Internal Revenue Bulletin:  2008-1 

January 7, 2008 

Announcement 2008-1

Cumulative List of Announcements Relating to Section 7428(c) Validation of Certain Contributions Made During Pendency of Declaratory Judgment Proceedings from January 1, 2007 through December 31, 2007.


The following is a cumulative listing of names of organizations that are presently challenging, under section 7428 of the Internal Revenue Code, the revocation of their status as organizations entitled to receive deductible contributions in declaratory judgment suits in the Tax Court, the United States District Court for the District of Columbia, or the United States Court of Federal Claims. The purpose of this announcement is to inform potential donors to these organizations of the protection under 7428(c) for certain contributions made during the litigation period.

Protection under section 7428(c) of the Code begins on the date that the notice of revocation is published in the Internal Revenue Bulletin and ends on the date on which a court first determines that an organization is not described in section 170(c)(2), as more particularly set forth in section 7428(c)(1). In the case of individual contributors, the maximum amount of contributions protected during this period is limited to $1,000.00, with a husband and wife being treated as one contributor. This protection is not extended to any individual who was responsible, in whole or in part, for the acts or omissions of the organization that were the basis for the revocation. This protection also applies (but without limitation as to amount) to organizations described in section 170(c)(2) which are exempt from tax under section 501(a). If the organization ultimately prevails in its declaratory judgment suit, deductibility of contributions would be subject to the normal limitations set forth under section 170.

I. Notice of Disposition of Declaratory Judgment Proceedings under Section 7428

This announcement serves notice to donors that on January 5, 2007, the United States Tax Court entered a decision accepting the agreement of the parties regarding the organization described below. Pursuant to the Decision, the organization listed below is described in section 501(c)(3) and is recognized as exempt from tax under section 501(a) but is classified as a private foundation under section 509(a).

Org. Name City State
Michael and Laura Gallop Family Foundation Agoura Hills CA

II. Notice of Disposition of Declaratory Judgment Proceedings Under Section 7428

This announcement serves notice to donors that on August 17, 2007, the United States Court of Appeals for the Fifth Circuit dismissed the case involving the below-referenced organization. The organization listed below is not recognized as an organization described in section 501(c)(3) and is not exempt from tax under section 501(a) and is not an organization described in section 170(c)(2).

Org. Name City State
Rameses School of San Antonio, Texas San Antonio TX

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