The Tax Law of Charitable Giving. Bruce R. Hopkins

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       Other. Other categories of charitable organizations are organizations established to promote environmental conservancy,336 organizations established to promote patriotism,337 organizations that provide care for orphans,338 organizations that facilitate student and cultural exchanges,339 organizations that promote, advance, and sponsor recreational and amateur sports,340 and organizations that maintain public confidence in the legal system.341

       Formal educational institutions, such as primary, secondary, and postsecondary schools; colleges and universities; early childhood centers; and trade schools.343 These entities have a regularly scheduled curriculum, a regular faculty, and a regularly enrolled body of students in attendance at the place where the educational activities are regularly carried on.344

       Other types of formal organizations, such as museums, zoos, planetariums, and symphony orchestras.345

       Organizations that have programs related to instruction or training of individuals for the purpose of improving or developing their capabilities.346 These entities include a wide variety of training organizations and study and research organizations.

       Organizations that have programs related to instruction of the public on subjects useful to the individual and beneficial to the community.347 These organizations provide a range of personal services, instruct the public in the field of civic betterment, and (again) engage in study and research.

       Churches, synagogues, and similar places of worship349

       Conventions and associations of churches350

       Integrated auxiliaries of churches351

       Church-run organizations, such as schools, hospitals, orphanages, nursing homes, publishing entities, broadcasting entities, and cemeteries

       Religious orders

       Apostolic groups352

       Missionary organizations

       Bible and tract societies

      The courts and the IRS traditionally have been reluctant to rule on whether an organization is a church or the like or a religious entity, if only because of concern about constitutional law constraints. This reluctance is dissipating, however, and the IRS and the courts are developing criteria for defining churches and other religious organizations.

       Organizations that are engaged in scientific research354

       Organizations that are otherwise operated for the dissemination of scientific knowledge (such as publishing entities)355

      Consequently, the organizations that are eligible charitable donees for purposes of the law of charitable giving are those that are charitable in the common law sense (most of which have been rendered charitable by statute, regulation, or IRS ruling) and those that have been encompassed by statutory definition.

       A trust created for the benefit of an aged clergyman and his spouse was held to be a private trust that did not involve exempt activities, irrespective of the fact that the two beneficiaries served were needy.366

       A trust the purpose of which was to pay a

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