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The IRS citation can be found on our technical page along with all other relevant citations at http://www.communityhealthtraining.org/TimeshareandIRS.htm We began as a 501(c)3 and changed to a private foundation. The specific legal difference is that a donor may deduct up to 50% of their annual income for a single donation to a 501(c)3, but may deduct only up to 30% for a private foundation. All other conditions of charitable donations apply equally.