Junior Associate From: Senior Partner Date: February 23, 2017 Re: Financing Parochial Schools The Catholic parish I belong to operates a grade...

To:       Junior Associate

From:   Senior Partner

Date:   February 23, 2017

Re:       Financing Parochial Schools

The Catholic parish I belong to operates a grade school.  The annual cost of the school is just over $5,000 per student, but tuition is only $3,000.  The parish can no longer afford to support the school under these circumstances.  The parish finance council has proposed a plan that involves increasing tuition to $4,000 per student and giving enrollment preference to families that pledge to donate at least $2,000 per child per year through the Sunday collection.  Children of families that pledge a lesser amount (or no contribution at all) will be admitted only to the extent that there are openings, based on a budget that includes tuition and school family pledges.  Families that fail to fulfill their pledges will not be allowed to enroll their children in subsequent years.

One of the members of the council asked if this arrangement will affect the families' ability to claim a charitable deduction for their Sunday contributions.  Please research this issue and let me know if there are any problems. If there are guidelines, how strict are they; that is, do the courts or the IRS indicate that there is some wiggle room?

Please submit a memo in the form and as discussed and analysis.  In your memo, be sure to cite statutes, regulations, cases and other authorities in the proper manner, for example, according to the specific citation or regulation, you must show the specific policy to identify the question and write some explanation by yourself. Grammar and spelling count. The memo is divided into five parts, summary, fact, issue, discussion and analysis, conclusion. Please search the database via IRS,RIA checkpoint, LexisNexis Academic and Westlaw's Campus Research.

MEMOTo: Senior PartnerFrom: Junior EstateDate: March 1, 2017Re: Arrangement effect on the families’ ability to claim a charitable deductionSummaryThe Catholic parish has found it difficult...