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Revocations and Rejections

Tuesday, April 28, 2015

Among this week's release of private letter rulings were two rejection letters and ten revocations. These are numbered PLRs 201517008 through 201517017, TAM 201517018, and PLR 201517019.

PLR 201517001 - Late Election Out of Automatic GST Exemption Allocation

Monday, April 27, 2015

In PLR 201517001, the Service exercised its discretion to allow a couple belatedly to elect out of the automatic allocation of GST exemption to a series of transfers to several irrevocable trusts with skip potential.

Six Scholarship Exception Rulings

Monday, April 27, 2015

In each of six rulings, PLRs 201517020 through 201517025, the Service determined a private foundation's grants to individuals would fall within the scholarship exception to the general prohibition against taxable expenditures.

One TAM Rejects, Another Grants Relief from Retroactive Revocation

Monday, April 27, 2015

In two unrelated technical advice memos, TAMs 201517026 and 201517027, the TE/GE Technical office reached different conclusions on whether an organization should be granted relief under Section 7805(b) from retroactive revocation of its exempt status. In one case, the organization withheld material information from its application, while in the other, although the organization operated for a nonexempt purpose, it disclosed relevant facts in its application.

1st Circuit Affirms Kaufman

Monday, April 27, 2015

In Kaufman v. Commissioner, the 1st Circuit federal appeals court affirmed a Tax Court decision imposing a gross valuation misstatement penalty where the value of a facade easement was determined to be zero.

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