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Recent Private Letter Rulings Supporting Organization Disqualified  


Author:  Staff Editors.


Source: Volume 09, Number 02, January/February 2010 , pp.6-6(1)




Family Foundation Advisor

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Abstract: 

In PLR 200946065, the IRS held that a supporting organization was not entitled to exemption under IRC §501(c)(3) and, alternatively, did not qualify as a supporting organization.To qualify as a supporting organization, X would have to meet all three of the following tests: 1. Organizational and operational tests under IRC §509(a)(3)(A). 2. Relationship test under IRC §509(a)(3)(B). 3. Lack of disqualified person control test under IRC §509(a)(3)(C).

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