An Administrator's Guide to California Private School Law Compendium

 The regulations and IRC are silent as to schools with annual gross receipts of more than $1,000,000, but it can be inferred that such schools must have comparability data on more than three comparable schools.  The school’s Board adequately and contemporaneously documented the basis for its determination. 6 Accurate documentation must note the following:  Terms of the approved transaction;  Date it was approved;  Members of the governing body or committee who were present during approval and those voting for approval;  Comparability data relied on and how it was obtained;  Actions taken related to any member who had a conflict of interest with respect to the transaction; and  Basis for determination of fair market value, if applicable. 7 If a school completes these three steps, the IRS may only rebut the presumption of reasonableness if it can show the comparability data relied on by the school was inappropriate.

An Administrator’s Guide to California Private School Law - Compendium ©2019 Liebert Cassidy Whitmore 15