Ezel / IRS Rulings / 200946048

CCA 200946048: Effective date of foundation exemption revocation

Number
200946048
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Revocation of Foundation Exemption
Topics
Tax-exempt organizations
Code sections
§ 501, § 6110
Ruling dated
January 30, 2009
Publicly released
November 13, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This Chief Counsel advice reviews a revised report of examination concerning a foundation's exemption and a scholarship arrangement. The writer states that the report was nearly ready and suggests that the effective date of revocation should be the year in which the organization was shown to have engaged in the scholarship arrangement. The underlying report and the case citations mentioned in the analysis are redacted or not included in the release. The advice is internal review guidance rather than a final determination.

Ruling snapshot

  • Question: What effective date should apply to revocation of the foundation's exemption?
  • Outcome: Advice given
  • Key authorities: IRC § 501

Full text (IRS public release)

ID: CCA-130927-09 Number: 200946048
Release Date: 11/13/2009
Office: -----------------------------
UILC: 501.03-02

From: --------------------------
Sent: January 30, 2009
To: ---------------------
Cc: ----------------------------
Subject: ------RAR (2) (2).doc

-----

Here is the ------ RAR with my changes. --------------------------------------------------------------------------------------
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---------------------. Other than some possible nits and need to add some cites for the cases I mentioned in the analysis, I think the RAR is in good shape and ready to go. I think the effective date of revocation should be the year we are confident that ------ was engaged in the scholarship arrangement.

Thanks very much for your hard work on these RARs. If I can get the actual versions delivered to the client so that I can provide them to --------- I would appreciate it.

Thanks.

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ATTACHMENT: [REDACTED]

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