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Section 4940 imposes an excise tax on the net investment income of most domestic tax-exempt private foundations, including private operating foundations. On December 20, 2019, new legislation was signed that changed the excise tax rates of net investment income for most domestic tax-exempt private foundations, including private operating foundations.

These documents are prepared by field attorneys in the Office of Chief Counsel, reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service.

"The Truth About Frivolous Tax Arguments" addresses frivolous tax arguments in general. This document was updated March 2022

The second section of "The Truth About Frivolous Tax Arguments" responds to some of the more common frivolous arguments made in collection due process cases. This document was updated in March 2022.

Section III of "The Truth About Frivolous Tax Arguments" explains the penalties that the courts may impose on those who pursue tax cases on frivolous grounds. This document was updated March 2022.

Legal Advice Issued to Program Managers during 2010

Legal advice signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers.