Recent Tax Court Case Illustrates Risk of “Sponsorship” Arrangements
Author: Katherine E. David, J.D..
Source: Volume 18, Number 06, September/October 2019 , pp.10-11(2)
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Abstract:
A recent case, Giving Hearts, Inc. v. Commissioner describes a creative idea that, ultimately, was a bridge too far. In 1977, Ronald Carrier organized a for-profit company, Window Plus, Inc. , which sells replacement windows and other home improvement products. Window Plus relies heavily on its in-house telemarketing staff to generate its sales leads. However, beginning in 2008, the National Do Not Call Registry caused the pool of potential customers who accept telemarketing calls to dwindle. Mr. Carrier realized that charitable organizations are not subject to the restrictions of the registry and figured it would make sense to combine for-profit telemarketing sales efforts with charitable giving.Keywords: Giving Hearts, Inc. v. Commissioner; Corporate Sponsorship Programs
Affiliations:
1: Strasburger & Price LLP.