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Private Letter Ruling

Articles related to tax regulations and how they impact taxpayers.

Extension for QTIP Election Granted

January 10, 2025
Decedent executed a revocable trust (Trust). Decedent died and was survived by Spouse. Upon Decedent’s death, the terms of Trust...

Farmer's Market Denied Exemption

January 3, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose is to have a marketplace in which local...

LLC Activities Qualify as Charitable and Educational Under 501(c)(3)

December 27, 2024
Taxpayer is a nonprofit corporation (Taxpayer) under section 501(c)(3) and classified as a public charity under sections 509(a)(1) and 170(b)(1)(A)(vi)...

Amendment to CRUT Terms is Approved

December 20, 2024
A and B executed a trust (Trust) that intended to qualify as a charitable remainder unitrust under Sec. 664(d)(2). The...

Extension for Portability Election Granted

December 13, 2024
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Business Group Denied Tax-Exempt Status

December 6, 2024
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose as a business association is to support local...

Educational Grant Procedures Approved

November 29, 2024
Foundation requested advance approval of its educational grant procedures. The grant program’s purpose is to help support entrepreneurs by providing...

Tax-Exempt Status Denied for Dog Training Group

November 22, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is organized for the training of dogs and...

Reverse QTIP Election Extension Granted

November 15, 2024
Decedent established a revocable trust (Trust) and was survived by Spouse. Under the terms of Decedent’s Trust, the trustee divided...

Cemetery Operator Denied Tax Exemption

November 8, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is organized and operated to provide the sale...

Scholarship Organization Denied Exemption

November 1, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization’s articles of incorporation state that its purpose is to host local...

Portability Election Extension Granted

October 25, 2024
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent's estate (Estate) was not required to file Form...

QTIP Election Extension Granted

October 18, 2024
Decedent executed a revocable trust (Trust). Decedent died and was survived by Spouse. Upon Decedent’s death, the terms of Trust...

Proposed Donation Constitutes Unusual Grant

October 11, 2024
Organization made a written request to recognize a proposed grant from a donor as an unusual grant under Reg. 1.170A-9(f)(6)(ii)...

Scholarship Organization Denied Exemption

October 4, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization’s articles of incorporation state that its purpose is to provide scholarship...

Extension to Allocate GSTT Exemption Granted

September 27, 2024
Grantor established irrevocable trusts for the benefit of Grantor’s children. Trust A and Trust B (Trusts) were funded on the...

Employer-Related Scholarship Procedures Approved

September 20, 2024
Foundation requested advance approval of its employer-related scholarship procedures. The approval is requested to expand an existing scholarship program that...

Class Reunion Organization Denied Exemption

September 13, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization’s articles of incorporation state that its purpose is to plan and...

Portability Election Extension Granted

September 6, 2024
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Employee Activity Group's Exempt Status Denied

August 30, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is organized and operated to bring together employees...