- 84 - been fulfilled. An audience selected because of its interest in cancer and other health related issues also indicates the reason for the mailing is public education. Conversely, if the message is a direct appeal for funds and sent to individuals based on their ability to contribute money, then the fundraising function has been fulfilled. All circumstances surrounding a mailing with regard to content and audience are examined together to arrive at the joint allocation of costs for each mailing between public education and fundraising. In 1987, the Council incurred joint costs of $9,705,721 for informational materials and activities that included fundraising appeals. Of those costs, $4,306,377 was allocated to public education and $5,399,344 was allocated to fundraising. Expenses related to both * * * [prospect mailings and housefile mailings] were allocated to public education and fundraising based on the relative content and intent of each mailing without regard to intended audience. NCIB did not accept petitioner’s allocations of its 1985, 1986, and 1987 mailing campaign expenses to public education. In preparing its reports on various charitable organizations, NCIB generally accepted the financial information contained in a charitable organization’s financial statements, except for the charitable organization’s allocation of its fundraising appeal expenses to exempt purpose activity. While aware of SOP 78-10 and SOP 87-2, NCIB examined the reasonableness of the allocations made by the charitable organization. For example, as indicated above, in a report it issued on petitioner, NCIB concluded that petitioner’s fundraising expenses for 1985 equaled about 97.7 percent of the related contributions petitioner received. With respect to petitioner’s 1988 mailing campaign “joint expenses”, petitioner’s certified public accounting firmPage: Previous 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 Next
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