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.