Question

Pigeon, Inc., a § 501(c)(3) organization, received support from the following sources.
Governmental unit A for services rendered ........ $ 6,300
Governmental unit B for services rendered ........ 4,500
Fees from the general public for services rendered
(Each payment was of $100) ............... 75,000
Gross investment income ............... 39,000
Contributions from disqualified persons ......... 26,000
Contributions from other than disqualified persons
(Each gift was of $50) ................. 160,000
Total support ..................... $310,800
a. Does Pigeon satisfy the test for receiving broad public support? Why or why not?
b. Is Pigeon a private foundation? Be specific in your answer.
c. Arnold Horn, Pigeon’s treasurer, has asked you to advise him on whether Pigeon is a private foundation. Write a letter to him in which you address the issue. His address is 250 Bristol Road, Charlottesville, VA 22903.


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  • CreatedSeptember 09, 2015
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