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Section 145 - Qualified 501(c)(3) Bonds

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PLR200313007 (12/17/2002)
This letter is our reply to your request for a ruling that the establishment of a limited partnership and a general partnership by two section 501(c)(3) hospital-related organizations and the use by these partnerships of certain bond-financed property will not cause the bond-financed property to be treated as owned or used by other than a section 501(c)(3) organiation for purposes of sections 145(a) and 141(b).

TAM200107020
Whether the Issuer is eligible for relief under §7805(b) of the Internal Revenue Code (the "Code") from the retroactive revocation of the Organization's exempt status, the effect of which was analyzed in the previous technical advice memorandum in this case issued on October 22, 1999. The Issuer argues that it relied on the determination letter issued to the Organization, its conduit borrower.

TAM200124002
Whether use of the Borrower's Minor League franchise by the Affiliate constitutes private business use under section 141(b)(1) of the Internal Revenue Code?

TAM200006049
This technical advice memorandum presents the following issues concerning the effect of a retroactive revocation of an organization's tax-exempt status under section 501(c)(3) of the Internal Revenue Code on the interest on bonds issued as section 501(c)(3) bonds under 145 for the use of that organization.

PLR199935063 (correction of PLR199931042)
This is in response to a letter from an authorized representative requesting a series of rulings regarding tax consequences associated with the transactions described within.

PLR199931042 (see PLR immediately above)
This is in response to a letter from an authorized representative requesting a series of rulings regarding tax consequences associated with the transactions described within.

TAM199927042
This letter is in reply to a request by Issuer and in further reply to requests for rulings on behalf of multiple "Entities" regarding the effect of proposed affiliation and economic integration agreements on outstanding bonds issued by Issuer.

Page Last Reviewed or Updated: 18-Apr-2014