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IRS
Final Determination Letter
IRS
Final Determination Letter [print
version]
In a letter from the Internal Revenue
Service dated May 12, 1999, National Heritage Foundation was informed
that its permanent status was affirmed based on our financial activity
during the Advanced Ruling Period. Quoting this letter:
"Based on the information you
submitted, we have determined that you are not a private foundation
within the meaning of section 509(a) of the Code because you are
an organization of the type described in section 509(a)(1) and
170(b)(l)(A)(vi). Grantors and contributors may rely on this determination
unless the (IRS) publishes notice to the contrary."
As many of you already know,
the coveted status is "public" foundation, not "private" foundation.
Broadly speaking, there are five types of "public" charities:
- Hospitals
- Churches
- Schools
- Government or Government Feeder
Organizations
- Publicly Supported Charities
NHF initially applied for public charity status in 1968, which
was granted in 1973. After the IRS challenge was defeated in 1987
(see NFI vs. the United States, 13 Claims 486, summarized on our
website), we reincorporated the National Heritage Foundation in
1993. We had until 1999 to "prove" that we are publicly supported,
and therefore be granted permanent Public Charity status.
Public status ensures that no public charity is controlled by
one, or a few, wealthy donors. It requires all charities that seek
public status to "pass a public support test." The public support
test requires that at least 1/3 of all charity income come from
"the public." The public is defined roughly as those who donate
less than 2% of total charity income. Since its inception in 1968,
NHF has always passed the "public support test" with flying colors.
According to the way public support is calculated, NHF is more
than 94% supported by the public.
You will find a copy of this IRS letter replacing the former letter
in our manual, Now That You Have Your Foundation.
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©
2006 by National Heritage Foundation
6201 Leesburg Pike, Suite 405
Falls Church, Virginia 22044-2201
Tel: 800-986-4483 Local: 703-536-8708
Fax: 703-820-5100
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