Nonprofit Groups Call for Repeal of UBIT on Fringe Benefits
Nonprofit Groups Call for Repeal of UBIT on Fringe Benefits
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2019-16365
- Tax Analysts Electronic Citation2019 TNT 82-412019 EOR 5-83
- Magazine CitationThe Exempt Organization Tax Review, May. 2019, p. 40083 Exempt Org. Tax Rev. 400 (2019)
April 15, 2019
The Honorable Richard Neal, Chairman
U.S. House Committee on Ways & Means
1102 Longworth House Office Building
Washington, D.C. 20515
The Honorable Kevin Brady, Ranking Member
U.S. House Committee on Ways & Means
1102 Longworth House Office Building
Washington, D.C. 20510
The Honorable Chuck Grassley, Chairman
U.S. Senate Committee on Finance
219 Dirksen Senate Office Building
Washington, D.C. 20515
The Honorable Ron Wyden, Ranking Member
U.S. Senate Committee on Finance
219 Dirksen Senate Office Building
Washington, D.C. 20510
Re: Unrelated Business Income Tax on Qualified Transportation Fringe Benefits in Section 512(a)(7)
Dear Chairmen Neal and Grassley, and Ranking Members Brady and Wyden:
Tax-exempt organizations have limited resources to devote to their missions and need your immediate leadership to provide relief from a significant new tax burden created by the 2017 Tax Cuts and Jobs Act (TCJA). Without your swift action, these tax-exempt entities upon which Americans rely will be forced to divert their time and resources away from their missions to calculate and then pay the new 21-percent unrelated business income tax (UBIT) the TCJA imposed on qualified transportation and parking benefits that tax-exempt groups provide to their employees. Not only do these organizations now have to pay a hefty tax on these benefits, but they must put a value on the benefit offerings as well, which can be difficult when there is no clearly defined valuation method. Although the IRS issued some interim guidance in late 2018, it is incomplete and raises more questions for tax-exempt organizations that struggle to comply.
Administratively, the new tax is excessively burdensome. This new requirement forces many tax-exempt employers, including churches and other places of worship, to file federal Form 990-T for the first time, irrespective of their engagement in unrelated business activity. Many organizations have already misfiled Form 990-T or missed filing deadlines altogether. A study commissioned by Independent Sector reveals that 156 organizations reporting UBIT for the first time will incur an estimated $200,000 in administrative expenses.1 Those nonprofits responding to the survey also estimated that they will see an average of nearly $12,000 diverted from their mission in order to meet this increased tax and administrative burden. Many large organizations will be forced to divert even larger sums from their missions to pay the new tax while smaller nonprofits are likely to pay more in accounting and legal fees spent trying to interpret and comply with the law than they actually pay in taxes.
To be clear, subjecting the tax-exempt sector to UBIT on transportation and parking benefits has and will continue to divert funds otherwise designated for valuable mission-related services.
Additionally, many localities require tax-exempts of a certain size to provide transportation fringe benefits to employees, meaning many organizations are subject to the tax simply for complying to local mandates. Moreover, several states couple their state laws to federal law, thus exposing churches and charities to additional tax liability. As noted above, time is of the essence, because many tax-exempt organizations must compute and make tax payments on or before April 15.
For these reasons, the undersigned organizations urge you to take action immediately to fully repeal this undue and burdensome UBIT on tax-exempts. Thank you for your attention to this critical matter. We look forward to working with you to support the productive, dynamic and mission-driven tax-exempt sector. If you have questions, please contact Mary Kate Cunningham, CAE, Vice President of Public Policy for the American Society for Association Executives (mcunningham@asaecenter.org).
CC:
The Honorable Nancy Pelosi, Speaker
U.S. House of Representatives
1236 Longworth House Office Building
Washington, D.C. 20515
The Honorable Kevin McCarthy, Leader
U.S. House of Representatives
2468 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Mitch McConnell, Leader
U.S. Senate
317 Russell Senate Office Building
Washington, D.C. 20510
The Honorable Chuck Schumer, Leader
U.S. Senate
322 Hart Senate Office Building
Washington, D.C. 20515
Signers
Alabama
Alabama Council of Association Executives
Alaska
The Foraker Group
Arizona
Alliance of Arizona Nonprofits
Caritas Law Group, PC
EMPACT — Suicide Prevention Center
Make Way for Books
Southwest Cable Communications Association
The Extra Credit Show
Arkansas
Partners Against Trafficking Humans California
A Better Way
Association Management Services, Inc.
California Association for Research in Astronomy
California Association of Nonprofits
California Disability Services Association
CalSAE
Diving Equipment and Marketing Association
Family Service Agency of the Central Coast
Firelight Foundation
House Ear Institute
Jewish Family Service of Los Angeles
Los Angeles County Bar Association
Project Apis m.
Raizes Collective
The Ralph M. Parsons Foundation
The San Francisco Foundation
Colorado
Black Ops Rescue
Caring for Colorado Foundation
Children's Hospital Colorado Foundation
Children's Museum of Denver at Marsico Campus
Colo Society of Association Executives
Colorado Association of Funders
Colorado Association of Local Public Health Officials
Colorado Nonprofit Association
Cottonwood Institute
Family Tree, Inc.
Gateway Prayer Garden
Kavod Senior Life
Lincoln Hills Cares
Liver Health Connection
Memorial Hospital Foundation
River Deep Foundation
Safehouse Progressive Alliance for Nonviolence
Severe Weather Shelter Network
Shadhika Project Inc.
The Adoption Exchange, Inc.
Weld Food Bank
Connecticut
Easterseals of Oak Hill
CT Community Nonprofit Alliance
The Jackson Laboratory
Mental Health Connecticut
MHC Homes
The Prentice Foundation
YWCA Hartford Region
Delaware
Delaware Alliance for Nonprofit Advancement
Delaware Community Foundation
Easterseals Delaware & Maryland's Eastern Shore
Philanthropy Delaware
United Way of Delaware
District of Columbia
Airports Council International — North America
American Association of Orthopaedic Surgeons
American Farm Bureau Federation
American Network of Community Options & Resources (ANCOR)
American Society of Association Executives
American Society of Civil Engineers
Assn of Direct Response Fundraising Counsel
Association of Christian Schools International
Building Owners and Managers Association International
Coalition of Religious Communicators Associations
Consumer Healthcare Products Association
Council for Christian Colleges and Universities
Council on Foundations
Dance/USA
Easterseals DC MD VA
Entertainment Software Association (ESA)
Eye Bank Association of America
Faith & Giving Coalition
Girl Scouts of the USA
Independent Sector
Linguistic Society of America
National Association of College and University Business Officers
National Consumer Voice for Quality Long-Term Care
National Council of Nonprofits
National Disability Rights Network
Rape, Abuse & Incest National Network
Senior Executives Association (SEA)
The Nonprofit Alliance
United Philanthropy Forum
United States Catholic Mission Association
World Vision, Inc. (US)
Florida
Aaron Keith Robinson Foundation, Inc
Florida Nonprofit Alliance
Light of the World Charities
Georgia
Georgia Center for Nonprofits
Georgia Society of Association Executives
Habitat for Humanity International
Southeastern Council of Foundations
Hawaii
Aloha United Way
Big Brothers Big Sisters Hawaii
The Caregiver Foundation
Hawai'i Alliance of Nonprofit Organizations
Hawaii Youth Services Network
Historic Hawaii Foundation
Read To Me International Foundation
Idaho
Aid For Friends, Inc.
Boise Philharmonic Orchestra
Concepts in Writing, Inc
Framing Our Community, Inc.
Hospice of Eastern Idaho, Inc
Idaho Nonprofit Center
Idaho Towing Association
Jannus, Inc.
Illinois
American Veterinary Medical Association
Association Forum
CCIM Institute
Central States SER Jobs for Progress
Doris & Victor Day Foundation
Easterseals
Forefront (Illinois)
Friends of the Forest Preserves
Illinois Collaboration on Youth
Institute of Food Technologists
Institute of Real Estate Management
Land of Lincoln Goodwill Industries
NAMA
National Council of Teachers of English (NCTE)
Palatine Township Senior Citizens Council
SERCO
Society of Actuaries
Springfield Area Arts Council
YMCA of the USA
Indiana
Alpha Kappa Psi
Alpha Kappa Psi Educational Foundation
Alpha Kappa Psi Fraternity, Inc
American Alliance of Orthopaedic Executives
Indiana Philanthropy Alliance
Indiana Society of Association Executives
Sojourner Truth House
Iowa
Black Hawk County Gaming Association
Iowa Council of Foundations
RJ McElroy Trust
Siouxland Community Foundation
Kansas
Nonprofit Connect Kentucky
Affordable Energy Corporation
Carnegie Center for Literacy & Learning
Cedar Lake Lodge, Cedar Lake Residences
Family & Children's Place
Hosparus Health
Kentucky Lions Eye Foundation
Kentucky Nonprofit Network
Kentucky Society of Association Executives
KY Society of Association Executives
Lexarts Inc
Louisville Parks Foundation
MAKING A DIFFERENCE NOW (MADN)
Louisiana
Alumni Arts Presents
Baton Rouge Green
Bossier Arts Council
CASA New Orleans
Court 13 Arts
Crescent City Lights Youth Theater
Focus Clubhouse Inc
Giving Tree Counseling Services
Goodwill Industries of North Louisiana
Juniper Table
Louisiana Association of Nonprofit Organizations
Louisiana Association on Compulsive Gambling
Louisiana Partnership for Children and Families
Louisiana Public Health Institute
Louvis Services
R.E.J.O.I.C.E., Inc.
St. Luke's Episcopal Mobile Medical
SWANS, Inc.
Trinity Community Center
WriteEdu Tutoring Service
Youth With A Mission Vision
Maine
Maine Association of Nonprofits
Acadia Center
Bean's Corner Baptist Church
Big Brothers Big Sisters of Southern Maine
Camp Mechuwana
Castine Historical Society
CELL
Child Evangelism Fellowship of Maine
Coastal Opportunities
College Guild
Community Concepts, Inc.
Day One
Farmington Conference Center
Friends of Fort Gorges
Goodwill Northern New England
Harbor House Community Service Center
Healthy Peninsula
Immigrant Legal Advocacy Project
Independence Advocates of Maine
Islesboro Affordable Property
James Place
Knox County Homeless Coalition
Lakes Environmental Association
Maine Council of Churches
Maine Discovery Museum
Maine Equal Justice
Maine Interfaith Power & Light
Maine Public Health Association
Maine Resource Recovery Association
Maine Robotics
Maine Society of Certified Public Accountants
Maine Student Veteran Alliance
MANP Maine Association of Non Profits
Milestone Recovery
Next Step Domestic Violence Project
Northern Maine Development Commission
Owls Head Transportation Museum
Piper Shores
Portland Community Squash
Portland Downtown
Portland Media Center
Portland Public Library
Portland Wheelers
ProsperityME
Rangeley Lakes Heritage Trust
Rockland Main Street, Inc.
Rufus Porter Museum
S.C.I.M.
Schoodic Institute at Acadia National Park
Ski Museum of Maine
Southern Maine Conservation Collaborative
Sweetser
The Genesis Fund
The Grand
The Maine Center for Public Interest Reporting
The Plant Memorial Home
Trainriders Northeast
Waldo Community Action Partners
Waterford Historical Society
Waterford Library Association
Wayfinder Schools
WindowDressers
Maryland
American Association on Intellectual and Developmental Disabilities
American Society of Addiction Medicine
Association of Biomolecular Resource Facilities
Entomological Society of America
Goodwill Industries International, Inc.
Maryland Nonprofits
ONJO FSC CORP
Renal Physicians Association
Senior Dog Sanctuary of Maryland Inc
Shepherds Of Zion Ministries International Church
Side by Side, Inc.
The Haney Company
Massachusetts
Amherst Survival Center
Ascentria Care Alliance
Association for Commuter Transportation
Bay Cove Human Services, Inc.
Boys & Girls Clubs of Boston
Bristol Elder Services, Inc.
Center for Living & Working, Inc.
CENTRO, Inc
Community Action Program Legal Services, Inc. (CAPLAW)
Community Resources for Justice
Delta Projects
Disability Resource Center, Inc.
Easter Seals Massachusetts
GLSEN
Horace Mann Educational Associates
JRI
Kennedy Donovan Center
LifeLinks/The Arc of Greater Lowell
Massachusetts Nonprofit Network
Morgan Memorial Goodwill Industries
NonProfit Data Management, LLC
North Charles Mental Health, Inc.
North Suffolk Mental Health Association, Inc.
Pathlight, Inc.
Philanthropy Massachusetts
Pine Street Inn
Providers' Council (Massachusetts Council of Human Service Providers, Inc.)
Seven Hills Foundation
Tapestry Health Systems
The May Institute, Inc.
The United Arc, Inc.
Venture Community Services
WORK, Inc
Michigan
Amyloidosis Foundation
Ann Arbor Hands-On Museum
Ann Arbor Street Art Fair, Inc.
Artrain, Inc
Catholic Youth Organization for the Archdiocese of Detroit
Council of Michigan Foundations
Creative Many Michigan
Fremont Area Community Foundation
Helping Women Period
HOPE Hospitality and Warming Center, Inc.
Independent Consultant
Jail and Outreach Ministry
Methodist Federation for Social Action
Michigan College Access Network
Michigan Migrant Legal Assistance Project, Inc.
Michigan Nonprofit Association
Neutral Zone
Opportunity Resource Fund
Starr Commonwealth
TechTown
The Arts Alliance, Inc.
The Center For Urban Youth & Family Development
The Henry Ford
United Way for Southeastern Michigan
Minnesota
Associations North
Bush Foundation
LeadingAge Minnesota
Minnesota Council of Nonprofits
Minnesota Council on Foundations
University of St. Thomas
Mississippi
Mississippi Center for Nonprofits Missouri
The Church Alliance
Cornerstones of Care
National Council of the United States Society of St. Vincent de Paul, Inc.
Network for Strong Communities
Nonprofit Connect
Painting Contractors Association
Montana
Bitter Root Cultural Heritage Trust
Florence Crittenton Home and Services
Missoula Hell Gate Elks Lodge #383
Montana Nonprofit Association
The Montana Racial Equity Project
United Way of Missoula County
Women's Opportunity & Resource Development, Inc (WORD)
Nebraska
Concordia University Nebraska
Nonprofit Association of the Midlands
Nevada
New Hope Foundation International New Hampshire
AIDS Response Seacoast
Castle Preservation Society
Center for New Beginnings
City of Lebanon
Easterseals New Hampshire
Eli and Bessie Cohen Camps
Episcopal Church of New Hampshire
Full Circle Consulting
Hypertherm, inc
Jeanine & Company
Journey Song
Nashua Adult Learning Center, Inc
New Hampshire Association for the Blind dba\Future In Sight
New Hampshire Community Loan Fund
NH Center for Nonprofits
Portsmouth Music and Arts Center (PMAC)
Rett's Roost
Riverbend Community Mental Health, Inc.
Seacoast Science Center
Sullivan County Transportation
The Freedom Café
The Music Hall in Portsmouth
The Water Project, Inc.
Transport NH
Upper Valley Transportation Management Association
Waypoint
White Birch Center
YWCA New Hampshire
New Jersey
4CS of Passaic County
Bergen Volunteer Medical Initiative
Catholic Charities, Diocese of Trenton
Center for Non-Profits
Center for Family Services
Children's Aid and Family Services, Inc.
Concerned Persons for Adoption
Collaborative Support Program of New Jersey, Inc.
Community Action Partnership NJ
Community Enterprises Corporation
Cope
Displaced Homemakers Network of NJ, Inc.
Easterseals New Jersey
Edison Greenways Group, Inc.
Fabian Consulting, Inc.
Family Connections, Inc.
Family Promise of Morris County
Holiday Express, Inc
HomeFront
Homes by TLC
LADACIN Network
Lake Hopatcong Foundation
LeadingAge New Jersey
MIA2HOPE International Ministry
Neral & Company, PA
New Jersey Association of Mental Health and Addiction Agencies, Inc.
New Jersey Association on Correction
New Jersey Future
NewBridge Services, Inc.
Palestinian American Community Center
Partners for Women and Justice
Perkins Center for the ARts
Princeton AlumniCorps
Princeton Project 55
Sojihuggles Children's Foundation
Studio Montclair Inc.
The Atlantic Foundation
The Connection for Women & Families
VolunteerConnect
Volunteers in Medicine
Wiss & Company, LLP
Youth Advocate Program
New Mexico
Albuquerque Community Foundation
Community Against Violence (CAV)
Community Foundation of Southern New Mexico
New Mexico Thrives
Taos Community Foundation
New York
4heads Inc.
Action for a Better Community Inc.
Action for Older Persons, Inc.
Adirondack Community Action Programs, Inc.
Allegany County Community Opportunities and Rural Development
Alliance of New York Family Councils
Asian American Arts Alliance
Better Neighborhoods, Inc.
Cabrini of Westchester
CAPTAIN Community Human Services
Cattaraugus Community Action, Inc.
Chautauqua Opportunities, Inc.
Cayuga/Seneca Community Action Agency
Charles Settlement House
Chicken & Egg Pictures
Commission on Economic Opportunity for the Greater Capital Region, Inc.
Community Action of Greene County,Inc.
Community Action of Orleans & Genesee, Inc.
Community Action Partnership for Dutchess County
Community Action Planning Council of Jefferson County, Inc.
Community Action Program for Madison County Inc.
Congregation Beit Simchat Torah
Cortland County Community Action Program, Inc.
CURE Childhood Cancer Association
Da Capo Chamber Players, Inc.
Dancewave
Empire State Society of Association Executives, Inc.
Family Service Society of Yonkers
Film Forum, Inc.
Foundation for The Open Eye, Inc.
Girl Be Heard
GLAAD INC
Health Center Network of New York — HealthEfficient
Heights and Hills, Inc.
Hemophilia Association of New York
Hester Street Collaborative, Inc.
Hoyt Foundation
Hudson River Heritage, Inc.
Hudson Valley Current
League of American Orchestras
Lifespan of Greater Rochester
Lifetime Assistance, Inc.
M-CM Network
MDMHS
Mohawk Valley Community Action Agency, Inc.
Mohawk Valley Library System
New York Center for Interpersonal Development, Inc.
New York Council of Nonprofits, Inc. (NYCON)
Niagara Community Action Program, Inc.
Nonprofit Coordinating Committee of New York
Nubian Conservatory of Music
NY Funders Alliance
NYC Veterans Alliance
OPERA America
Opportunities for Otsego, Inc.
Orthodox Union
PAMAR Pan American Musical Art Research Inc.
PathStone Corporation
Planned Parenthood of Central and Western NY
Plant Powered Metro New York
Pro Action of Steuben and Yates, Inc.
Queens Sickle Cell Advocacy Network.Inc
Regional Economic Community Action Program, Inc. (RECAP)
Rensselaer County Historical Society
RIMS — The Risk Management Society
Rural Health Network of SCNY
Saratoga County Economic Opportunity Council, Inc. (EOC)
Savvy Ladies
Schoharie River Center, Inc.
St. Ann's Corner of Harm Reduction, Inc.
St. Joseph's Neighborhood Center
The Community Place of Greater Rochester
The New York Academy of Medicine
The Richards Library
The Strong National Museum of Play
The Webster Apartments
Theatre Communications Group
Tioga County Rural Ministry, Inc.
Tompkins Community Action, Inc.
Ulster County Community Action Committee, Inc.
Voices of Ascension Chorus & Orchestra
Volunteer Legal Services Project of Monroe County
West Fulton Arts, Inc.
Westchester Jewish Community Services
Women's eNews
Zone 126
North Carolina
Arts North Carolina
Artspace
Campion Fund (Phyllis and Mark Leppert Foundation for Fertility Research
Catholic Diocese of Charlotte
Children and Family Services Center, Inc.
Children's Law Center of Central North Carolina
Easterseals UCP North Carolina & Virginia
Hubzone Technology Initiative
Larry King's Clubhouse: Children's Play & Care Center
LIFE Skills Foundation
MPC Certified Public Accountants
North Carolina Center for Nonprofits
North Carolina Justice Center
North Carolina Theatre Conference
Pathways For The Future, Inc.
RAIN
Saint John Neumann Catholic Church — Charlotte
Scotland Community Health Clin
Tryon Riding & Hunt Club
YMCA of Western North Carolina
North Dakota
African Arts Arena (AAA)
Beyond Shelter, Inc.
Bismarck Cancer Center
Central ND Cancer Registry
North Dakota Association of Nonprofit Organizations (NDANO)
PATH North Dakota, Inc.
The Bee and Butterfly Habitat Fund
Ohio
Akron Center for Recovery, Inc.
Esperanza Inc
Heating, Air-conditioning, & Refrigeration Distributors International
Licking County Foundation
New Community Bible Fellowship
Ohio Association of Nonprofit Organizations
Ohio Society of Association Executives
Philanthropy Ohio
Oklahoma
Oklahoma Center for Nonprofits
Oregon
Nonprofit Association of Oregon
Oregon Society of Association Management
Portland Youth Philharmonic
Pennsylvania
Alleghenies Unlimited Care Providers
Association of Independent Colleges and Universities of Pennsylvania
Bell Socialization Services, Inc.
Center for Advocacy for the Rights and Interests of the Elderly (CARIE)
Centre Safe
Children's Aid Society, SOPA District COB
COBYS Family Services
Easterseals Eastern PA
Ohev Shalom Synagogue
Pennsylvania Association of Nonprofit Organizations
PHMC
Pressley Ridge
Society of Cable Telecommunications Engineers
Spigel Consulting
Special People in Northeast, Inc. (SPIN)
Women for Sobriety, Inc.
Women's Resource Center
Youth ADVOCATE Programs
Rhode Island
RICARES: Rhode Island Communities for Addiction Recovery Efforts
Seven Hills Rhode Island
South Carolina
Children's Trust of SC
South Carolina Society of Association Executives
Together SC
United Way of the Midlands
South Dakota
South Dakota Community Foundation Tennessee
College and University Professional Association for Human Resources
Community Foundation of Cleveland and Bradley County
Family & Children's Service
Momentum Nonprofit Partners
Texas
ACH Child and Family Services
American Heart Association
American Payroll Association
Philanthropy Southwest
Restaurant Facility Management Association
Texas Council of Administrators of Special Education
Texas Society of Association Executives
Utah
Avian Sanctuary And Protection
Canyonlands Field Institute
Eagala
Hero's Journey Content
IJ & Jeanne Wagner Jewish Community Center
The INN Between
Latino Behavioral Health Services
Mentors International
Mundi Project
R. Steven Chambers PLLC
Salt Lake American
Senior Charity Care Foundation
The Family History Guide Association
The Learning Center for Families DBA Root for Kids
Utah Clean Energy
Utah Friends of Basset Hounds
Utah Nonprofits Association
YCC Family Crisis Center
Vermont
Common Good Vermont
Vital Communities
Virginia
After School Association of America
American Alliance of Museums
American Composites Manufacturers Association
American Council of Engineering Companies of VA (ACEC/VA)
ANA Nonprofit Federation
Association of Child Life Professionals
Center for Nonprofit Advancement
Clean Fairfax
Eisenman & Associates, Inc
Evangelical Council for Financial Accountability
GMEC SWVA
Hampton Roads Ecumenical Lodgings & Provisions, In
Hearth, Patio & Barbecue Association (HPBA)
Home School Legal Defense Association
Keeney Group, Inc.
Meals on Wheels America
Northern Virginia Chamber of Commerce
Pet Industry Joint Advisory Council
Society of American Florists
Virginia Forestry Association
Virginia Recreation and Park Society
Virginia Rural Health Association
Virginia Sheriffs' Association, Inc.
Virginia Society of Association Executives
Washington
Days for Girls International
Olympic Peninsula Nonprofit Alliance
Olympic View Community Foundation
Stage West Community Theatre
The Mockingbird Society
Washington Nonprofits
West Virginia
ArtsLink, Inc.
Huntington Museum of Art
Literacy Volunteers of Monongalia and Preston Counties
Mountain Hospice Inc.
MountainHeart Community Services, Inc
West Virginia Nonprofit Association
Wisconsin
Alliance for Strong Families and Communities
AMPED Association Management
Wyoming
Wyoming Nonprofit Network
FOOTNOTES
1How the TCJA's New UBIT Provisions Will Affect Nonprofits: A Tax on Transportation Fringe Benefits and Separate Reporting of Unrelated Business Income Streams, Urban Institute, January 2019. Available at https://independentsector.org/resource/research-on-ubit-provisions-in-2017-tax-cuts-and-jobs-act/
END FOOTNOTES
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2019-16365
- Tax Analysts Electronic Citation2019 TNT 82-412019 EOR 5-83
- Magazine CitationThe Exempt Organization Tax Review, May. 2019, p. 40083 Exempt Org. Tax Rev. 400 (2019)