by George G. Jones and Mark A. Luscombe A number of high-profile tax issues attracting the attention of the Internal Revenue Service, the Congress and the media over the last couple of years have involved exempt organizations.

In the IRS’s focus on tax shelters, some of the shelters viewed as abusive have had as a key element the use of an exempt organization in the structure. The IRS has even seen some cases in which the exempt organization was in fact a promoter of the shelter scheme.

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