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

 

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.