|
|
|
|
IRS Private Letter Rulings and Technical Advice Memoranda
FILE-NAME: PLR
COVERAGE: From 1954 through current
FREQUENCY: As received from the agency
UPDATE-SCHEDULE: Within 1 day of publication
CONTENT-SUMMARY:
IRS Private Letter Rulings and Technical Advice Memoranda (PLR file) are written determinations issued by the National Office of the Internal Revenue Service that interpret and apply tax law to a taxpayer's specific set of facts.
Letter Rulings deal with pre-return filing transactions and are issued directly
to individual taxpayers at their request. Technical Advice Memoranda (TAM) deal with refund claims and examination issues after a return has been filed; the request for a TAM is made by a district IRS office, although such a request often follows a taxpayer's suggestion that technical advice be sought.
These written determinations are binding on the IRS in relation to the taxpayer
who requested the ruling.
PUBLISHER:
Internal Revenue Service
SEGMENT-DESCRIP: | CITE | The CITE segment contains the ruling number of the document in the same format as in the Document segment, along with a LEXIS cite. | | | CITE (PLR 8430065) | | | | | DATE | The DATE segment contains the date of the IRS ruling. | | | DATE=3/7/2008 | | | | | EXHIBITS | The EXHIBITS segment contains the text of any exhibit, form or attachment related to the ruling. | | | EXHIBITS (attachment) | | | | | REFER-REPLY-TO | REFER-REPLY-TO contains a code representing a contact reference at the IRS. | | | | | | | | TEXT | The TEXT segment contains the actual text of the ruling. | | | TEXT (exempt status and funding) | | | | | UI-LIST | The UI-LIST segment contains one or more eight digit numbers. The first four refer to the IRS Code Section and the last four represent further breakdowns within the Section. | | | UI-LIST (501.03-01) | | | |
DOC-DESCRIPTION:
Each ruling constitutes a document.
DISPLAY-SEQUENCE:
Documents display according to the private letter ruling number.
USE-TIPS:
To find documents in the PLR file concerning the application of section 83 of
the Internal Revenue Code:
ENTER: section 83 w/5 Internal Revenue Code and date is 1993
LEXSEE:
When you know the official or parallel citation to a case, including the LEXIS
cite, you can view that case from anywhere on the LEXIS service. Simply enter
LEXSEE (or LXE) and the cite. For example:
LXE Private Ruling 9723057
or
LXE PLR 9723057
HIER-LOC:
Area of Law - By Topic/Accounting/Access Directories/Tax Center/Federal/Primary/IRS
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Pensions & Benefits/Find Administrative Materials
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Taxation/Find Federal Administrative Materials
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Taxation/Find Federal Administrative Materials/Agency Decisions
Area of Law - By Topic/Administrative Law/Find Specific Agency Decisions & Materials/Tax - Federal
Area of Law - By Topic/Estates, Gifts & Trusts/Find Statutes, Regulations & Administrative Materials/Administrative Materials & Regulations
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Human Resources/Agency Decisions
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Pensions & Benefits
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Taxation
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Taxation/Agency Decisions
Area of Law - By Topic/Financial Crisis Litigation/Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Find Federal Administrative Materials
Area of Law - By Topic/Financial Crisis Litigation/Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Find Federal Administrative Materials/Agency Decisions
Area of Law - By Topic/Financial Services Industry - Critical Issues/Related Industries View/Estate Gifts & Trusts/Find Statutes, Regulations & Administrative Materials/Find Statutes, Regulations & Administrative Materials/Administrative Materials & Regulations
Area of Law - By Topic/Financial Services Industry - Critical Issues/Related Industries View/Pensions & Benefits/Research and Assess Issues/Find Administrative Materials
Area of Law - By Topic/Human Resources/Find Administrative Materials/Federal/Agency Decisions
Area of Law - By Topic/Pension & Benefits/Find Administrative Materials
Area of Law - By Topic/Taxation/Find Federal Administrative Materials
Area of Law - By Topic/Taxation/Find Federal Administrative Materials/Agency Decisions
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Human Resources/Agency Decisions
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Pensions & Benefits
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Agency Decisions
SAMPLE-DOC:
This document may not be used or cited as precedent. Section 6110(k)(3) of the Internal Revenue Code.
Private Letter Ruling 200810025
PLR 200810025; 2008 PLR LEXIS 4
March 7, 2008
[*1]
SUBJECT MATTER: Charities
SUMMARY:
According to Founders' application for tax-exemption per IRC ? 501(c)(3), Organization was founded for the ostensible purpose of funding a charity that sought to grant wishes of children who had life-threatening diseases. Thereafter, Organization was preliminarily recognized as exempt but was not classified as a private foundation. An IRS inquiry into deductions taken by Founders, however, resulted in a report disallowing those deductions and assessing additional taxes. The government thereafter sought revocation, claiming that Founders had operated Organization for their own personal benefit and that Founders had established Organization for tax avoidance purposes and thus was properly disregarded as a sham. Founders not only agreed with the government that Organization was properly disregarded as a sham but also conceded that the tax deductions claimed by them for all "contributions" to Organization were improper by paying all income taxes relating thereto, including interest. Other objections asserted by them including that the IRS should not have reclassified Organization as a private foundation were not addressed, however, and a final adverse determination letter was issued.
APPLICABLE SECTIONS:
Section 501(c)(3) -- Charities
UI LIST:
UI No. 501.03-01
REFERENCE: Refer Reply To: SE:T:EO:MA:7928
TEXT:
Release Date: 3/7/08
Date: November 13, 20XX
Refer Reply to: SE:T:EO:MA:7928
Certified Mail
ORG:
This is a final adverse determination as to your exempt status under section 501(c)(3) of the Internal Revenue Code (IRC). It is determined that you are no longer recognized as exempt from Federal income tax under IRC section 501(c)(3), effective December 28, 20XX, for the following reason(s):
You are not organized and operated exclusively for exempt purposes specified under IRC section 501(c)(3). More than an insubstantial part of your activities are in furtherance of non-exempt purposes and benefit private interests.
Contributions to your organization are not deductible under IRC section 170.
You are required to file Federal income tax returns on the form indicated above. You should file these returns within 30 days from the date of this letter, unless a request for an extension of time is granted. File the returns in accordance with their instructions, and do not send them to this office. Processing of income tax returns and assessment of any taxes due will not be delayed [*2] because you have filed a petition for declaratory judgment under IRC section 7428.
[REMAINDER OF TEXT OMITTED IN ORDER TO SHORTEN DOCUMENT]
|
|
