IRS Denies Exemption to Trust Formed Primarily to Support Foreign Institution

Tax Notes Today reports that the IRS has determined that a domestic trust ostensibly formed to  further charitable, religious and educational purposes does not qualify for exemption from federal income tax as an organization described in Internal Revenue Code section 501(c)(3).  The adverse determination is available at 2010 TNT 79-40.  Here is a copy of the abstract:

The IRS has denied exempt status to an organization that supports a foreign institute for Jewish studies, finding that private rather than public interests are being served and that the group -- as a foreign conduit -- would not be eligible to receive deductible donations if, on appeal, the IRS were to find it qualifies for exempt status.

JRB