IRS recognizes an organization as eligible under section 4945(f)

Number

201307013

Outcome

Approved

Document type

Determination Letter

IRS subject

Influencing The Outcome of Elections

Topics

Private foundations

Code sections

§ 4945, § 501, § 509, § 170, § 6110

Ruling dated

November 20, 2012

Publicly released

February 15, 2013

Source

View Official PDF

Apply this to your situation

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

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

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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