In a letter to the Chief of IRS Appeals Office Diane Ryan, attorney Marcus Owens of Caplin & Drysdale criticized the Appeals Office for denying a request to seek Technical Advice regarding whether debt management programs conducted by credit counseling organizations qualify as a charitable activity. The Appeals Office denied the request for Technical Advice because of ample precedent and judicial decisions in favor of the government's decision that such debt management programs are not charitable, but Owens argues that the Appeals Office has failed to provide any such precedence or guidance. Owens also argues that the enactment in 2006 of Internal Revenue Code secion 501(q), which permits debt management program activity, raises a unique question of law that should be examined.
See also 2010 TNT 31-19, February 17, 2010.
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal.
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