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  • 1.  Donor sponsoring student

    Posted 2 days ago

    I searched through the archives and found almost the exact question I wanted to ask from 2019, but there were no responses/answers back then.

    We have a donor interested in "sponsoring" a student to golf in our Golf Tournament by paying the standard amount ($400) associated with an individual golfer. This offering currently has a gift/non-gift split of $200/$200. Since the donor is neither choosing the beneficiary nor receiving any benefit, would the entire $400 be considered a charitable donation? (sources appreciated)

    Thanks!



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    Russel Heskin
    University of La Verne
    rheskin@laverne.edu
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  • 2.  RE: Donor sponsoring student

    Posted 2 days ago
    This would fail the IRS test o. Size of charitable class. You should check with counsel but I do not see a gift here.

    John


    John Taylor Principal, John H. Taylor Consulting, LLC 919.816.5903 Big ideas; small keyboard





  • 3.  RE: Donor sponsoring student

    Posted 14 hours ago
    Russel, I just realized that I had not sent a followup note as I had intended.

    The IRS's concern over charitable class has been documented for half a century. They are concerned that donations are available only to a limited few. While IRS Publication 526 discusses the non-deductibility of gifts directed for the benefit of specific individuals, the IRS has also ruled that donations to a charity must benefit the "community" at large. Here is a snip from page 7 of IRS Publication 5781, Exempt Organizations Technical Guide:

    image.png
    If your organization had a "Student Emergency Fund" that donors could give to and any student could apply for, that would be okay. However, covering golf tournament fees probably would not qualify as an emergency.

    John

    John H. Taylor, Principal
    John H. Taylor Consulting, LLC
    2604 Sevier Street
    Durham, NC     27705

    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987


    On Wed, Jul 8, 2026 at 8:11 PM John Taylor <johntaylorconsulting@gmail.com> wrote:
    This would fail the IRS test o. Size of charitable class. You should check with counsel but I do not see a gift here.

    John


    John Taylor Principal, John H. Taylor Consulting, LLC 919.816.5903 Big ideas; small keyboard





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