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Abstract: 

Although private letter rulings are not regarded as binding authority, they often do provide readers with insight into what new ideas might be worth considering for their own donors and clients. The first PLR addresses whether a transfer from a grant-making private foundation to a related private operating foundation constitutes a qualifying distribution. In each of the remaining two rulings, foundation expenditures were deemed not to be for tax-exempt purposes resulting in the revocation of tax-exempt status.

Keywords: PLR 201335020; PLR 201335026; PLR 201331007

Affiliations:  .