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The Law of Tax-Exempt Healthcare Organizations, 3rd Edition by Bruce R. Hopkins, Thomas K. Hyatt

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CHAPTER THIRTY-SIX

IRS Audits of Healthcare Organizations

§ 36.3 IRS IMPLEMENTING GUIDELINES

p. 889, third complete paragraph. Delete last sentence and insert:

These plans are reflected in the agency's almost always annual publications, which used to be termed implementing guidelines and are now termed annual reports, which include work plans.

p. 898. Insert following existing material:

(h) Fiscal Year 2009 Annual Report, Work Plan (New)

The IRS changed its nomenclature with the fiscal year 2009 document, terming it an annual report and including a work plan. The most striking aspect of this report was announcement of a charitable spending initiative, which is a long-range study to learn more about “sources and uses of funds in the charitable sector and their impact on the accomplishment of charitable purposes.” The IRS will look at fundraising, public contributions, grants, and revenues from related and unrelated businesses, types and amounts of direct and indirect unrelated business expenses, compensation of officers, program service activities, and the “effect each has on funds available for charitable spending.” The first stage of this initiative will focus on organizations with “unusual fundraising levels” and organizations that report unrelated ...

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