Ezel / IRS Rulings / 1307013
Determination Letter 1307013 Released February 15, 2013 Approved Transcribed from scan

IRS recognizes an organization as eligible under section 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 described in section 4945(f) of the Internal Revenue Code. The letter states that the organization is already exempt under section 501(c)(3) and is not a private foundation because it is described in sections 509(a)(1) and 170(b)(1)(A)(vi). Based on the information supplied and the assumption that the organization will operate as described in its request, grants from private foundations to the organization will not be treated as taxable expenditures under sections 4945(d)(2) or 4945(d)(4), as long as it remains described in section 4945(f).

Ruling snapshot

  • Question: Does the organization qualify as an organization described in IRC § 4945(f)?
  • Outcome: Approved
  • Key authorities: IRC §§ 4945(f), 4945(d)(2), 4945(d)(4), 501(a), 501(c)(3), 509(a)(1), and 170(b)(1)(A)(vi)

Full text (IRS public release)

internal Revenue Service Department of the Treasury
P. O. Box 2508

Cincinnati, OH 45201

R

Release Number: 201307013

Release Date: 2/15/2013

Date: November 20, 2012

Person to Contact - ID#:
Contact Telephone Numbers:

Employer Identification Number:

UIL: 4945.04-03
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 sections 509(a)(1) and 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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