United Cancer Council, Inc. - Page 100

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               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 firm                    




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