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9th Cir act of self-dealing amount apply assets benefit capital gain cent Chapter charitable contributions charitable organizations classification Commissioner computed Congress corporation court December 31 deduction defined in section described in section determined disqualified person donor educational employees excess business holdings excise tax exclusively exempt function exempt organization exempt purpose exempt status exempt under Section foundation manager funds gift gift tax grant gross income income tax interest Internal Revenue Internal Revenue Code Internal Revenue Service investment income lease limited lobbying nonexempt October 9 operating foundation orga organiza organization described organization's paragraph payment period private foundation public charity status regulations religious rent respect S.D. Cal subparagraph subsection supporting organization tax imposed Tax Reform Act tax-exempt status term tion trade or business transaction Treas UBTI United unrelated business activities unrelated business income unrelated trade zation