RR-2018-14

The Internal Revenue Service (IRS) is continuing its program of reviewing revenue rulings published in the Internal Revenue Bulletin to identify and publish lists of those rulings that are obsolete and therefore are no longer considered determinative because: (1) the applicable statutory provisions or regulations have been changed or repealed; (2) the ruling position is specifically covered by a statute, regulation, or subsequent published position; or (3) the facts set forth no longer exist or are not sufficiently described to permit clear application of the current statute and regulations.

This revenue ruling obsoletes Rev. Rul. 68–59, 1968–1 C.B. 273, which held that an exempt organization in computing its net operating loss under § 172 of the Internal Revenue Code (Code) must exclude the specific deduction of $1,000 provided in § 512(b)(12) of the Code. Section 512(b)(12) was amended to disallow the $1,000 specific deduction for the purpose of computing the net operating loss under § 172. Tax Reform Act of 1969, Pub. L. No. 91–172, § 121(b)(2)(B), 83 Stat 487, 539 (1969).

Rev. Rul. 68–59 has been identified under the IRS’s review program as no longer being determinative because the ruling position is now specifically covered by a statute and is hereby declared obsolete.

The principal author of this revenue ruling is Gregory Schantz of the Office of Associate Chief Counsel (Tax Exempt and Government Entities Associate Chief Counsel). For further information regarding this revenue ruling, contact Gregory Schantz at (202) 317-4086 (not a toll-free number).