p. 84. Add after first paragraph:
The IRS emphasized several portions of new § 501(q) in denying exemption to a prospective credit counseling organization. Charging fees that are consistent with market rates for similar counseling by a for-profit entity rather than rates based on the recipient's ability to pay was deemed to evidence operation as a commercial, rather than charitable, business. Another fact leading to denial was that the CEO controlled the organization and the “entire enterprise is carried on in such a manner as to substantially benefit the CEO in her personal capacity.”1
p. 84. Add to footnote 65:
IRS updated its FAQs on Credit Counseling Organizations on November 1, 2011.
*p. 88. Add new bullet:
p. 110. Add after last paragraph in this section:
On June 21, 2012, the Treasury Inspector General for Tax Administration (“TIGTA”) issued a report regarding ...