The following is a cumulative listing of names of organizations that
are presently challenging, under section 7428 of the Internal Revenue Code,
the revocation of their status as organizations entitled to receive deductible
contributions in declaratory judgment suits in the Tax Court, the United States
District Court for the District of Columbia, or the United States Court of
Federal Claims. The purpose of this announcement is to inform potential donors
to these organizations of the protection under 7428(c) for certain contributions
made during the litigation period.
Protection under section 7428(c) of the Code begins on the date that
the notice of revocation is published in the Internal Revenue Bulletin and
ends on the date on which a court first determines that an organization is
not described in section 170(c)(2), as more particularly set forth in section
7428(c)(1). In the case of individual contributors, the maximum amount of
contributions protected during this period is limited to $1,000.00, with a
husband and wife being treated as one contributor. This protection is not
extended to any individual who was responsible, in whole or in part, for the
acts or omissions of the organization that were the basis for the revocation.
This protection also applies (but without limitation as to amount) to organizations
described in section 170(c)(2) which are exempt from tax under section 501(a).
If the organization ultimately prevails in its declaratory judgment suit,
deductibility of contributions would be subject to the normal limitations
set forth under section 170.
I. The organizations listed below continue to be involved in pending
declaratory judgment suits under section 7428 of the Code, challenging revocation
of their status as eligible donees under section 170(c)(2). Protection under
section 7428(c) begins on the date indicated.
|Michael and Laura Gallop Family Foundation
||Agoura Hills, CA
|| (June 28, 2004)
|South Community Association
|| (September 1, 2003)
II. The organization listed below has timely filed a declaratory judgment
suit under section 7428 of the Code during 2005. Protection under section
7428(c) begins on the date indicated.
|Rameses School of San Antonio, Texas
||San Antonio, TX
|| (January 24, 2005)
III. The organization listed below is no longer described in section
170(c)(2) and is not recognized as exempt under section 501(c)(3) of the Code.
|South Park Remedial Association
IV. The organization listed below continues to be described in section
170(c)(2) and is recognized as exempt under section 501(c)(3) of the Code.
|Clinica Materna Infantil 30-30, Inc.
Internal Revenue Bulletin 2006-01
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