Revenue Ruling 83-104

Six hypothetical situations were presented concerning charitable donations to private schools. In situation 1, a private school charged tuition, which was waived if the child’s parents made a contribution to the school equal to the tuition. In situation 2, a private school solicited contributions from parents of applicants during the application and enrollment period. The parents of applicants were singled out for solicitation. Most parents contributed the suggested amount. The school did not charge tuition. In situation 3, a private school admitted a larger percentage of applicants whose parents contributed than of applicants whose parents did not contribute. In situation 4, a religious group ran a private school. The group solicited contributions from members, local churches, and nonmembers. However, most contributions came from parents of children attending the school. Parents normally contributed on a regular, established schedule. Students were not refused admittance based on their parents’ failure to contribute. In situation 5, a private school charged tuition and solicited contributions from parents of attending children. The solicitation materials indicated that the parents of students were singled out for solicitation. A contribution amount was suggested, but there was no unusual pressure to contribute. Other parties, such as former students, also contributed. In situation 6, a church operated a private school, attended by children of both members and nonmembers. The church received contributions from all members, which were placed in the general operating fund. Most members did not have children in the school and most of the church’s expenditures were non-school functions. The church solicited funds from members with children in the school in the same manner as from other members. Tuition was charged for nonmember children only.