Each year Smart School, a private educational institution th…
Each year Smart School, a private educational institution that qualifies for tax-exempt status under section 501(c)(3) sets up a pie stand for three weeks in its foyer to raise funds for the school. A bakery across the road argues that this is unfair competition and the income from the pies should be taxed at ordinary rates. Is the income from the pie sales unrelated business income?
Read DetailsWhen his dog Gunnar became paraplegic after a car accident,…
When his dog Gunnar became paraplegic after a car accident, Jason knew he’d do anything for his beloved pup. Once a wheelchair cart helped Gunnar get around again, Jason decided to pay it forward. He started a nonprofit organization called Gunnar’s Wheels that provides free wheelchairs to dogs whose families fall below certain income levels. Gunnar’s Wheels was established in 2004, and over the last five years has reported the following support. Grant from government agency $5,000 Contributions from the Humane Society (a public charity) $25,000 Gross investment income $1,000 Donations From individuals to the extent they contributed $2,620 or less $50,000 From individuals to the extent they contributed more than $2,620 $25,000 From the WK Kellogg Foundation (private foundation) $25,000 Total Support $131,000 a) (10 points) Does Gunnar’s Wheels qualify as a donative public charity under section 509(a)(1)? Show your calculations and explain why or why not. b) (10 points) Assume that Gunnar’s Wheels did not receive any of its donations from individuals. Rather, the WK Kellogg foundation provided a grant totaling $100,000 over the last five years. Further assume that Gunnar’s Wheels has a bona fide program for solicitation of funds from the general public, governmental units, or public charities and its board is comprised of members of the community. All other facts are the same. Does Gunnar’s Wheels qualify as a donative public charity under section 509(a)(1)? Show your calculations and provide analysis of relevant tax law as to why or why not.
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