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a. created the organization
b. previously contributed a substantial part of its support or endowment
c. stood in a position of authority with respect to the organization, such as a foundation manager within the meaning of section 4946(b)
d. directly or indirectly exercised control over the organization, or
e. was in a relationship described in Internal Revenue Code section 4946(a)(1)(C) through 4946(a)(1)(G) with someone listed in bullets a, b, c, or d above.
A contribution made by a person described in a. - e. is ordinarily given less favorable consideration than a contribution made by others not described above.
a) The grant was not made by a person who created you or who previously contributed a substantial amount of your support. The grantor also does not stand in a position of authority with respect to you and does not exercise control over you.
b) The grant is a bequest and is in the form of cash or investments.
c) You have carried on an actual program of public solicitation, have exempt activities, and have attracted a significant amount of public support over the years.
d) You have met the public support test in past years.
e) Because you have relied on public support in the past, it can be assumed that you will be able to maintain that level of public support in the future.
f) You have a large representative governing body.
Foundation's Set-Aside of Funds Approved
Commercial Activity Sinks Marine Science Organization's Exemption
No UBTI on Endowment Units to Trust
Foundation's Set-Aside Approved
Pipe Manufacturer Fails to Qualify for Exemption
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