CPE for FY 1994


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.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 1994. This 1994 series was published in July 1993.

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.


Defining "Church" - The Concept of a Congregation PDF
A discussion of the method used to define "church" under the Internal Revenue Code, focusing on the importance of the concept of a congregation.

Environmental Preservation Issues PDF
Recent developments on the treatment of environmental preservation under IRC 501(c)(3).

Current Issues Affecting Certain Cooperatives and Like Organizations Described under IRC 501(c)(12) PDF
A summary of the requirements for exemption under IRC 501(c)(12), discussion of issues bearing on the 85 percent member-income text, analysis of issues relating to unreasonable accumulation of earnings, and current legislative proposals to amend IRC 501(c)(12).

In-Kind Contributions PDF
A discussion of issues sometimes found in organizations that solicit contributions of property for distribution to individuals needing assistance or to intermediary organizations that assist such individuals.

Income Tax Regulation 301.9100-1 PDF
Application of the relief provision in income tax regulation 301.9100-1 to organizations that do not file timely applications for recognition of exemption.

Social Clubs - IRC 501(c)(7) PDF
Update on social clubs under IRC 501(c)(7), including the amount of nontraditional income that a social club may receive without jeopardizing its exempt status, record keeping requirements, and taxable activities of social clubs.

UBIT: Sale of Land PDF
Unrelated business income tax issues in the sale of land by exempt organizations.

UBIT: Royalty Income and Mailing Lists PDF
A discussion of "affinity" fundraising arrangements between for-profit companies and exempt organizations, focusing on the unrelated business income tax treatment of royalty income and income from the sale, rental, or use of organizations' mailing lists.

Low-Income Housing Update PDF
This discussion focuses on the proposed safe harbor guidelines for low-income housing published in Notice 93-1.

Community Foundations PDF
Tax and non-tax issues, including exemption and public charity status, of community foundations.

Illegality and Public Policy Considerations PDF
The effect of illegality and public policy considerations on tax-exempt status.

IRC 501(c)(15) - The Blitz Since '86 PDF
Issues arising as a result of the liberalization of IRC 501(c)(15) by the Tax Reform Act of 1986.

Integrated Delivery Systems PDF
Exemption issues under IRC 501(c)(3) for corporations created to manage alliances of medical facilities and practitioners that comprise integrated delivery systems.

Corporate Sponsorship Income PDF
Corporate sponsorship income under the unrelated business income tax provisions.

The First Book of Arbitrage - Overview PDF
Arbitrage rules for tax-exempt bonds.