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American Institute of CPA's on
October 1, 1995. The length of the
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From the supplier: IRS Letter Ruling 9526003 declares that interest-free loans to a tax-exempt foundation that yield income due to imputed interest are to be considered property held for investment under IRC section 163(d)(5). The loans involved were found to be gift loans, and the foregone interest was treated as a charitable contribution. The ruling did not address whether this ruling would still hold under the exemption from imputed interest rules for loans of under $250,000.
Citation DetailsTitle: Noninterest-bearing loan to exempt foundation may be characterized as "property held for investment."
Author: Sidney W. Leibowitz
Publication:The Tax Adviser (Magazine/Journal)
Date: October 1, 1995
Publisher: American Institute of CPA's
Volume: 26
Issue: n10
Page: 602(1)
Distributed by Thomson Gale.
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