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Private Letter Ruling

Articles related to tax regulations and how they impact taxpayers.

Foundation's Set-Aside Approved

April 11, 2025
Foundation is tax-exempt under Sec. 501(c)(3) and a private foundation under Sec. 509(a). Foundation requested approval to set aside funds...

Neighborhood Association's Tax-Exempt Status Denied

April 4, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose is to operate as a neighborhood association that...

Extension to Allocate GSTT Exemption Granted

March 28, 2025
Grantor established irrevocable trusts for the benefit of Grantor’s spouse and descendants. The trust is divided into two separate trusts...

Organization's Exempt Status Revoked

March 21, 2025
Organization previously applied for tax exempt status as a church under IRC section 501(c)(3). Organization’s primary purpose, as stated in...

Community Association Denied Tax-Exempt Status

March 14, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose as a business association is to support local...

Employer-Related Scholarship Procedures Approved

March 7, 2025
Foundation requested advance approval of its employer-related scholarship procedures under Sec. 4945(g)(1). Approval is requested for a scholarship program for...

Tax-Exempt Status Denied for Software Promoter

February 28, 2025
Organization applied for tax exempt status under Sec. 501(c)(6). Organization’s mission is to promote another organization’s blockchain ecosystem open-source software...

Portability Election Extension Not Granted

February 21, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Tax-Exempt Status Denied for Union Organization

February 14, 2025
Union Organization (Organization) applied for tax exempt status under Sec. 501(c)(3). Its articles state that it is an association of...

Foundation Granted Additional Time to Sell Excess Business Holdings

February 7, 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...

NIL Nonprofit Denied Exempt Status

January 31, 2025
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is a nonprofit corporation whose purpose is to...

Extension for Portability Election Granted

January 24, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Foundation's Set-Aside Approved

January 17, 2025
Foundation is tax-exempt under Sec. 501(c)(3) and a private foundation under Sec. 509(a). Since its formation, Foundation has provided grants...

Extension for QTIP Election Granted

January 10, 2025
Decedent executed a revocable trust (Trust). Decedent died and was survived by Spouse. Upon Decedent’s death, the terms of Trust...

Farmer's Market Denied Exemption

January 3, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose is to have a marketplace in which local...

LLC Activities Qualify as Charitable and Educational Under 501(c)(3)

December 27, 2024
Taxpayer is a nonprofit corporation (Taxpayer) under section 501(c)(3) and classified as a public charity under sections 509(a)(1) and 170(b)(1)(A)(vi)...

Amendment to CRUT Terms is Approved

December 20, 2024
A and B executed a trust (Trust) that intended to qualify as a charitable remainder unitrust under Sec. 664(d)(2). The...

Extension for Portability Election Granted

December 13, 2024
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...

Business Group Denied Tax-Exempt Status

December 6, 2024
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose as a business association is to support local...

Educational Grant Procedures Approved

November 29, 2024
Foundation requested advance approval of its educational grant procedures. The grant program’s purpose is to help support entrepreneurs by providing...