Alternative Approaches
1974 committee bill
The 1974 committee bill included a provision modeled after the Tax
Court declaratory judgment provision in the Employee Retirement Income Security Act of 1974. The committee bill provided for declaratory judgment proceedings only in the United States Tax Court, to bring to bear the expertise and national uniformity of statutory interpretation that would result from making that court the exclusive
forum for these suits.
The bill authorized suits to be brought by the organization seeking the determination as to its own status, and did not give any rights to contributors or to third parties who wish to defend or attack the organization.”
The bill applied to revocations of prior favorable Service determinations, as well as initial unfavorable determinations (or refusals to rule), but limited its application to determinations of whether an organization is exempt as a “charitable organization,” whether it is an eligible recipient of deductible charitable contributions, and whether it is a private foundation ( and, if so, whether it is an operating foundation ).
The committee concluded that the questions that could be resolved under the procedures it provided for generally were the more important questions in the field, and that it was important to provide promptly a mechanism for answering those questions. Examination of the more intricate problems (such as the standing of contributors and of third parties ), the committee concluded, could properly be delayed until the Congress could evaluate the working of the declaratory judgment procedure provided under the bill, as well as that enacted under the 1974 pension law.
Mr. Ullman
His proposal is the same as that in the 1974 committee bill.
The Supreme Court has implicitly held that under certain circumstances suits can be brought by third parties to restrain the
Internal Revenue Service
from
treating an organization as being exempt . Coit v . Green , 404 U.S. 997 ( 1971 ), affirming Green
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