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

 

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.