Reliance on Distributee’s Ruling Letter

(1) Under Treas. Reg. 1.507-2(a)(2), an organization seeking to terminate its

private foundation status under Section 507(b)(1)(A) may rely on a final ruling or determination letter issued to a potential distributee organization that such distributee is described in Section 170(b)(1)(A)(i) - (vi) and (ix) until public notice is given of revocation of the distributee’s classification or public notice is given that grantors may be affected pending verification of the continued foundation status classification of the distributee except where the distributor or grantor:

a. Had knowledge that the distributee’s foundation classification letter was

revoked, or

b. Was in part responsible for, or was aware of, the act, the failure to act, or

the substantial and material change on the part of the organization which gave rise to the revocation of the distributee’s determination letter. See Rev. Proc. 2024-5, 2024-1 I.R.B. 262 (updated annually).