January 2006

• This issue is devoted to a summary of the Tax Relief Act of 2005 (S. 2020), passed by the Senate on November 18, 2005.

February 2006

• IRS Issues FY 2006 Implementing Guidelines

• IRS Rules State District Court Judge Not Government Official for Self-Dealing Law Purposes [PLR 200542037]

• IRS Announces Electronic Filing Waiver Requesr Criteria, Process [Notice 2005-88]

• Court Rules Vision Care Plan Cannot Qualify as Social Welfare Entity [Vision Service Plan v. United States]

• Court Upholds Revocation of Exemption of Gaming Organization [South Community Association v. Commissioner]

• IRS Issues Inflation Adjustments for 2006 [Rev. Proc. 2005-70]

March 2006

• IRS (Finally) Fully Articulates Public Charity/Political Campaign Activity Review Criteria [PLR 200602042]

• IRS Approves Incentive Bonus Program of Public Charity [PLR 200601030]

• ABA Tax Section Comments on Proposed Private Benefit/Intermediate Sanctions Regs

• Finance Committee Chairman Suggests Lesser Role for Compensation Consultants

• Tax Court Declines Jurisdiction in Case Where Organization Was Dilatory in Responding to IRS [National Paralegal Inst. Coalition v. Commissioner]

• Tuition Payments to Religious Schools Held Not Deductible as Charitable Gifts [Sklar v. Commissioner]

• Licensing Agreement Ruled to Entail Nontaxable Royalties [PLR 200601033]

• Catch-Up Corner

April 2006

• Reconciliation of Tax Legislation Proving to be a Struggle [H.R. 4297]

• IRS Issues Report on 2004 Political Campaign Interventions

• Proposals of Interest in Administration's FY 2007 Budget Request

• IRS Rules as to Nontaxable Income Received by For-Profit Subsidiary [PLR 200602039]

• Dissolved Foundation Continues to Exist for Tax Purposes, Terminates in Reorganization Transaction [PLR 200607027]

• IRS Announces 2006 Dirty Dozen [IR-2006-25]

• Charitable Giving Legislation: Petitions and Research

May 2006

• Tax Reconciliation Legislation Conference Nearing End

• IRS Announces Plans to Monitor, Enforce Law as to 2006 Political Campaign Interventions [FS-2006-17]

• Exempt Hospital's Investment in Insurance Company Held to Further Charitable Purposes, Not Generate Unrelated Income [PLR 200606042]

• Private Foundation's Participation in Angel Investment Fund Ruled Program-Related Investment [PLR 200610020]

• Public Charity's Fees for Arranging Pools for Bonds Held Related Business Income [PLR 200611033]

• Waiver of Grazing Permit to Government Held Not Deductible Gift [Bischel v. United States]

• Senator Grassley and Exempt Hospital Reforms

• Court Finds Ostensibly Informal Chief Counsel Advice to be Disclosable Pursuant to IRC, But Protected by FOIA
  [Tax Analysts v. IRS]

• House Passes Political Organizations Contribution Limits Legislation [H.R. 513]

• ABA Tax Section Requests Withdrawal of Anti-Terrorism Guidelines

June 2006

• Organization Operating Abusive Donor-Directed Fund Program Ruled to Not be Tax-Exempt [New Dynamics Foundation v. United States]

• Nonprofit Sector Panel Issues Supplemental Report

• IRS Issues Directive as to Exempt Organizations in Low-Income Housing Ventures

• IRS Defines Gross Receipts for Exempt Insurance Companies [Notice 2006-42]

July 2006

• Tax Reconciliation Legislation, Signed Into Law, Contains Tax Shelter Excise Tax Provision [H.R. 4297]

• Status of Trailer Bill

• IRS Issues Revenue Ruling as to Narrow Tax-Exempt Status for Down Payment Assistance Organizations [Rev. Rul. 2006-27]

• IRS Announces New Steps, Guidance Concerning Credit Counseling Agencies [IR-2006-80]

• Credit Counseling and Down-Payment-Assistance Organizations: Some Thoughts on Fairness

• Senator Grassley and Exempt Hospital Reforms - Part Two

August 2006

• IRS's Lawyers Supplement Guidance as to Tax Exemption for Credit Counseling Organizations, Based on Qualification as Educational Entities [CCAM 200620001).

• IRS Denies Recognition of Exemption for Orgnization Serving Disabled Because of Absence of Charitable Class [PLR 200621025]

• IRS's Lawyers Apply Quid Pro Quo Penalties to Disguised Tuition Payments [CCAM 200623063]

• IRS's Lawyers Opine on Church Audit Rules and Political Activity [CCAM 200623061]

• Court Finds Gift of Conservation Easement Nondeductible [Turner v. Commissioner]

• Hearing on Employment Tax Compliance by Charities Held

September 2006

• Congress Passes Bill With Exempt Organizations, Charitable Giving Revisions [H.R. 4]

• Humiliating IRS and Tax Court, Appellate Court Reverses $70 Million Intermediate Sanctions Decision [Caracci v. Commissioner]

• IRS Issues Request for Comments on Application of Tax Shelter Law [Notice 2006-65]

• Black Lung Trust's Assets Held Not Distributable "Excess" Assets [PNC Bank, N.A. v. PPL Electric Utilities Corp.]

• Tax Court Revisits Reasonable Compensation Case, Finds Smaller Excess [E.J. Harrison & Sons, Inc. v. Commissioner]

• Court Rules That Retroactive Tax Regulation Is Ineffective [Klamath Strategic Investment Fund, LLC v. United States]

• IRS Announces Charitable Giving Statistics [IR-2006-113]

• Charitable Giving Boomed in 2005

October 2006

• Entirety of issue devoted to summary of tax-exempt organizations, charitable giving law changes wrought by Pension Protection Act of 2006 (Pub. L. No. 109-280)).

November 2006

• IRS and Treasury Unveil 2006-2007 Priority Guidance Plan

• Senate Finance Committee Holds Hearing on Community Benefit Standard

• A Look at the New Credit Counseling Organizations Law

• IRS Invokes Private Benefit Doctrine to Deny Tax-Exempt Status [PLR 200635018]

• The New Tax Laws: What's Not to Like

• Trust Held to be Grantor Trust, Not CRUT, Because of Payments [CCAM 200628026]

• Bank Held to Breach Fiduciary Duty as Trustee of CRUT [Fifth Third Bank v. Firstar Bank]

• Because of Benefits and Inurement, Plan Held to Not Qualify as VEBA [PLR 200638027]

December 2006

• IRS Using Triage in Processing Applications for Recognition of Exemption

• IRS Provides Transitional Guidance as to New Appraisal Standards [Notice 2006-96]

• CHA Offers Template as to Community Benefit Standard

• Mobile Home Park's Operations Ruled Charitable as Providing Affordable Housing to Poor, Distressed [PLR 200642009]

• Ways and Means Tosses Bomb to Higher Education Community

• Treasury Department Updates Anti-Terrorism Guidelines

• New York Times Featured Series on Exceptions, Exemptions for Religious Organizations