§ 7.4 PROVISION OF HOUSING
p. 203. Insert as second paragraph:
Likewise, a nonprofit corporation was formed to purchase, rehabilitate, sell, and lease housing properties. It did not impose restrictions on who may rent these properties, although it advised the IRS that it will give preference to low- and moderate-income families, first-time home buyers, and veterans. All of its income will be derived from “appreciated values received from the sale or rent of rehabilitated properties.” This organization is an “affinity partner” with what apparently is a for-profit company. It presented itself as a “profitable opportunity” for the company, stating it will increase the company's “scope of services” and will assist the company in “marketing of new sales opportunities.” The IRS quite correctly ruled that the organization's programs are not charitable and that it is not serving a charitable class.107.1
§ 7.6 PROMOTION OF HEALTH
(a) Hospital Law in General
p. 208. Insert as first complete paragraph, before heading:
A subsequent report from the IRS to Congress, dated January 28, 2015, offered comparisons among tax-exempt, taxable, and government-owned hospitals.148.1 This report provided information regarding charity care and bad-debt expenses, and contains information about exempt ...