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Revocations and Rejections

Tuesday, September 2, 2014

Among this week's release of private letter rulings was one revocation, PLR 201435015.

Four More Rulings Approve Modification of pre-Chapter 14 Trust

Tuesday, September 2, 2014

In four identical rulings, PLRs 201435007 through 201435010, Service approved the proposed modification of a trust holding the proceeds of the sale of real property in which a couple and their six children had acquired life and remainder interests prior to the enactment of the "special valuation rules" of Section 2702.

No Excess Holdings or UBTI from Bequest of LLC Units to Foundation

Tuesday, September 2, 2014

In PLR 201435017, the Service determined a bequest to a private non-operating foundation of membership interests in a limited liability company that owned buildings and land in an office park would not result in excess business holdings or unrelated business income.

PLR 201435016 - Foundation to Foundation Transfer

Tuesday, September 2, 2014

In PLR 201435016, the Service ruled favorably on the proposed transfer by a private nonoperating foundation of most of its assets to a related private operating foundation, and the balance of its assets to a public charity both foundations supported.

Judicial Watch Says Lerner e-Mails Recoverable

Friday, August 29, 2014


Judicial Watch claimed government lawyers privately acknowledged "missing" e-mails to and from former EO Director Lois Lerner could be recovered from various backup systems, but said the effort would be "too onerous."

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