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Revocations and Rejections

Tuesday, April 15, 2014

Among this week's release of private letter rulings were three rejection letters and two revocations, numbered PLRs 201415003 through 201415007.

TE/GE Again Tweaks Processing of Exemption Applications

Tuesday, April 15, 2014


The Acting Director of EO Rulings and Agreements announced further changes to guidelines for referring applications for 501(c)(3) or (c)(4) status from EO Determinations to EO Technical.

Woodbury: Late Filing Wrecks 6166 Election

Tuesday, April 15, 2014

In Estate of Woodbury v. Commissioner, the Tax Court ruled the election to pay estate tax in installments could not be made on a late filed return, and the prior notice by the estate that it intended to so elect did not substantially comply with the statute or the regulations.

PLR 201415010 - Transactions with Disqualified Person Not Self-Dealing

Monday, April 14, 2014

In PLR 201415010, the Service ruled various transactions between a private operating foundation and its sole contributor would not constitute acts of self-dealing.

PLR 201415009 - Earmarked Contributions Were Deductible

Monday, April 14, 2014

In PLR 201415009, the Service ruled contributions to a land grant university earmarked for activities of youth clubs sponsored by the university were deductible, and the operation of those activities would not jeopardize the university's exempt status.

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