CHAPTER FIFTEENPrivate Foundations and Public Charities
- *§ 15.4 Publicly Supported Organizations Donative Entities
- § 15.5 Service Provider Organizations
- § 15.7 Supporting Organizations
- § 15.8 Change of Public Charity Category
*§ 15.4 PUBLICLY SUPPORTED ORGANIZATIONS DONATIVE ENTITIES
(a) General Rules
p. 730, note 95. Delete and substitute:
Reg. § 1,170A-9(f)(6)(v). This concept of earmarking is also reflected in the rules for service provider organizations (see § 15.5) (Reg. § 1.509(a)-3(j)(1), (2). Examples that apply in both contexts are in Reg. § 1.509(a)-3(j)(3).
§ 15.5 SERVICE PROVIDER ORGANIZATIONS
(c) Unusual Grants
p. 749, note 181, first line. Delete Reg. citation and substitute:
Reg. § 1.509(a)-3(c)(3), (4).
p. 749, note 181, second line. Delete Reg. citation and substitute:
Reg. § 170A-9(f)(6)(ii), (iii).
p. 750. Insert as first complete paragraph:
There has been a flurry of favorable private letter rulings concerning unusual grants this spring. In one instance, a community foundation was about to receive a bequest from an estate, the size of which was unusual compared with the foundation's support levels and which would have adversely affected its status as a public charity; the decedent had not previously contributed a substantial part of the foundation's support and the bequest ...
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