Revenue Ruling 2003-12
Internal Revenue Service
2003-1 C.B. 283 (2003)
- Written by Jessica Rice, JD
Facts
Three hypothetical fact situations were presented, all occurring in a presidentially declared disaster area of a fictional state named ST. In each situation, the flood-affected citizens of ST were able to receive grant funds to either pay or reimburse medical, temporary housing, or transportation costs incurred as a result of the floods that were not covered by insurance or otherwise. In all three situations, the recipients had to abide by the program’s rules, and none of the programs were created to indemnify or reimburse all costs incurred. In Situation (1), the state, ST, created a program to reimburse or pay for citizen’s expenses. In Situation (2), a § 501(c)(3) organization, O, created a program to reimburse or pay for expenses, as the mission of the organization was to assist citizens affected by disasters. In Situation (3), an employer, R, created a program to reimburse or pay expenses to any affected employee regardless of length of employment.
Rule of Law
Issue
Holding and Reasoning ()
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