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Donors who contribute financially to certain charitable, educational, scientific, and religious organizations may receive tax deductions for their contributions. Although the reasons the government foregoes these taxes are debated, the most widely accepted explanation is that the government is subsidizing the charitable organizations in return for the tangible and intangible societal benefits they provide. Because it is imperative that society receive the benefits the government has subsidized, the analysis and improvement of Internal Revenue Service (IRS) regulations pertaining to charitable organizations is a significant endeavor. According to the IRS, these organizations are divided into “public charities” and “private foundations.” The public charities defined in Internal Revenue Code § 509(a) include universities, churches, hospitals, museums, and ballet companies, and generally are engaged in “inherently public activities,” meet one of several public support tests, or support one of the above-noted organizations. These support requirements each allow for some form of supervision by the general

Best Supporting Actor: Refining the 509(a)(3) Type 3 Charitable Organization