Pigeon, Inc., a § 501(c)(3) organization, received support from the following sources.
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Governmental unit A for services rendered
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$ 6,300
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Governmental unit B for services rendered
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4,500
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Fees from the general public for services rendered (Each payment was of $100)
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75,000
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Gross investment income
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39,000
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Contributions from disqualified persons
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26,000
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Contributions from other than disqualified persons (Each gift was of $50)
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160,000
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Total support
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$310,800
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a. Does Pigeon satisfy the test for receiving broad public support? Why or why not?
b. Is Pigeon a private foundation? Be specific in your answer.
c. Arnold Horn, Pigeon's treasurer, has asked you to advise him on whether Pigeon is a private foundation. Write a letter to him in which you address the issue. His address is 250 Bristol Road, Charlottesville, VA 22903.