Abstract
The flow of IRS rulings concerning grants to individuals by private foundations, holding that they do not constitute taxable expenditures, is a constant one, with these determinations tumbling out by the tens annually; this is not, by itself, news. Usually, these grants are in the form of scholarships, fellowships, internships, and the like (e.g., most recently, Priv. Ltr. Ruls. 202114025 and 202114026). But, recently, these approved grants have been of more exotic varieties. An illustration follows, involving grants to IT service providers.
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