1jesusandjohnwayne
LillianFaderman
Gilgamesh 360x1000
1lookingforthegoodwar
lifeinmiddlemarch2
2theleastofus
2confidencegames
5confidencegames
12albion
1confidencegames
9albion
Tad Friend 360x1000
Margaret Fuller 2 360x1000
Stormy Daniels 360x1000
3theleastofus
Ruth Bader Ginsburg 360x1000
1madoff
Anthony McCann2 360x1000
4confidencegames
Thomas Piketty2 360x1000
1defense
399
Thomas Piketty1 360x1000
Mark V Holmes 360x1000
2jesusandjohnwayne
storyparadox2
1theleasofus
2lookingforthegoodwar
Edmund Burke 360x1000
storyparadox3
8albion'
7albion
7confidencegames
1falsewitness
14albion
2falsewitness
Margaret Fuller1 360x1000
Adam Gopnik 360x1000
199
2albion
2trap
13albion
Margaret Fuller5 360x1000
Margaret Fuller 360x1000
4albion
Storyparadox1
lifeinmiddlemarch1
1gucci
1trap
Learned Hand 360x1000
Margaret Fuller2 360x1000
10abion
2defense
2transadentilist
11632
1lafayette
2lafayette
Lafayette and Jefferson 360x1000
299
Maurice B Foley 360x1000
6confidencegames
3paradise
Spottswood William Robinson 360x1000
AlexRosenberg
Betty Friedan 360x1000
George F Wil...360x1000
3albion
3confidencegames
Margaret Fuller4 360x1000
Brendan Beehan 360x1000
1paradide
1empireofpain
1lauber
Office of Chief Counsel 360x1000
Richard Posner 360x1000
Mary Ann Evans 360x1000
11albion
Margaret Fuller3 360x1000
James Gould Cozzens 360x1000
3defense
Susie King Taylor 360x1000
499
Anthony McCann1 360x1000
Maria Popova 360x1000
6albion
Susie King Taylor2 360x1000
George M Cohan and Lerarned Hand 360x1000
1albion
2gucci
2paradise
Samuel Johnson 360x1000
5albion
Thomas Piketty3 360x1000
1transcendentalist

 

kelvin octa at Pexels

This was originally published on PAOO on July 15th, 2010.  After nearly a decade of blogging, this remains the funniest decision I have ever encountered.

Free Fertility Foundation v. Com 135 TC 2

I had originally thought of calling this “You Can’t Make This Stuff Up”, but I figured I’ll get in enough trouble without quoting Don Imus. Free Fertility Foundation v. Com 135 TC 2 sounds like something you might read in Onion, but it is a genuine tax court decision. I had noted its precursor back when I was not tax blogging and might have got around to it.

PLR 200736307 and related PLR 200737044 revoked the exempt status of a nameless organization whose charitable purpose was the provision of donated sperm to worthy women. The IRS (they don’t say how) determined that 88% of said sperm if you will excuse the expression, came from the same donor, who along with his father founded and ran the organization, The canned language of one of the rulings invites the organizers to apply to the Tax Court for declaratory judgment. Apparently they did.

So we are able to get details. Failure to obtain exempt status has not put the foundation under. You can get all the details on http://www.freedonr.com/. The donor catalog (which has one entry) has extensive information on the intellectual achievements of the donor including for example :

4th grade: 3rd place in school science fair with science project entitled “Using Red Cabbage Juice to Determine Acidity”.

I guess that is something that a prospective mom would want to know about.

At any rate the Tax Court went along with the IRS on this one. It boils down to his exempt purpose not benefiting a broad enough class of people. The petitioner claimed it was a very broad class indeed namely all women in the world capable of bearing children. The tax court thought the class somewhat more limited – namely women who want to bear his children. In prefacing their decision they did however make the following observation :

The free provision of sperm may, under appropriate circumstances, be a charitable activity.