Organization Alleged to Have Engaged in Listed Transactions Challenges Revocation
Author: Katherine E. David, J.D..
Source: Volume 19, Number 02, January/February 2020 , pp.6-7(2)
< previous article |next article > |return to table of contents
Abstract:
In August 2019, the IRS issued a final adverse determination against National Outreach Foundation, Inc., (NOF) retroactively revoking NOF’s IRC §501(c)(3) status. In November 2019, NOF filed a Tax Court Petition challenging the revocation. This article examines the supporting facts and reasoning behind this important ruling, including “Anatomy of a Listed Transaction: Notice 2004-30” which summarizes the services rules on classifying transactions that have a potential for tax avoidance or evasion (“listed”).Keywords: National Outreach Foundation, Inc.; Tax Avoidance
Affiliations:
1: Clark Hill PLC.