Two County Offices of Education and several public school districts in California are forming a Joint Powers Agency (JPA) to provide maintenance, operations, food service, transportation, printing, ans warehouse/delivery services. The JPA is being formed by public education organizations to provides services to public education organizations. Is the JPA 403(B) eligible organization? Is it necessary to seek a Letter of Determination from the IRS?

I believe that there are some old regs or rulings that cover this subject.