โ Scribed by Bruce R. Hopkins
No coin nor oath required. For personal study only.
The iRS has wrltten an as-yet unreleastd technical advice memorandum revoking the tax-exempt status, as a charity, of a direct contracting type of health maintenance organization. The IRS has issued proposed regulations relating to the effect of certain administrative expenses on the valuation of property that qualifies for the estate tax marital or charitable deduction (REG- 114663-97). The IRS has held that a graduate school can provide administrative services to a group of colleges without engaging in an unrelated business (Priv. Ltr. Rul. 9849027). The IRS has also ruled that it is not an unrelated business for a supporting organization, operating for the benefit of a university that is part of a medical center, to manage a computer system for a partnership of affiliated physicians (who are the faculty of the hospital in the center) and to operate a motel to provide temporary residential facilities for patients and their families and friends (Tech. Adv. Mem. 9847002). Due to space limitations in this issue, these and other developments will be discussed in next month's issue.
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