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Private Letter Ruling

Articles related to tax regulations and how they impact taxpayers.

Distributions from Charitable Trust to Private Foundations Approved

January 9, 2026
Husband and Wife are the settlors and trustees of a charitable remainder unitrust (Trust) under Sec. 664. Trust provides that...

Charitable Bequest Constitutes Unusual Grant

January 2, 2026
Organization made a request to recognize a proposed transfer from Donor under Reg. 1.170A-9(f)(6)(ii). Organization is a Sec. 501(c)(3) public...

IRS Denies Community Group's Exempt Status

December 26, 2025
Organization applied for exempt status under Sec. 501(c)(3) as a hobby club organized to promote entrepreneurial leadership skills, community outreach...

Foundation Granted Additional Time to Sell Excess Business Holdings

December 19, 2025
Organization is tax-exempt under Sec. 501(a), as an organization described in Sec. 501(c)(3) and classified as a private foundation under...

Election for QTIP Extension Granted

December 12, 2025
Decedent and Spouse executed a revocable trust (Trust). Decedent died and was survived by Spouse. Upon Decedent’s death, the terms...

Organization Formed to Support Youth is Denied Exempt Status

December 5, 2025
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it was formed as a booster club to provide...

IRS Grants Portability Election Extension

November 28, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Organization Formed to Support Individual is Denied Exempt Status

November 21, 2025
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it was formed as a Special Needs Trust (Trust)...

Foundation's Scholarship Procedures Approved

November 14, 2025
Foundation requested advanced approval of an educational grant program under Sec. 4945(g)(3). The purpose of the grant program is to...

NIL Nonprofit Denied Exempt Status

November 7, 2025
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is a nonprofit corporation whose purpose is to...

Exempt Status Denied for Motorcycle Club

October 31, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). It operates as a social club for motorcycle riders, hosting regular...

Dominoes Group Denied Exempt Status

October 24, 2025
Organization applied for exempt status under Sec. 501(c)(3) as a hobby club organized for the social and recreational benefit of...

Portability Election Extension Granted

October 17, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Educational Center's Transfer Constitutes Unusual Grant

October 10, 2025
Organization made a request to recognize a proposed transfer from its supporting organization (Organization B) as an unusual grant under...

Family Reunion Organization Exempt Status Denied

October 3, 2025
Organization applied for exempt status under Sec. 501(c)(3). Its primary activity is to support family functions, activities, gatherings and events...

Extension for QTIP Election Granted

September 26, 2025
Decedent executed and amended a revocable trust (Trust). Decedent died and was survived by Spouse. Upon Decedent’s death, the terms...

Festival Denied Exempt Status

September 19, 2025
Organization applied for exempt status under Sec. 501(c)(3). Its primary activity is hosting an annual three-day community festival featuring entertainment...

Farmers Market's Exempt Status Denied

September 12, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s purpose is to improve the production and marketing of locally...

Transfers to New Private Foundations Approved

September 5, 2025
Foundation is tax-exempt under Sec. 501(c)(3) and classified as a private foundation under Sec. 509(a). Foundation was funded by distributions...

Portability Election Extension Granted

August 29, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...