PUBLICATION 78 - ELECTRONIC VERSION This is an electronic version of Publication 78, 'Cumulative List of Organizations'. This publication lists the names of organizations eligible to receive tax deductible contributions, as well as the amount of the contribution that is deductible. This listing is produced from computer records and is subject to certain limitations, particularly in the format and arrangement of the entries. DATA RECORD: Position(s) Contents 1-105 Organization Name 106 blank 107-136 City 137 blank 138-139 State 140 blank 141-147 Deductibility limitation codes (7) one digit codes 148 blank 149-168 Advance Ruling Expiration Date Organizations are listed only under the legal name (or recognized abbreviation such as "VFW") currently listed with the Internal Revenue Service. Following the name is the address (city and state) used by the organization. No separate listings of "common" or "popular" names of organizations are included. However, some exceptions to the general rule may appear. Subordinate units that are included in group exemption letters are not given a separate listing. However the listing for the central organization indicates that contributions to subordinate units covered by the group exemption are also deductible. If the organization's name does not include the name of an individual it will be in strict alphabetical sequence of the name exclusive of an introductory "The". If the organization's name includes the name of an individual it will generally be listed alphabetically according to the surname of the individual. For example, The John Smith Foundation will be listed under "S" as Smith Foundation, The John. However, some exceptions to this general rule may appear. If you are unable to find an organization listed under the surname of an individual, you should see if it is listed under the given name of the individual. Names with ampersands are alphabetized without considering the ampersand. For example, "The Brown & White" Foundation would be alphabetized "Brown W . . .". Organizations whose names begin with numbers, such as 400 Club, will come at the end of the list after the "Z's." These are in sequence by the first digit of the number. ========================================================= Abbreviations o/w/o--of will of u/a--under agreement u/d--under deed u/d/t--under deed of trust u/i--under indenture u/t/a--under trust agreement u/w--under will u/w/o--under will of Cumulative List of Organizations described in Section 170(c) of the Internal Revenue Code of 1986 Preface Part I of this preface contains a description of codes used in the individual listings. Part II contains a general explanation of the rules covering deductions for contributions for Federal income tax purposes. Part I This publication contains a list of organizations to which contributions are deductible. The list is not all-inclusive. If an organization is not listed but has a ruling or determination letter holding contributions to be deductible, generally the letter will serve as evidence to contributors of the deductibility of their contributions. Contributions to an organization described in section 170(c)(1) for exclusively public purposes will be allowed regardless of whether the organization has received a letter confirming its status. The organizations described in section 170(c)(1) are a state, a possession of the United States, or any political subdivision of the foregoing, or the United States or the District of Columbia. This publication employs a coding system to identify each organization listed by type and limitation on deductibility. The codes, which appear to the right of the organization's name, are explained below. The significance and effect of the limitations on deductibility are explained in Part II. Code Meaning None A public charity with a 50% deductibility limitation. 1 Generally, a central organization holding a group exemption letter, whose subordinate units covered by the group exemption are also included as having contributions deductible, even though they are not separately listed. 2 A fraternal organization contri- butions to which are deductible by an individual but only if they are to be used exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals. 3 A private operating foundation with a 50% deductibility limitation. 4 A private foundation, generally with a 30% deductibility limitation. 5 A charitable organization whose status as a public charity (rather than a private foundation) has not been determined. Most of these organizations have not sought formal recognition as public charities, even though many of them, such as churches or P.T.A.'s, may qualify as public charities. This code also includes some organizations that have formally claimed public charity status but that status has not yet been determined to be correct by the Internal Revenue Service. 6 An organization described in section 170(c) of the Code other than a charity. 7 An organization to which contributions are deductible if made for the use of a govern- mental unit. These have a 30% deductibility limitation. 8 A foreign-addressed organization . OTHER CODING--A four-digit number appearing after the name of an organization and following the legend "Until" indicates the Advance Ruling Expiration Date. The entry represents organizations receiving a "public charity" advance ruling under section 501 (c)(3) of the Internal Revenue Code. The first two-digit number represents the year and the last two-digit number represents the month in which the "public charity" advance ruling is scheduled to terminate (e.g. 9906 indicates a June 30, 1999 expiration date). Additionally, for advance ruling dates expiring in the year 2000, this date will be indicated by a four-digit number representing the year, and the last two digits representing the month (e.g., 200012 indicates a December 31, 2000 expiration date). The following examples, using fictitious names, illustrate the use of this coding system: Doe Foundation, The John (4) Columbia, Md. Explanation: Code (4) denotes that this is a private foundation with a 30% deductibility limitation. Royal order of Falcons (1) (2) (6) South Orange, N.J. Explanation: Code (1) denotes that contributions to subordinate units included under the group exemption are deductible; code (2) limits deductibility to contributions used exclusively for religious, charitable, and other designated purposes; and code (6) denotes a 30% deductibility limitation. Metatarsal Society of America, Inc. Washington, D.C. Explanation: No code means a public charity with a 50% deductibility limitation. Tree Public Society, Until 200009, Yuma, AZ Explanation: Until 200009 denotes a 50% deductibility limitation until September 2000. Deductibility after this date will depend on a final determination or ruling on foundation status. Publication No. 78 is updated and reissued annually. Additions are published in cumulative quarterly supplements. However, when the Internal Revenue Service withdraws recognition of status or when it recognizes a change in an organization's status, the cumulative quarterly supplements do not reflect such changes. Status changes are published by announcements in the Internal Revenue Bulletin. Bulletin announcements also provide the public with current information on the status of protected contributions, where an organization has timely filed suit for declaratory judgment under section 7428 of the Code challenging its revocation of exemption. Organizations which are required to file annual information returns on either Form 990 (Return for Organization Exempt from Income Tax) or Form 990-PF (Return for Private Foundation Exempt from Income Tax) as required by section 6033 of the Code, but which have not done so for two years (extensions of time to file considered) prior to the extraction date of this edition, may not be included in this listing. However the exclusion of an organization from the Cumulative List because of this does not constitute the termination of the Internal Revenue Service's recognition of its exempt status. The extent to which contributors may rely on the listing of organizations in this publication for purposes of deductibility is contained in Revenue Procedure 82-39. Such reliance is also subject to any announcements published in the Internal Revenue Bulletin that inform the public about the status of certain protected contributions under section 7428(c) of Code. The General rule as set forth in Revenue Procedure 82-39 is that contributions will be deductible by persons unaware of a change in the organization's status until (1) the date of publication of an announcement in the Internal Revenue Bulletin that contributions to the organization are no longer deductible or (2) a different date specified in another announcement concerning certain protected contributions under Section 7428(c) of the Code. Similar reliance provisions apply to an organization's foundation classification as it appears in the list. See also Revenue Procedure 89-23. Questions concerning the listings in this publication or supplements, i.e., with regard to omissions, misspelling, alphabetical misplacement, coding errors, deductibility of contributions to a particular organization not listed, and questions of a general technical nature should be addressed to your District Director. The Cumulative List, Publication No. 78, and supplements may be obtained on a subscription basis from the Superintendent of Documents, Government Printing office, Washington, D.C. 20402. Subscription information, including current price, may be obtained by calling (202)783-3238. Part II This section contains a general explanation of the rules covering income tax deductions for contributions by individuals. A more comprehensive discussion of the rules can be found in Publication 526, "Charitable Contributions", and Publication 561, "Determining the Value of Donated Property". Both Publications may be obtained free by calling 1-800-829-3676. Charitable contributions of money or property made to certain qualified organizations may be deducted if you itemize your deductions. Generally, you may deduct up to 50% of your adjusted gross income, but 20% and 30% limitations apply in some cases. Qualified Organizations A contribution is deductible if it is made to, or for the use of, any of the following organizations that otherwise are qualified under section 170(c) of the 1986 Code: A State, a U.S. possession, or political subdivision thereof, of the United States, or the District of Columbia, if made exclusively for public purposes; A community chest, corporation, trust fund, or foundation, organized or created in the United States or its possessions, or under the laws of the United States, any State, the District of Columbia or any possession of the United States, and organized and operated exclusively for charitable, religious, educational, scientific, or literary purposes, or for the prevention of cruelty to children or animals; A church, synagogue, or other religious organization; A war veterans' organization, its post, auxiliaries, trusts or foundations organized in the United States or its possessions; A nonprofit volunteer fire company; A civil defense organization created under Federal, State, or local law. (This includes unreimbursed expenses of civil defense volunteers that are directly connected with and solely attributable to their volunteer services); A domestic fraternal society, operating under the lodge system, but only if the contribution is to be used exclusively for one or more charitable purposes; A nonprofit cemetery company if the funds are irrevocably dedicated to the perpetual care of the cemetery as a whole and not a particular lot or mausoleum crypt. Timing of Contributions Contributions must actually be paid in cash or other property before the close of your tax year to be deductible, whether you use the cash or accrual method. Deductible Amounts If you donate property other than cash to a qualified organization, you may generally deduct the fair market value of the property. However, if the property has appreciated in value, some adjustments may have to be made. The rules relating to how to determine fair market value are discussed in Publication 561 "Determining the Value of Donated Property". Limitation on Deductions In general, contributions to charitable organizations may be deducted up to 50% of adjusted gross income computed without regard to net operating loss carrybacks). However, contributions to certain private foundations, veterans organizations, fraternal societies, and cemetery organizations are limited to 30% adjusted gross income (computed without regard to net operating loss carrybacks). The 50% limitation applies to (1) all public charities (no code), (2) all private operating foundations (code 3), (3) certain private foundations that distribute the contributions they receive to public charities and private operating foundations within 2-1/2 months following the year receipt, and (4) certain private foundations the contributions to which are pooled in a common fund and the income and corpus of which are paid to public charities. Public charities include; churches or conventions or associations of churches; tax-exempt educational organizations with a regular faculty and curriculum and a regular student body attending resident classes; tax-exempt hospitals; under certain circumstances, organizations directly engaged in continuous medical research in conjunction with such hospitals, and certain organizations operated exclusively to hold and administer property for State and local colleges and universities; a state, a possession of the U.S., or any political subdivision of any of the forgoing, or the U.S. or the District of Columbia, if the contribution is made for exclusively public purposes; charitable organizations that receive support in the form of gifts or fees from the general public or from government grants; and organizations operated in connection with any of the above. A private operating foundation, briefly, is a private foundation that spends the majority of its income in the active conduct of charitable undertakings rather than distributing its income to other organizations. The 30% limitation applies to private foundations (code 4--other than those previously mentioned that qualify for 50%) and to other organizations described in section 170(c) that do not qualify for the 50% limitation (codes 2, 6 and 7). A private foundation is any organization described in section 501 (c)(3) that is not a public charity or a private operating foundation. The other organizations that qualify for the 30% limitation are organizations such as fraternal societies and veterans' organizations. There is a special limitation on certain gifts of long-term capital gain property. A discussion of that special limitation may be found in Publication 526. "Income Tax Deduction for Contributions." Foreign organizations The organizations listed in this publication with foreign addresses are generally not "foreign organizations" but are domestically formed organizations carrying on activities in foreign countries. These organizations are treated the same as any other domestic organization with regard to deductibility limitations. Certain organizations with Canadian addresses listed may actually be "foreign organizations" to which contributions are deductible only because of tax treaty. With regard to these organizations in addition to the limitations on the amount of the deduction allowed by section 170 of the Code, the deduction may not exceed the amount allowed as a deduction under Canadian law computed as though the taxable income (in the case of a corporation) or adjusted gross income (in the case of an individual) from sources in Canada is the aggregate income. A deduction for a contribution to a Canadian organization (foreign) listed in this publication is unallowable if the contributor reports no taxable income from Canadian sources on the United States income tax return. Except as provided above, contributions made to a foreign organization are not deductible. DATA RECORD: Position(s) Contents 1-105 Organization Name 106 blank 107-136 City 137 blank 138-139 State 140 blank 141-147 Deductibility limitation codes (7) one digit codes 148 blank 149-168 Advance Ruling Expiration Date