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1. Because the income of the Trust derives from the exercise of an essential governmental function and will accrue to a state or a political subdivision thereof, the Trust's income is excludable from gross income under IRC section 115(1).
2. The Trust is classified as a trust within the meaning of section 301.7701-4(a) of the Regulations. Because Trust's income is excludable from gross income under IRC section 115(1) the Trust is not required by IRC section 6012(a)(4) to file an annual income tax return.
Scholarship Expenditures Not Taxable
Change in Org's Activities Leads to Revocation of Exempt Status
Conversion of Charitable Lead Annuity Trust from Non-Grantor to Grantor Trust
Organization's Benefit Plan Is Deemed a Church Plan
Organization's Exemption is Revoked for Failure to Respond to Audit
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