Fee Exempt Proof

0319-EX-ST-2008 Text Documents

Regents of the University of California

2008-07-17ELS_91976

MAK—10—2004   1S5:3G         510 987 0Y12
     snietnat Atvernmmsy y—1                                                   510 987 gaiz       P.02
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       District                                   450 Goiden Gate Ave.
       Director                                   San Franciseo, Calit 94102

                                                  Person to Contact:                     A o
      »® The Regents of the University            Desk Officer                        feceiyen
                                                                                    SEP 10 :: ap
           of California                          Telephone Number:
         c/o The Office of the Ceneral            (415) 556—5253                      GrFice or
         Counsel                                  Refer Reply to:                       ThE
                                                                                      CECAAl
       590 University Hall                        EP/EO:L
                                                                                       SuNSE
       2200 University Avenue                    . Cate:
       Berkeley, CA 94720
                                                  8 SEP 19827
       Re:   Request for Confirmation of Exempt
             Status under Section 5Q0l(c)(3) of
             the Internal Revenue Code of 1954


       Dear Regents:

       This is in reference to your letter of July 13, 1982 requesting confirmation
       of the exempt status of The Regents of the University of California under
       section 50i1(c)(3) of the Internal Revenue Code of 1954.

       In our letter of September 14, 1939, Code IT:P:T:Ll CQ, it was held that
       you were entitled to exemption under the provisions of section 101(6) of
       the Revenue Act of 1938.

       A determination or ruling letter issued to an organization granting
       exemption under the Internal Revenue Code of 1954 or under a prior or
       subsequenat Revenue Act remains in effect until exempt status has been
      _terminated, revoked or modified.

       Our records indicate that you are the regularly constituted state university
       of the State of California originally created by a state legislature act of
       1868; that you are engaged in educational activities; that your income is
       derived from investments, endowments, tuition, and miscellancous sources;
       and that your income is used in furtherance of your educstional activities.

       In addition, it appears from our records (*acludxnv the.information submitted
       with your letter of July 13, 1982), that there has been no. change in your
       organization‘s exempt status.     Accordingly, our letter of September 14, 1939
       is still in effect.   This letter does not constitute a no change examination                     <7j
       letter .

       Because section 501(c)(3) of the Internal Revenue Code of 1954 was derived
       from and continues, without substantive change, the language of section
       101(6) of the Revenue Act of 1938 ("1939 Code") and because our letter of
       September 14, 1939 is still in effect, it appears that you and your
       constituent units are entitled to exemption as an organization described
       in section 5O0l(c)(3) of the 1954 Code.

       Donors may deduct contributions to you as provided in section 170 of the
       Internal Revenue Code of 1954 (formerly section 23(0) of the Internal


 MHK—14—2004   1539       510 987 d12
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                                                  —~2~

     The Regents of the Universirty of California
                                                                           /
     Revenue Code of 1938). Bequests, legacies, devises, transfers, or gifts
     to you or for your use are deductible for Federal estate and gift tax
     purposes as provided in the applicable provisions of sections 2055, 2106,
     and 2522 of the Internal Revenue Code of 1954.

     You are not required to file Form 990, Return of Organization Exempt from
     Income Tax, because you are a State instituCtion, the income of which is
     excluded from gross income under section l15(a) of the Internal Revenue
     Code of 1954.                         '               —

     You are not required to file Federal income tax returns unless you are
     subject to the tax on unrelated business income under section 511 of the
     Code. If you are subject to this tax, you must file an income tax return
     on Form 990—T. This office has not been asked to consider and therefore,
     in this letter, we are not determining whether any of your present or
     proposed activities are unrelated trade or business as defined in section
     513 of the Internal Revenue Code of 1954 .

     Because this letter could help resolve any questions about your exempt
     status, you should keep it in your permanent records.

     If you have any questions, please contact the person whose name and
     telephone are shown in the heading of this letter.

                                              Sincerely,


                                              Moche] Sm
                                              District Director




                                                                                TOTRL P.03



Document Created: 2019-02-17 13:41:18
Document Modified: 2019-02-17 13:41:18

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