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 $100) |
75,000 |
|
Gross investment income |
39,000 |
|
Contributions from disqualified persons |
26,000 |
|
Contributions from other than disqualified persons |
|
|
(each gift was $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.