The Nonprofit Counsel 1997 Summaries

January 1997

  • Oversight Subcommittee to Look at Exempt Organizations ... Again

  • IRS Issues Favorable Joint Operating Agreement Ruling

  • University Golf Course and the Fragmentation Rule [TAM 9645004]

  • Coming Events: Transformation of a Health Care Institution [PLR 9643039]

  • Certain Voter Registration Efforts Ruled Not Taxable Expenditures -- Part II [PLR 9640021]

  • IRS Allows Pooled Fund Provisions Not in Prototype Document [PLR 9642037]

  • Tax Expenditures Estimates Issued by Joint Committee Staff [JCS-11-96]

  • State Fund-Raising Regulation Report


February 1997

  • Gingrich Case Provides New Perspective on Law of Charities and Politics; Dealing With the "Arcane"?

  • Intermediate Sanctions Return Regulations Issued

  • Charitable Deduction, Substantiation, and Quid Pro Quo Final Regulations Issued

  • IRS Rules on Liquidation of For-Profit Subsidiary Into Exempt Organization [PLR 9645017]

  • Private Foundation Violates Laws; Earns IRS Reprieve [TAM 9646002]

  • State Fund-Raising Regulation Report


March 1997

  • IRS Proposes For-Profit Liquidation Regulations

  • IRS Sets Criteria for Related and Unrelated Travel Tours [TAM 9702004]

  • Use of Low-Cost Articles in Fund-Raising Found to be Unrelated Business [TAM 9652004]

  • Remainder Trust Held Fully Taxable Because of Unrelated Income [Leila G. Newhall Unitrust v. Commissioner]

  • Associate Member Dues Revenue Procedure Modified [Rev. Proc. 97-12]

  • Parade of Legislation

  • State Fund-Raising Regulation Report


April 1997

  • Ways and Means Committee 1997-1998 Oversight Schedule Set

  • Supporting Organizations and For-Profit Subsidiaries

  • Limitation as to Corporate Gifts Held Inapplicable in Case of "S" Corporations [PLR 9703028]

  • Property Improvement Held to be Qualifying Distribution, Another Not [PLR 9702040]

  • IRS Revokes Self-Dealing Ruling [PLR 9703020]

  • Parade of Legislation

  • Structural Tax Reform: Impact on Tax-Exempt Organizations -- Part Three


May 1997

  • Supreme Court Decides That Charitable Bequests Need Not Be Reduced By Administration Expenses Paid From Income [Commissioner v. Estate of Hubert]

  • Intermediate Sanctions Watchers: Study the Adelphi University Case

  • IRS Shifts on Trusts as Income Beneficiaries of Charitable Remainder Trusts [PLR 9710008]

  • Administrative Services by Exempt Organization Held to be Related Activity [TAM 9711002]

  • Parade of Legislation


June 1997

  • Proposed Charitable Remainder Trust Regulations Issued

  • IRS Finalizes Physician Recruitment Ruling [Rev. Rul. 97-21]

  • Charitable Organization With 98-Percent Unrelated Support Remains Exempt [TAM 9711003]

  • Preparatory Time Causes Fund-Raising Event to be Unrelated Business [TAM 9712001]

  • Loss of Exemption by Some Members Held to Not Adversely Affect Group Ruling [TAM 9711004]

  • Proposed Provisions Held to Not Disqualify Charitable Remainder Trusts [PLR 9712031]

  • Parade of Legislation


July 1997

  • Budget Agreement Reached

  • Supreme Court: State Property Tax Exemption Unconstitutional When Nonresident Organizations Not Included [Camps Newfound/Owatonna, Inc. v. Town of Harrison, Maine]

  • IRS Proposes Charitable Remainder Trust Regulations

  • Private Practice Activities Held Converted to Exempt Health Care Functions -- Part I [PLR 9710030]


August 1997

  • House and Senate Pass Tax Bills; Packages Headed for Conference and ...?

  • Summary of the House Bill

  • Summary of the Senate Bill

  • Guide to Provisions

  • The Magic Number: $200 Million


September 1997

  • Taxpayer Relief Act Becomes Law

  • New Charitable Remainder Trust Rules

  • Establishing an Unrelated Business: A Case Study

  • Private Practice Activities Held Converted to Exempt Health Care Functions -- Part II [PLR 9710030]

  • Church in Revocation Case Wins on Discovery Issue [Branch Ministries, Inc. v. Richardson]

  • Final Labor Organization Regulations Issued

  • Commerce Clause Case: A Commentary [Camps Newfound/Owatonna, Inc. v. Town of Harrison, Maine]


October 1997

  • Self-Dealing Taxes Levied for Services Rendered [Madden v. Commissioner]

  • University's Fitness Center Ruled to Include Educational Programs [PLR 9732032]

  • Agricultural Organization's Research Program Services Held to be Permissible [PLR 9732022]

  • Urban Renewal Organization Held Charitable, Despite Failure to Meet Low-Income Housing Guidelines [PLR 9731038]

  • Charitable Deduction Available for Gifts for University-Owned Fraternities Renovation [PLR 9733015]

  • A Look at the Proposed IRS Restructuring and Tax Reform Act


November 1997

  • IRS Issues Proposed Disclosure Rules as to Forms 990, 1023, 1024

  • Foundation's Participation in Disqualified Person Investment Fund Held Not Self-Dealing [PLR 9726006]

  • Postal Service Proposes Rules Concerning Mailing of Premiums

  • The Competition Controversy: This Time the Educational Testing Service


December 1997

  • IRS Restructuring Bill Passes House

  • Laboratory Testing Held Related Business Due to "Unique Circumstances" [PLR 9739043]

  • Associate Member Dues Held Not Taxable [TAM 9742001]

  • Employee Assistance Fund of Exempt Hospital Held Charitable [PLR 9741047]

  • Trust Fails as Supporting Entity Because Income Payout Inadequate [TAM 9730002]

  • Agreement Found to be Only License, So Rental Exclusion Not Available [PLR 9740032]

  • Religious Liberty and Charitable Donations Protection Act Introduced

  • The Competition Controversy: This Time the NCAA

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