Comment from Graham, John
John GrahamOpposeIndividual
Summary: John K. Graham, a tax attorney, argues that Example 3 of the Proposed Regulations is overbroad and creates an inappropriate chilling effect on organizations seeking the Single Identified Organization Exception. He suggests dropping Example 3 in favor of a rule that explicitly restricts distributions to internal use, arguing that board membership by a donor should not automatically disqualify a fund.
See attached file with comments on single identified organization exception.