- 9 -
Applicant will specifically provide that the
American Endowment Foundation shall receive one-third
of the support provided through the donor advised fund
to expand its representation in Southeastern Michigan.
The remaining two-thirds will support only qualified
charities of Northville, Michigan under the independent
determination of American Endowment Foundation’s board
of directors, based upon the non-binding
recommendations of the Applicants [sic] advisory
committee. * * *
* * * * * * *
The purpose to which the funds are put will represent a
projected $5,682 or 39.11% of the American Endowment
Foundation’s overall expenditures toward supplies,
postage, telephone and travel. Furthermore, these
funds will represent virtually the entire expenditure
by the American Endowment Foundation within the
Southeastern Michigan region.
The above suggests that petitioner intended to recommend to AEF
that one-third of its contributions to the donor-advised fund be
used to support activities in southeastern Michigan and two-
thirds be used to support charities in Northville, Michigan. As
discussed above, AEF is not bound by such recommendations.
With its Form 1023, petitioner submitted to the IRS a copy
of the organization’s bylaws. Pertaining to governance of
petitioner, the bylaws reiterated that there were to be at least
three directors, a majority of which could not consist of
disqualified persons under section 4946. The bylaws provided
that for purposes of conducting business, a majority of the
entire board would constitute a quorum, with a majority vote
thereof determining board action. The instrument further
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