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OTHER ASPECTS OF DEDUCTIBLE GIVINGfurther the research project of a particular professor. Inasmuch as the universitylacked discretion over the use of the funds, the IRS concluded that it was only aconduit, so that the true donee was the professor. The IRS ruled that the gift wasnot deductible. 151 Similarly, an individual made a contribution to a missionaryfund that was intended to reimburse missionaries for approved expenses not coveredby amounts received from the missionaries’ parents, friends, relatives, orpersonal savings; the donor’s son was one of the missionaries. The IRS ruled thatcontributions to the missionary fund that were earmarked for a particular individualwould be treated as gifts to that individual and were not deductible. 152The pivotal test in this setting is whether the charitable organization receivingthe contribution has full control of the donated funds and discretion as totheir use, so as to ensure that the funds will be used to carry out the charity’sfunctions and purposes. Contributions are deductible unless they are distinctlymarked by the donor so that they may be used only for the benefit of a designatedindividual or are received by the charity pursuant to a commitment orunderstanding that they will be so used. 153For example, a corporation established a scholarship program, selecting theuniversities from which it drew a substantial number of its employees. The universitiesselected the recipients of the scholarship, although there was no employmentcommitment between the corporation and the scholarship recipients. TheIRS observed that, for purposes of determining that a contribution is made to orfor the use of a charitable organization rather than to a particular individual whoultimately benefits from the contribution, the organization must have full controlof the use of the donated funds, and the contributor’s intent in making the paymentmust be to benefit the organization, not the individual recipient. 154In another instance, students at a religious educational institution had theirtuition paid by “sponsors,” which in many cases were the students’ parents. Thesponsors signed a commitment form that set the contribution amount and the paymentschedule, and indicated the names of the sponsor and the student; space wasprovided on the payment envelopes for the student’s name. The form providedthat use of the contributions was “solely at the discretion of” the organization. TheIRS denied a charitable contribution deduction because deductibility requiresboth full control of the gift funds by the charitable organization and an intent bythe donor to benefit the charity and not a particular recipient. The agency concludedthat the commitment form and envelopes indicated that the paymentswere designated for the benefit of particular students. The control the school hadover the use of the funds was no different from the control any school has overtuition payments. 155151 Rev. Rul. 61-66, 1961-1 C.B. 19.152 Rev. Rul. 62-113, 1962-2 C.B. 10. See the discussion of Davis v. United States in § 3.1(a), text accompaniedby notes 26–32; Priv. Ltr. Rul. 9247030 (holding that a gift to a charitable organization was earmarked for anoncharitable organization).153 Rev. Rul. 62-113, 1962-2 C.B. 10.154 Rev. Rul. 68-484, 1968-2 C.B. 105.155 Rev. Rul. 79-81, 1979-1 C.B. 107. 376