Abstract
When Priv. Ltr. Rul. 201911010 was reviewed, the initial decision here was that it was not worth summarizing. The ruling held that “[p]roviding food and drink to members of the general public absent a showing of need is not a charitable purpose.” That appears obviously correct. It was no surprise to see the IRS invoke the commerciality doctrine in this case. It was annoying to read that the IRS faulted the organization for being “funded primarily through support by a related for‐profit entity.” Corporate foundations are nearly always funded that way, although the support from the for‐profit company is usually the sole support. This ruling by the IRS on this latter point seemed so preposterous as to not merit comment.
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