Willful agreement to taxable expenditure

A foundation manager's agreement to a taxable expenditure is willful if it is voluntary, conscious, and intentional.  No motive to avoid the restrictions of the law or to incur any tax is necessary to make an agreement willful.  However, a foundation manager's agreement to a taxable expenditure is not willful if he or she does not know that it is a taxable expenditure.

 

 


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