(From a speech by Howard Shoenfeld, IRS Special assistant for tax exempt organizations)


1 . Organization fails to consider obvious and subtle unrelated business income tax issues.

2. Organization improperly classifies employees as independent contractors.

3. Organization improperly allocated revenue and expenses between activities or among affiliates.

4. Organization fails to report changes in its operations or activities to the IRS.

5. Organization overlooks IRS conditions in a ruling letter or fails to heed IRS audit changes and cautions.

6. Organization and its related entities deal with each other improperly.

7. Organization files incomplete or inaccurate information and tax returns.

8. Organization fails to maintain adequate books and records.

9. Organization fails to comply with applicable lobbying rules and limitations.

10 Organization fails to follow public inspection and fundraising disclosure requirements.