Ezel / IRS Rulings / 1305014
Determination Letter 1305014 Released February 1, 2013 Other outcome Transcribed from scan

IRS recognizes an organization under IRC § 4945(f)

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This page covers one taxpayer's ruling from 2013, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2013
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

The IRS recognized an organization as exempt from federal income tax under IRC § 501(a) because it qualifies under § 501(c)(3). The IRS also determined that the organization is not a private foundation because it qualifies under § 170(b)(1)(A)(vi). The organization was recognized under § 4945(f), so grants to it by private foundations will not be treated as taxable expenditures under §§ 4945(d)(2) or 4945(d)(4), as long as it continues to qualify under § 4945(f).

Ruling snapshot

  • Question: Does the organization qualify under IRC § 4945(f) so that grants from private foundations are not taxable expenditures?
  • Outcome: The organization was recognized under IRC § 4945(f).
  • Key authorities: IRC §§ 170, 4945, and 501

Full text (IRS public release)

Internal Revenue Service Department of the Treasury

P. O. Box 2508
Cincinnati, OH 45201

Release Number: 201305014
Release Date: 2/1/2013

Date: November 7, 2012

UIL Code: 4945-0400

Person to Contact - ID#:
Contact Telephone Numbers:

Employer Identification Number:

Dear

This letter is in response to your request to be recognized as an organization described
in section 4945(f) of the Internal Revenue Code.

The Internal Revenue Service has recognized you as an organization exempt from
federal income tax under section 501(a) of the Code because you are an organization
described in section 501(c)(3). In addition, you are not a private foundation because you
are described in section(s) 170(b)(1)(A)(vi) of the Code.

Based upon the information supplied, and assuming your operations will be as stated in
your request, we’ve determined that you are an organization described in section
4945(f) of the Code. Grants made to you by private foundations will not be treated as
taxable expenditures under sections 4945(d)(2) or 4945(d)(4) of the Code as long as
you are described in section 4945(f).

If you have any questions regarding this matter, please contact the person whose name
and telephone number are shown in the heading of this letter.

Sincerely,

Holly O. Paz
Director, Exempt Organizations
Rulings and Agreements

Letter 4778 (3-2012)
Catalog Number 58221N

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