IRS Ruling on Smithsonian as a "Publicly Supported" Institution, 1970

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J. A. Tedesco, Chief, Rulings Section, Exempt Organizations Branch, Internal Revenue Service, on 8 December 1970, issues a ruling that reaffirms the 1966 IRS ruling that the Smithsonian is a "publicly supported" organization, as defined in section 170(b) (1) (A) (vi) of the Internal Revenue Code, not a "private foundation," as defined in section 509(a) of the Internal Revenue Code. The Tax Reform Act of 1969 provides that donors may deduct their contributions to a publicly supported institution in amounts up to 50% of the donors contribution base for the taxable year.


  • Littleton, John W
  • Powers, Peter G
  • Tedesco, J. A
  • United States Internal Revenue Service
  • Office of the General Counsel


Smithsonian Legal Documents

Legal document information

  • Title 26, Internal Revenue
  • Memorandum


See also memo from Smithsonian General Counsel Peter G. Powers on 11 December 1970, and the earlier ruling from John W. Littleton, Internal Revenue Service, 29 June 1966.

Contained within

Smithsonian Institution Archives, Record Unit 99, Office of the Secretary, Records, 1970, Box 411, Folder General Counsel (Documents)

Contact information

Institutional History Division, Smithsonian Institution Archives, 600 Maryland Avenue, S.W., Washington, D.C. 20024-2520,




  • Income tax
  • Internal revenue law
  • Gifts
  • Income tax deductions for charitable contributions
  • Internal revenue
  • Memorandums
  • Federal Government, Relations with SI
  • Internal revenue--United States


United States

Physical description

Number of pages: 2; Page Numbers: 1-2

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