AICPA Urges IRS to Clarify Form 990 Instructions 

    Published June 21, 2006

    Internal Revenue Service, TE/GE


    1111 Constitution Ave., NW


    Washington, DC20224




    Attention: Michael Seto, T:EO:RA:G:1, 1750 Penn.Building




    RE:      Instructions for Form 990, Return of Organization Exempt from Income Tax




    Dear Mr. Seto:




    As a follow-up to our meeting on April 24, 2006, enclosed are comments prepared by the American Institute of Certified Public Accountants (AICPA) regarding a specific set of changes in the Instructions to Lines 25, 75b and 75c of the 2005 Form 990, Return of Organization Exempt from Income Tax. These comments generally recommend greater clarity in the Instructions, and were developed by the 2005 Form 990 Task Force of the AICPA’s Exempt Organizations Technical Resource Panel, and approved by the Tax Executive Committee.




    The AICPA is the national, professional association of CPAs, with approximately 350,000 members, including CPAs in business and industry, public practice, government, and education; student affiliates; and international associates. Our members provide audit and tax services to thousands of not-for-profit organizations. These comments were developed by practitioners who serve tax-exempt organizations and are experienced with both the nuances of the Instructions and the challenges that arise for taxpayers in applying them.




    We appreciate your consideration of these comments. If you have any questions, please contact me at; Mary Rauschenberg, Chair, Exempt Organizations Technical Resource Panel, at; or George White, AICPA Technical Manager, at








    Thomas J. Purcell III

    Chair, AICPA Tax Executive Committee

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