Charitable and Educational (PLR 202451009)
EO Tax Journal 2024-180
1 – RSM Offering Free EO Webcasts
2 – Wacko EO Case Continues
3 – In the News
4 – Editor’s Notebook
5 – Dog Training Organization Denied (c)(3) Status (Denial 202446014)
EO Tax Journal 2024-177
1 – Editor’s Notebook
2 – Trust’s Income Is Excludable from Gross Income under Section 115(1) (PLR 202445010)
3 – IRS Rules Income Is Excludable from Gross Income under Section 115(1) of the Code (PLR 202445009)
4 – IRS Rules Authority’s Income Is Excludable from Gross Income under Section 115(1) and Is an Instrumentality for Purposes of Section 170(c)(1) (PLR 202443008)
EO Tax Journal 2024-175
1 – The EOTJ Mailbag
2 – In the News
3 – Editor’s Notebook
4 – Applicant Operating a Cemetery Denied (c)(3) Status (Denial 202444012)
5 – Georgia CPA Sentenced in Syndicated Conservation Easement Tax Scheme
EO Tax Journal 2024-170
1 – Editor’s Notebook
2 – Chairman Smith Calls for States to Investigate Nonprofits Engaged in Antisemitic and Illegal Activity, including Supporting Terrorism
3 – Applicant Promoting Physical Fitness Denied (c)(3) Status (PLR 202443019)
EO Tax Journal 2024-168
1 – Editor’s Notebook
2 – In the News
3 – Commentary on DAFs
4 – Excerpt from October 15, 2024 Letter of American Council on Education to House Ways and Means Committee
5 – IRS Rules that a Taxpayer’s Income Is Excludable from Gross Income under Section 115(1) and It Is an Instrumentality for Purposes of Section 170(c)(1) (PLR 202443007)