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Re: [ga] FUNDING


Dave:

    I am surprised that you stepped in this. I do refer to the IRS "Support
Test". A very simple test of several, required by the IRS.

                                Qualified Support
                                _____________     = Minimum %

                                Total Support

This is just one test, their are others that define Qualified Support.

/Bruce
"Let us reason together."



----- Original Message -----
From: "Dave Crocker" <dhc2@dcrocker.net>
To: "Michael Froomkin - U.Miami School of Law" <froomkin@law.miami.edu>
Cc: <ga@dnso.org>
Sent: Saturday, April 21, 2001 17:11
Subject: Re: [ga] FUNDING


Sigh.  Another red herring.

The IRS does not require any minimimum contribution or donation level for a
501(c)(3) tax-exempt status.

The criteria related to tax-exempt status are varied and somewhat complex,
but donations, per se, are not particularly relevant.

This assessment is based on:

         a) 8 years running a 501(c)(3) that charges fees; though it gets
donations, the percentage has never been an issue; and

         b) A quick review of Nolo Press' The California Nonprofit
Corporation Handbook, by Anthony Mancuso.

d/

At 01:11 PM 4/21/2001, Michael Froomkin - U.Miami School of Law wrote:
>It may raise tax issues, but it doesn't raise "APA" (Administrative
>Procedure Act) issues.  Try "IRS" - "Internal Revenue Service" ...
>
>On Sat, 21 Apr 2001, Eric Dierker wrote:
>
> > I cannot find an alteration of this statement by Mr. Roberts.  If this
> > is accurate we are not near the 51% donation funding required by our IRS
> > status.  This raises serious APA issues.

----------
Dave Crocker   <mailto:dcrocker@brandenburg.com>
Brandenburg InternetWorking   <http://www.brandenburg.com>
tel: +1.408.246.8253;   fax: +1.408.273.6464

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