Exempt Organizations Technical Guide›TG 62: Excise Taxes on Taxable Expenditures – IRC Section 4945›Table of Contents
C. Section 507 Termination and Other Sanctions
Publication 5590 — Exempt Organizations Technical Guide TG 62: Excise Taxes on Taxable Expenditures under IRC 4945 · 2026-10-03 edition · updated 2026-10-04 · United States
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(1) If a private foundation willfully and repeatedly or willfully and flagrantly violates
Section 4945 (or any of the other provisions of Chapter 42), the IRS may terminate its private foundation status pursuant to Section 507(a)(2).
(2) Hence, such private foundation may be subject to the termination tax imposed by
Section 507(c).
(3) In addition, a private foundation or foundation manager may be liable for the tax
under Section 6684 in the amount equal to the tax under Section 4945. See, for example, Thorne v. Commissioner, 99 T.C. 67 (1992); cf. Larchmont Foundation, Inc. v. Commissioner, 72 T.C. 131 (1979), vacated and remanded, 659 F.2d 1085 (7th Cir. 1981).
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