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governing the organization's operations, and makes decisions in advancement of the organization's mission and within the scope of the entity's governing documents.17.1

      (c) IRS Ruling Policy

       p. 102. Insert as first complete paragraph:

      1 17 This aspect of fiduciary responsibility principles may come into play where the beneficiary is another tax‐exempt organization. For example, a court held that a trustee of a charitable trust breached his duty as a trustee by refusing to execute documents required to effect distributions of funds to another charitable entity in its capacity as a beneficiary of the trust (Cook v. Marshall, 2019 WL 917598 (E.D. La. 2019)). Likewise, a court held that the trustees of a supporting organization (see § 12.3(c)) breached their duty of loyalty to the supported organization in a variety of ways (Cohen v. Minneapolis Jewish Federation, 286 F. Supp. 3d 949 (W.D. Wis. 2017)), with this court subsequently holding that the fees and costs owed to the supported organization must be paid by the trustees of the supporting organization personally and that these trustees must be removed and replaced (Cohen v. Minneapolis Jewish Federation, 346 F. Supp. 3d 1274 (W.D. Wis. 2018)). These opinions were affirmed (776 Fed. Appx. 912 (7th Cir. 2019)).

      2 17.1 In general, Hopkins, Legal Responsibilities of Nonprofit Boards, Third Ed. (BoardSource, Washington, D.C.: 2019).

      3 89.1 Priv. Ltr. Rul. 202010025.

        § 6.2 Public Policy Doctrine (b) Race‐Based Discrimination

        § 6.3 Collateral Concepts (a) Requirement of Charitable Class (i) Illegal Activities

      (b) Race‐Based Discrimination

       p. 118, third paragraph, fourth sentence. Delete and substitute:

       p. 119, fourth line. Move footnote to follow guidelines.

       p. 119, note 72. Insert before last period:

      , as modified by Rev. Proc. 2019‐22, 2019‐22 I.R.B. 1260.

      (a) Requirement of Charitable Class

       p. 126, last complete paragraph. Insert as last sentence:

      The IRS determined that an organization could not be exempt because it engaged in illegal activities, which apparently were activities to obstruct administration of the revenue laws, as detailed in a plea agreement entered into by its executive director (Priv. Ltr. Rul. 201924018).

       p. 135, last paragraph. Insert as last sentences:

      1 69.1 Rev. Proc. 2019‐22, 2019‐22 I.R.B. 1260.

      2 143.1 Priv. Ltr. Rul. 201911016.

      3 217.1 Priv. Ltr. Rul. 201615018.

      4 217.2 Priv. Ltr. Rul. 201917008.

      5 217.3 Priv. Ltr. Rul. 201940008. See § 25.5(c).

        § 7.2 Relief of Distressed (b) Disaster Relief Programs

        § 7.4 Provision of Housing

        § 7.6 Promotion of Health (a) Hospital Law in General (b) Additional Statutory Requirements for Hospitals

        §

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