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FUNDAMENTAL CONCEPTS• Other. Other categories of charitable organizations are: Organizations established to promote environmental conservancy 302 Organizations established to promote patriotism 303 Organizations that provide care for orphans 304 Organizations that facilitate student and cultural exchanges 305Organizations that promote, advance, and sponsor recreational andamateur sports 306 Organizations that maintain public confidence in the legal system 307Educational Organizations. Organizations that are considered educational forpurposes of the law of charitable giving 308 are:• Formal educational institutions, such as primary, secondary, and postsecondaryschools; colleges and universities; early childhood centers; andtrade schools. 309 These entities have a regularly scheduled curriculum, aregular faculty, and a regularly enrolled body of students in attendance atthe place where the educational activities are regularly carried on. 310• Other types of “formal” organizations, such as museums, zoos, planetariums,and symphony orchestras. 311• Organizations that have programs related to instruction or training ofindividuals for the purpose of improving or developing their capabilities.312 These entities include a wide variety of training organizations andstudy and research organizations.• Organizations that have programs related to instruction of the public onsubjects useful to the individual and beneficial to the community. 313 Theseorganizations provide a range of personal services, instruct the public inthe field of civic betterment, and (again) engage in study and research.302 See, e.g., Rev. Rul. 76-204, 1976-1 C.B. 152.303 See, e.g., Rev. Rul. 78-84, 1978-1 C.B. 150. It was held that an estate was entitled to a charitable contributiondeduction for the gift of assets to a trust “to be used solely and exclusively in fostering and promoting the causeof patriotism, loyalty and fundamental constitutional government in the United States of America, and in combatingsubversive activities, socialism and communism, including, if deemed advisable, assistance in theteaching of the principles of conservatism in public affairs among college and high school students.” Buder v.United States, 7 F.3d 1382 (8th Cir. 1993). The government argued that the trustees of the trust had discretionto dispense funds to organizations that engage in lobbying and political campaign activities, which might precludethe organization from qualifying as a charitable organization (see the text accompanied by notes 220,221); the court found that contention “cramped” and it “decline[d] to set a standard that is so rigorous that theaverage testator who is attempting to make a charitable donation will fail to meet it.” 7 F.3d at 1386.304 See, e.g., Rev. Rul. 80-200, 1980-2 C.B. 173.305 See, e.g., Rev. Rul. 80-286, 1980-2 C.B. 179.306 Hutchinson Baseball Enterprises, Inc. v. Commissioner, 73 T.C. 144 (1979), aff’d, 696 F.2d 757 (10th Cir.1982).307 Kentucky Bar Foundation, Inc. v. Commissioner, 78 T.C. 921 (1982).308 The law underlying these categories is discussed in Tax-Exempt Organizations ch. 7.309 Reg. § 1.501(c)(3)-1(d)(3)(ii)(1).310 IRC § 170(b)(1)(A)(ii).311 Reg. § 1.501(c)(3)-1(d)(3)(ii)(4).312 Reg. § 1.501(c)(3)-1(d)(3)(i).313 Id. 100

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