- 7 - $1,554,244.00. Simultaneously with the foregoing contribution, petitioner and the Laphams entered into a charitable gift annuity agreement whereby petitioner agreed to pay the Laphams an annual annuity of $116,568.32 over the joint lives of the donors, payable in quarterly installments of $29,142.08. The obligation is unsecured. The Administrative Process In a Form 1023, Application for Recognition of Exemption, received by the Internal Revenue Service (IRS) in July of 1999, petitioner sought recognition as a section 501(c)(3) tax-exempt organization and as a section 509(a)(3) supporting organization. Therein petitioner indicated that it would “support THE AMERICAN ENDOWMENT FOUNDATION * * * and other qualified charitable organizations by receiving and administering funds for the benefit of THE AMERICAN ENDOWMENT FOUNDATION.” Petitioner further explained that it would be “operated in connection with” AEF and would “receive[] donations which would otherwise be the subject of fundraising activities conducted by the supported organization.” The Form 1023 described petitioner’s sources of financial support as “Donations from the Lapham family and its friends, including individuals and businesses” and “Interest on investments”. The statement of revenue and expenses included with the application reflected gifts, grants, and contributionsPage: 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