CPE for FY 1992


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

Listed below is a series of articles published as the Exempt Organizations Continuing Professional Education (CPE) Technical Instruction Program for Fiscal Year 1992. The 1992 series of articles were published in August 1991.

These materials were designed specifically for training purposes only. Under no circumstances should the contents of these articles be used or cited as authority for setting or sustaining a technical position.

The freely available Adobe Acrobat Reader software is required to view, print and search these files.


Update on Churches Examinations under IRC 7611PDF
A step-by-step review of the church inquiry and examination process, including developments since 1985.

Unrelated Business Income AllocationsPDF
Explanation of the rules for allocating expenses between unrelated (taxable) and exempt activities.

Tax Exempt Bond FinancingPDF
Exemption issues arising with respect to the exemption of organizations participating in tax exempt bond financing.

Low-Income Housing as a Charitable ActivityPDF
Exemption under IRC 501(c)(3) for organizations that seek to relieve the poor and distressed by providing housing.

Social Clubs - IRC 501(c)(7)PDF
An explanation of current Service thinking and court decisions concerning the determination of a social club's unrelated business taxable income and treatment of outside revenue and losses.

Abatement and WaiversPDF
A discussion of IRC 4962, IRC 4961, Reg. 301.7611-1 A-14, and Reg. 1.9100-1.

Economic Development Corporations: Charity Through the Back DoorPDF
Exemption of economic development corporations under IRC 5019c)(3), 501(c)(4), and 501(c)(6).

Emergency Funds and Disaster Relief Organizations (Definite Class Problem)PDF
An overview of the definite class problem under IRC 501(c)(3) with respect to emergency funds and disaster relief organizations.

IRC 7701 - General DiscussionPDF
A general discussion of the definitional provisions of IRC 7701.

The Depths of IRC 419 and 419APDF
IRC 419 and 419A limitations on employer deductions to employee welfare benefit plans.

Foreign Activities of Domestic Charities and Foreign CharitiesPDF
A discussion of exemption, charitable contributions deductibility, private foundation, unrelated business tax, withholding tax, and return filing issues. Also, an overview of tax treaties.

Federal Tax Exemption of Prepaid Health Care Plans after IRC 501(m)PDF
An analytical description of the history of prepaid health care plans, an analysis to apply in determining whether IRC 501(m) should influence the plan's qualification for exemption, and the continuing evolution of the health maintenance organization exception under IRC 501(m).