Exempt Organizations Technical Guide›TG 3-22: Termination of Private Foundation Status - IRC Section 507›Table of Contents
Abatement of Taxes
0324 Publ 5614 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
(1) The IRS may at its discretion abate the unpaid portion of Section 507(c) tax
imposed, if:
a. The private foundation distributes its net assets to one or more
organizations described in Section 170(b)(1)(A) (other than in clauses (vii) or (viii), each of which has been in existence and so described for a continuous period of at least 60 calendar months, or
b. Effective assurance is given to the IRS that the assets of the organization
which are dedicated to charitable purposes will, in fact, be used for charitable purposes. See Treas. Reg. 1.507-9.
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