Vanderbilt Law Review

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The number and importance of tax exempt organizations has steadily grown in the past decade to the point where there were over 45,000 as of the beginning of 1963, as compared with 12,000 at the end of 1952. "Unquestionably, the economic life of our nation has be-come so intertwined with foundations that unless something is done about them, they will hold a dominant position in every phase of American life." This, according to the Patman Report, is because"multi-million-dollar foundations have replaced the trusts which were broken up during the Theodore Roosevelt administration." Both the Patman Report and the increased activity of the Internal Revenue Service in its audit program demonstrate the increased interest in the tax exempt field. In spite of this, however, not a great deal has been written in this area in recent years. This note will attempt to set forth and clarify the tests and requirements established by the Internal Revenue Code of 1954, and the Treasury Regulations issued there under, by which an organization may receive, and maintain tax exempt status, and by which gifts to such organizations will qualify as deductible charitable contributions.

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