Originally published on Forbes.com Aug 20th, 2013
Benjamin Franklin famously wrote that nothing is certain except death and taxes. These days, it seems, maybe not even those. In a previously unreported action, on May 10th, the Internal Revenue Service revoked the long-held charitable tax exemption of the Life Extension Foundation Inc., an organization dedicated to denying the certainty of death. The Foundation is contesting the revocation in a lawsuit filed on August 7, 2013 in the Federal District Court for the District of Columbia. (The revocation is available in redacted form here as PLR 201331008. )
About The Life Extension Foundation
The Life Extension Foundation is a substantial organization. According to its 2009 Form 990 (the latest available on Guidestar), it had assets of over $25 million and netted more than $3 million on revenue of more than $18 million that year. From those funds it supported some enterprises that would warm the coldest heart of a Larry Niven or Robert Heinlein fan:
The Stasis Foundation received $5 million to continue its development of a state-of-the-art facility where DNA will be stored by those who choose cryopreservation.
21st Century Medicine, a for-profit company, received $3.5 million. The company is an emerging leader in living systems preservation technology.
Suspended Animation received $1.1 million. SA stabilizes the human body cells immediately after death and transports the deceased to a cryogenic storage site. (Before you sign up you might want to read Larry Niven’s A World Out of Time to reflect on the possibility of a dystopian future State which is unkind to corpsicles )
The IRS Problem With Life Extension Foundation
The IRS’ problem with the Foundation is, however, an entirely worldly one: it asserts the membership organization’s operations seem to be too entwined with the for-profit Life Extension Buyers Club. Members of the Foundation receive discounts on health supplements and the Buyers Club pays royalties to the Foundation. The origin of this arrangement goes back to the 1990s when the Florida Cryonics Association (the original name of the Foundation) moved some commercial operations to a for-profit company.
All in all, in the view of the IRS, the Foundation is still too entangled in profit making activities. In the revocation, it writes:
…. the Foundation operates to a more than insubstantial extent for the non-exempt purpose of aiding in the sale of nutritional supplements, publications, and blood testing services by a for-profit entity.
The IRS also raised concerns about the independence of the foundation’s grant-making. The Foundation had no written grant application form and no published criteria for grant selection, the IRS complained. Moreover, Saul Kent, the founder of the Foundation and major shareholder of the Buyer’s Club, serves on the boards of companies that have received annual grants from the Foundation. As this old Los Angeles Times article reports, Kent is a longtime advocate of cryonics who received national attention in the late 1980s when he had his late mother’s head surgically removed for freezing.
It almost seems now like the organization is being punished for being too successful—in raising money and selling memberships, that is, not (so far as we know) in extending life. Still, the IRS has raised some legitimate concerns. It will be interesting to see how this case plays out. I hope I live long enough to see the resolution.
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