The Nonprofit Counsel 1993 Summaries

January 1993

  • IRS Issues Proposed College and University Examination Guidelines

  • IRS Finds Mailing List Exchanges to be Unrelated Business Activity [PLR 9250001]

  • A Look at the FEC's Proposed Issue Advocacy Organizations Regulations

  • Treasury Department Issues Option on Tax Restructuring


February 1993

  • IRS Issues Two Pooled Income Fund Rulings on Multi-Charity Funds, Then Promptly Revokes One [Rev. rule. 92-107, 92-108, 93-8]

  • IRS Publishes Annual Reporting Forms

  • IRS Publishes Final Regulations on Nontaxation of Insurance Coverage

  • IRS Issues Proposed Partnership Allocations Regulations

  • IRS Issues Exempt Organization Procedural Rules for 1993

  • The Proposed IRS University Audit Guidelines: Part One

  • Bush Administration Sends Last Budget, Which Contains Tax Expenditures Estimates


March 1993

  • Clinton Administration Serves Up Tax Proposals

  • IRS Issues Proposed Sponsorship Regulations

  • Government Wins HMO Case on Appeal [Geisinger Health Plan v. Commissioner]

  • Treasury Issues Fraternal Society Report, With Views on Commerciality -- Part I

  • Charitable Deduction Denied: "Donor" Did Not Own Gifted Property [Kamilche Company v. United States]

  • Appeals Court Finds For Social Club: Gain on Sale Nontaxable [Atlanta Athletic Club v. Commissioner]

  • Legislation Update


April 1993

  • Tax Bill Taking Shape; Nonprofit Organizations Provisions Emerging

  • Proposed "Federal Program Improvement Act" Contains Tax-Exempt Organizations Provisions

  • Gift Held Deductible, Not Assignment of Income or Part of Step Transaction [Greene v. United States]

  • Income Under Crop-Share Lease Held Nontaxable Rent [Harlan E. Moore Charitable Trust v. United States]

  • Grantor's Powers, Trust Provisions Do Not Defeat Qualification of Remainder Trusts [PLR 9252023]

  • Supporting Organization's For-Profit Subsidiary Will Not Defeat Exemption [PLR 9305026]


May 1993

  • Tax Bill Still Being Written; Tax Talk Dominates Washington

  • Charitable Deduction Allowed Despite Technical Failure in Meeting Substantiation Rules [Bond v. Commissioner]

  • Treasury Issues Fraternal Society Report, With Views on Commerciality -- Part II

  • IRS Ruling Illustrates Use of Charitable Lease by Foundation [PLR 9248030]

  • Crop Lease Arrangement Held to Not Yield Taxable Rent [Trust U/W Emily Oblinger v. Commissioner]

  • Court Determines Charitable Deduction Arising From Estate Settlement [Warren Estate v. Commissioner]

  • Legislation Update


June 1993

  • President Submits Tax Legislation; Bill Headed for House Floor

  • Inventory of Developments


July 1993

  • House Subcommittee Launches Hearings on Public Charities; Focus on Inurement

  • Tax Court Finds Royalties From Rental of Mailing Lists [Sierra Club, Inc. v. Commissioner]

  • Court Finds Private Inurement in Tangle of Organizations and Transactions [Airlie Foundation, Inc. v. United States]

  • Miscellaneous Tax Measures Under Consideration in Subcommittee

  • Treasury Issues Fraternal Society Report, With Views on Commerciality -- Part III

  • Charitable Giving for 1993 Reached $124.3 Billion

  • Parade of Legislation


August 1993

  • Senate Passes Campaign Finance Reform Legislation

  • Estate's Charitable Deduction Cannot Be Increased By Paying Expenses From Income, Court Holds [Burke v. United States]

  • Court Denies Estate Tax Charitable Deduction Because of Representatives' Discretion [Estate of David N. Marine v. Commissioner]


September 1993

  • Tax and Budget Legislation Narrowly Passes Congress, Is Promptly Signed Into Law

  • Oversight Subcommittee Holds Second Hearing on Public Charities

  • Hearings Set on Variety of Tax, Including EO, Bills

  • Parade of Legislation


October 1993

  • Unrelated Business Income Rules Revised by New Tax Law

  • New Tax Legislation: An Inventory

  • Commentary on the August Pickle Hearings

  • Remainder Trust Deduction Allowed, Gift Portion Held Ascertainable [Wells Fargo Bank v. United States]

  • Private Foundation Loses Exemption Because of Inurement [TAM 9335001]

  • A Look at New California Charitable Solicitation Law


November 1993

  • Another Tax Bill in 1993? Probably Not

  • A Look at the Newest Tax-Exempt Health Care Provider: The IDS

  • Church Audit Rules Held Satisfied; IRS Audit of "Church" Permitted [United States v. C.E. Hobbs Foundation for Religious Training and Education]

  • Second-Tier Subsidiary Used to Side-Step Unrelated Business Income Tax [TAM 9338003]

  • The Proposed IRS University Audit Guidelines: Part Two


December 1993

  • Ways and Means Committee Developing Another Tax Bill

  • IRS Issues Favorable Rulings to Scientology Organizations

  • Charitable Deduction to Trust to Promote Patriotism Upheld [Buder v. United States]

  • Charitable Deduction Denied for Lead Trust's Excess Contributions [Rebecca K. Crown Income Charitable Fund v. Commissioner]

  • Still Another Opinion on Charitable Deduction Arising Out of Estate Settlement [Estate of Hubert v. Commissioner]

  • IRS Issues Notice Providing Guidance on 1993 Dues Deductions [Notice 93-55]

  • "Putting A Roof on the Church": Some Thoughts

  • Technology Transfer and Tax Exemption

  • Parade of Legislation

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