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The 1984 Nonprofit Counsel Summaries

January 1984

  • SBA: Nonprofits Are Unfairly Competing With Small Business

  • Exempt Organizations: When Can they Be General Partners in Limited Partnerships?

  • Last-Minute Lobbying Against Deduction Tables Fails

  • House Subcommittee Reviews Research Tax Rules

  • Tax Status of Jewish Organizations Challenged [Khalef et al. v. Regan]

  • Tax Court Frustrated Over "Church" Abuse Cases [Miedaner v. Commissioner]

  • IRS Recognizes New Criteria for Exempt Hospitals [Rev. Rul. 83-157]

  • Government Payments Can Enhance or Jeopardize "Public Charity" Status [Rev. Rul. 83-153]

  • IRS Issues Dangerous Ruling [Rev. Rul. 83-166]

  • Ways and Means Committee Explores Revisions of Capital Gains/Losses Treatment

  • IRS Allows Estate Tax Deduction for Gift of Optional Interest in Residence [Rev. Rul. 83-158]

February 1984

  • IRS Hearing Held on New Discount and Income Factors

  • Form 990 Advisory Committee Formed

  • Historic Preservation Council Reports

  • Tax Avoidance Advice Thwarts Exemption [National Association of American Churches v. Commissioner]

  • Gifts of Rights to Services Are Deductible [Rev. Rul. 84-1]

  • 1984: Difficult Year for Tax Changes

  • Cooperative Hospital Service Organization Regs Proposed

  • Ruling Requests Rules Revised [Rev. Proc. 84-1]

  • Two-Tiered Pricing Systems Do Not Preclude Exemption

  • Tax Court: Inurement Can Be Of Gross Earnings As Well As Net [People of God Community v. Commissioner]

March 1984

  • 990 Advisory Board

  • Internal Funds Offer Fund Raising Opportunities [American Bar Association v. United States]

  • UBI Partnership Rules Reaffirmed [Service Bolt and Nut Co. Profit Sharing Trust v. Commissioner]

  • Church-Related Organizations Now Exempt From Filing [Notice 84-2]

  • Expenses of Child's Missionary Work Held Deductible Gifts [White v. United States]

  • Hearing Held on Land Gift Bill

  • IRS Rules That Unrelated Debt-Financed Property Exemption Available for Rented Property [TAM 8246006]

  • Conable to Retire

  • Tax Preferences for "Formal" Educational Institutions

April 1984

  • Tax Bills on Course

  • Fund Raising/Business Ventures Distinctions Outlined [American Bar Endowment v. United States]

  • Private Foundation Regs Issued

  • Interest-Free Loans Held Taxable [Dickman v. Commissioner]

  • Sister's Wages Held Taxable [Samson v. United States]

  • Ministers Housing Allowance Limited [Reed v. Commissioner]

  • No Declaratory Judgment Jurisdiction Where No Final Adverse Determination [AHW Corporation v. Commissioner]

  • UBI Partnership Rule Upheld [Service Bolt and Nut Co. Profit Sharing Trust v. Commissioner]

  • Government Wins "Tax Shelter" Case [Anselmo v. Commissioner]

  • Deduction for Remainder Gift Upheld Despite Election Against Will [First National Bank of Fayetteville, Arkansas v. United States]

May 1984

  • House and Senate Pass Tax Bills, Depart for Easter Recess

  • Church Auxiliary Rules Upheld [Lutheran Social Service of Minnesota v. United States]

  • Expenses of Alumni Association's Travel Tours Held Nondeductible [Rev. Rul. 84-55]

  • Proposed Trust Reformation Rules: A Summary

  • Exempt Organizations in Partnerships: Applicability of Sale-Leaseback Rules

  • House Committee Acts to Expand Tax Revisions

  • Tax Exemption Upheld in Face of Claims of Commerciality and Private Benefits [Alive Fellowship of Harmonious Living v. Commissioner]

  • Change in Annual Accounting Period Is Automatic [IR 84-54]

June 1984

  • IRS Rules Sweepstakes Gifts Deductible

  • Tax Reform Efforts Launched

  • Higher Education Wins Major UBI Cost Allocation Case [Rensselaer Polytechnic Institute v. Commissioner]

  • Final Split-Interest Gift Tables, Regulations Published

  • IRS Concedes Expanded Deduction for Expenses for Charity [Rockefeller v. Commissioner]

  • OMB Issues Guidelines Concerning "Lobbying"

  • Pre-1969 Trust Held Not Foundation But Grandfathered Split-Interest Trust [Hammond v. United States]

  • Final Regulations on Copyrighted Gifts of Art Issued

  • IRS Issues Interest-Free Loan Tables

  • Marital Deduction Regulations Proposed

  • Charitable Deduction Rules May Be Revised

July 1984

  • Tax Legislation Finalized in Conference

  • New Exemption Ruling Procedures Published [Rev. Proc. 84-46]

  • AAFRC Giving Data for 1983 Published

  • 990 Advisory Committee Meets Again

  • Nonsubstantive Amendments Disregarded for 15-Month Rule Purpose, Says IRS [Rev. Proc. 84-47]

  • Status of Regulation Projects

  • Fund Raising and Defamation -- An Update [National Foundation for Cancer Research et al. v. Newsweek, Inc. and Quinn]

  • IRS Rules Volunteers Liable for Tax Penalty [Rev. Rul. 84-83]

  • Estate Owes Interest Despite Total Passage to Charity [Oxford Orphanage, Inc. v. United States]

August 1984

  • Rebuttable Fund Raising Cost Percentage Held Unconstitutional [Secretary of State of Maryland v. Joseph H. Munson Co., Inc.]

  • National Membership Organization Ordered to Admit Women [Roberts, Acting Commissioner, Minnesota, Department of Human Rights v. United States Jaycees]

  • Racial Discrimination Suit Dismissed for Lack of Standing [Allen v. Wright, Regan v. Wright]

  • IRS Liberalizes Inventory Gift Rule

  • Mortmain Law Fails to Defeat Charitable Deduction [Rev. rul. 84-97]

  • IRS Allowed to Allocate Charitable Deduction [Dolese v. Commissioner]

  • Expenses of Child's Missionary Work Held Non-Deductible Gifts [Brinley v. Commissioner]

  • When Are Fund-Raising Costs "High"?

  • Sale-Leaseback Rules/Partnership Problem Rectified

  • Public Cemetery Found Charitable [Mellon Bank v. United States]

  • Forthcoming Hearings

  • Illinois Action Expands Fund-Raising Regulation

September 1984

  • 1984 Act Revises Many Aspects of Exempt Organizations Law

  • Tax Reforms Loom

  • Distinguishing Between Business Expenses and Charitable Gifts [Rev. Rul. 84-110]

  • IRS Proposes Foundation Reporting Rules

  • Transfer of Notes Held Self-Dealing [Gershman v. Commissioner]

  • Tax Court Continues to Find Church Abuses ... [Church of Ethereal Joy v. Commissioner]

  • With D.C. Federal Court Not Far Behind [Freedom Church of Revelation v. United States]

  • "Operating Educational Organization" Defined by Tax Court [Estate of Ethel P. Green v. Commissioner]

  • Excess Business Holdings Guidelines Announced by IRS [Ann. 84-81]

  • New Foundation: Governmental or Private Body?

  • Form Published for Social Security Tax Exemption [Form 8724]

  • Tax Court: Carpet Installation/Fund-Raising Bars Exemption [Self-Realization Brotherhood, Inc. v. Commissioner]

  • Recreational Activities Preclude Exemption for "Bus Ministry" [Retreat in Motion, Inc. v. Commissioner]

  • Tax-Exempts and the ITC

  • Pre-1982 Remainder Trust Annuities Held Ineligible for Marital Deduction [Leach Estate v. Commissioner]

October 1984

  • Success Does Not Mean Loss of Tax Exemption [Presbyterian and Reformed Publishing Co. v. Commissioner]

  • Advertising Income Held Related Revenue [The American College of Physicians v. United States]

  • IRS Issues Temporary Tax Shelter Regulations

  • Doctrine of Election Bars Gift Deduction Limitation Reversal [Grynberg v. Commissioner]

  • Tuition Aid, Legal Services Benefits May Continue

  • "Church By Mail" Refused Exemption [Church By Mail, Inc. v. Commissioner]

  • Slit-Interest Trusts Rules Issues

  • IRS: No Deduction Where Ticket Privileges Received [Rev. Rul. 84-132]

  • Hearing Held on Charitable Deduction Permanence

  • Church of Scientology Exemption Revocation Upheld [Church of Scientology of California v. Commissioner]

November 1984

  • 98th Congress Adjourns, Both Passes and Leaves Tax Legislation

  • IRS Clarifies Gift Deduction Rules for Veterans' Organizations [Rev. Rul. 84-140]

  • More on Church of Scientology Exemption Revocation

  • IRS Revises Application for Recognition of Tax-Exempt Status (Form 1023)

  • Regulatory Miscellany

  • Update on Tax Shelter Rules

  • FASB Fund-Raising Cost Proposal May Be Imminent

December 1984

  • FASB Issues Proposed Joint Costs Guidelines

  • Tax Topics for Donors

  • Church's Medical Aid Plan Held Exempt Function [Bethel Conservative Mennonite Church v. Commissioner]

  • Estate Charitable Deductions Denied Under "Implied Repeal" Doctrine [Estate of Flanigan v. Commissioner]

  • Foundation Held To Not Satisfy Termination Requirements [Gladney v. Commissioner]

  • Gift Annuity Tables Revised

  • Christmas Card Fund Raising Not Taxable [Veterans of Foreign Wars of the U.S., Department of Missouri, Inc. v. United States]

  • Planned Gifts: Which Ones?

  • $322 Billion in Tax Expenditures Tallied

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