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The J. S. Bach Foundation is a non-profit charitable institution dedicated to give musical education to children in elementary schools. There is a provision in the document that formed the Foundation which states that upon the dissolution of the Foundation, its assets, which consist primarily of musical instruments, may be donated to the different schools for which it provides music education. Would this provision affect the Foundation's request for tax exemption and how? If the provision stated that upon dissolution of the Foundation its assets would be sold at auction and the proceeds of that auction returned to unique donors to the Foundation, would this alternative provision affect the Foundation's request for tax exemption and how?
The IRS agent insists that the payments be prepaid income subject to tax in the year of receipt. Your client believes that the amounts involved are customer deposits. Writ
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