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Revenue Ruling 90-74

1990-2 C.B. 34 (1990)

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Revenue Ruling 90-74

Internal Revenue Service
1990-2 C.B. 34 (1990)

Facts

Section 115 of the Internal Revenue Code (code) exempted from taxable income any revenue derived from performing essential government functions for the benefit of a state or a political subdivision of a state. The Internal Revenue Service (IRS) issued a revenue ruling to clarify how § 115 could be used to facilitate insurance-pooling arrangements for county governments. In the ruling, the IRS described a hypothetical nonprofit corporation that existed to pool the casualty risks of various county governments in a particular state. County governments became members of the organization by paying fees based on the counties’ actuarially determined casualty risks. The organization paid out the member counties’ casualty losses. The organization was run by a board of directors elected by representatives of the member counties. The organization generated investment income to help fund its obligations.

Rule of Law

Issue

Holding and Reasoning ()

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