A Judge Is Not a Government Official for Purposes of the Self-Dealing Rules . . . Or Is He?
Author: Marion E. Ringel.
Source: Volume 05, Number 04, May/June 2006 , pp.3-4(2)
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Abstract:
In October 2005, the IRS released a ruling that a district court judge elected by the voters in his district is not a government official for purposes of IRC §4946.Accordingly, the IRS ruled that any payments a private foundation makes to such a judge as compensation for his services would not constitute self-dealing for purposes of IRC §4941. Shortly thereafter in a subsequent private letter ruling released in January 2006, the IRS purported to revoke this ruling.Keywords:
Affiliations:
1: Simpson Thacher & Bartlett LLP.