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Abstract: 

Our regular round up of private letter rulings highlights a number of adverse rulings made by the service. A grant-making public charity lost its exempt status when the IRS found that the organization failed to implement the grant-making controls described in its exemption application. In other private letter rulings, the IRS reclassified a private operating foundation as a private non-operating foundation although without affecting its exempt status; an arts-promoting organization denied IRC §501(c)(3) status for private benefit and private inurement; two revocations for private foundations deemed to have fraudulently diverted charitable contributions to satisfy personal debts; and a ruling by the IRS that an organization created to promote and facilitate trade, commerce, tourism, and friendship between two countries essentially operated a networking event for business owners and investors, not a qualifying purpose under IRC §501(c)(3).

Keywords: Form 990-PF; IRC §6001; Trade, Commerce, and Cultural Exchange

Affiliations:  1: Strasburger & Price, LLP.