The bottom line, presented up top:
• Estate planning organization not qualified for federal income tax exemption under IRC §501(a) as an organization described in IRC §501(c)(3). • Contributions not tax deductible. • IRS will notify the appropriate state officials of its determination, as required by IRC §6104(c), by sending them a copy of its determination letter.
Details
IRS Letter Ruling 202324011 is an excellent primer on the law governing IRC §501(c)(3) tax exemption for an organization having charitable purposes—but also business or private objectives.
Alert—and Two Suggestions
- Perhaps you don’t need to know all the details now. Then, do what I do. File stuff for future reference should it be needed. (Confession: Most stuff goes into my miscellaneous file—and that presents retrieval problems).
- Read A Rude Awakening at the very end of this article. In the proverbial nutshell, it explains why the IRS has denied 501(c)(3) charitable status to the estate planning organization detailed in this column.
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