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An Exempt Status Sorting Hat.pdf

Schmalbeck-An-Exempt-Status-Sorting-Hat-21-NYUJLegis-603.pdf

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📊 Size: 39 KB

📄 Pages: 5 pages

⬇️ Downloads: 86

Summary

Professor Lloyd Mayer's description of § 501(c)(4) as a "catchall" category is accurate, and he concludes that its catchall nature may be problematic in cases where organizations use it to escape restrictions associated with alternative classifications. The ambiguity in categorizing organizations under § 501(c) creates difficulties for organizations, the IRS, and courts. The current approach, where organizations choose their own category, opens up opportunities for abuse. An alternative approach would be for the IRS to review applications and decide on the most appropriate category, similar to a "sorting hat" concept, where the IRS determines the correct category for an organization, rather than allowing the organization to choose. This approach has some precedent, such as the IRS's regulation for § 501(c)(10), which excludes certain organizations from qualifying under that category, even if they meet the eligibility requirements.

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Description

Professor Lloyd Mayer's description of § 501(c)(4) as a "catchall" category is accurate, and he concludes that its catchall nature may be problematic in cases...

Technical Information

File Format: PDF
File Size: 39 KB
Pages: 5
Language: EN
Total Downloads: 86
Last Updated: 13 hours ago

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