The Internal Revenue Code subjects charitable trusts that are not exempt from tax to some of the same requirements and restrictions that apply to private foundations, if the trusts have any unexpired interests de­voted to charitable purposes for which a charitable deduction was allowed.  The aim is to prevent a trust of this nature from being used to avoid the requirements and re­strictions that apply to private foundations.

In this connection, a charitable purpose in­cludes a religious, educational, charitable, sci­entific, or literary purpose, a purpose to foster national or international sports competition (but only if there is no provision of athletic facilities or equipment), a purpose to prevent cruelty to chil­dren or animals, or a gift to or for the use of a state, a possession of the United States, or any political subdivision of the same, the United States, or the District of Columbia, when the gift is to be used exclusively for public purposes.

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