Listed below is a series of articles published as the Exempt Organizations Continuing Professional Education (CPE) Technical Instruction Program for Fiscal Year 1984. The series of articles was published in January 1984. These materials were designed specifically for training purposes only. Under no circumstances should the contents of these articles be used or cited as authority for setting or sustaining a technical position. The freely available Adobe Acrobat Reader software is required to view, print and search these files. Developments Relating to Churches PDF A discussion of exempt organization tax law developments that occurred during 1983 which affected churches. Update on Private Schools and the Impact of Bob Jones University v. U.S. PDF A review of the Supreme Court's decision in the Bob Jones University case, and its impact on the Service's administration of tax exemption provisions with respect to discrimination in other contexts. Health Care Organizations PDF Update of prior articles on health care organizations, focusing on current developments, medical office buildings (partnerships), and unrelated business income of hospitals. Litigation by IRC 501(c)(3) Organizations PDF Discussion of exemption under IRC 501(c)(3) for organizations that engage in litigation, including legal aid organizations, human and civil rights defense organizations, public interest law firms, and organizations that attempt to achieve charitable goals through the institution of litigation as plaintiffs. Contributions Deductibility and Related Matters of Importance for Exempt Organizations Specialists PDF A discussion of important rules relating to the deduction of contributions made to exempt organizations. Selected Problems of Voluntary Employees' Beneficiary Associations (VEBAs) PDF Selected problems of voluntary employees' beneficiary associations, including funding problems, deductibility of employer contributions to VEBAs, discrimination in favor of highly compensated employees, "affiliation" of employers, inurement through inter-VEBA transfer, and the permissibility of benefits provided. Developments in the Social Club Area (IRC 501(c)(7)) PDF A discussion of social club developments. IRC 512 - Regularly Carried On PDF A discussion of the meaning of "regularly carried on", focusing on the decision of the United States Tax Court in the Suffolk County Patrolmen's Benevolent Association, Inc. v. Commissioner case. Incomplete Returns Program PDF Exploring aspects of the incomplete returns program, including an awareness of why the Service is concerned about incomplete returns, legal considerations in development of the program, and the correspondence role of the Service Centers. Instrumentalities - Lessening the Burdens of Government PDF A discussion of the issues under IRC 501(c)(3) and other sections of the Code. Local Associations of Employees Exempt under IRC 501(c)(4) PDF Requirements for exemption of local associations of employees under IRC 501(c)(4). Private Operating Foundations PDF A discussion of private operating foundations. IRC 4945 - Decentralization of Advance Approval of Grant-Making Programs under IRC 4945(g) PDF A general overview of the statutory and regulatory provisions that apply in determining whether an organization's grant-making program satisfies the requirements of IRC 4945(g), as a guide for processing requests by key district directors. IRC 4942(g)(2) - Set-Asides PDF Requirements for set-asides as qualifying distributions under IRC 4942(g)(2). Developments in the Private Foundation Area PDF A discussion of possible legislative changes, an update of procedures for issuing determination letters with respect to unusual grants, and reconsideration of Rev. Rul. 82-223, relating to indemnification of foundation managers by private foundations. Statute of Limitations in Chapter 42 Tax Cases PDF A discussion of the statute of limitations in Chapter 42 tax cases, including procedures for securing consents to extend the statute, required forms, and parties authorized to act for the foundation.
