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§ 2.2 Operational Test (a) Charitable Class

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p. 29. Add at end of first full paragraph at top of page:

I highly recommend that readers first study the following IRS private letter ruling to get a full dose of the concepts, citations, and issues that must be considered in working with tax‐exempt organizations. I hope you agree with this approach and will return to reading this private letter ruling in the future to refresh how the IRS reached its conclusion that the entity did not qualify for tax‐exemption. Throughout the discussion of new developments, one can consider how the result could have changed to achieve successful IRS recognition of exemption. Note the organization and its advisors did not contest the negative conclusion.1

Tax Planning and Compliance for Tax-Exempt Organizations

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