- 5 -
principal and the income thereof solely for the
public charitable and educational purposes of the
Corporation; * * *
AEF operates a donor-advised fund program under which donors
are able to make recommendations regarding the charitable use or
beneficiary of their contributions. Such suggestions are
generally, but not necessarily, followed, as the organization is
not bound by any donor’s advice. The ultimate decision with
respect to the timing, manner, or recipient of any distribution
lies with AEF.
During 1998, total contributions in the amount of $7,350,000
were received by AEF. The organization’s income was $650,000.
The Lapham Foundation
Petitioner finds its genesis in the Laphams’ intent to
return to their community of Northville, Michigan, a portion of
what they had received over the years as long-time residents and
community leaders. Petitioner was incorporated by Mr. Lapham as
a nonprofit corporation under the laws of the State of Michigan
on December 29, 1998. The articles of incorporation filed with
the State at that time provide:
The purpose of the Corporation is to operate
exclusively for the benefit of THE AMERICAN ENDOWMENT
FOUNDATION, a publicly supported organization, as
described in Internal Revenue Code Section 509(a)(1) or
(2), or, in the event THE AMERICAN ENDOWMENT FOUNDATION
loses its tax exempt status, substantially abandons
operations, or dissolves, for the benefit of additional
publicly supported organizations of the same class, by
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011