Reg. § 1.507-4 Imposition of tax.
(a) General rule Section imposes on each organization the private foundation status of which is terminated under section a tax equal to the lower of:
(1) The amount which such organization substantiates by adequate records (or other corroborating evidence which may be required by the Commissioner) as the aggregate tax benefit (as defined in section ) resulting from the section status of such organization, or
(2) The value of the net assets of such organization.
(b) Transfers not subject to section 507(c) Private foundations which make transfers described in section or (2) are not subject to the tax imposed under section with respect to such transfers unless the provisions of section become applicable. See , -2(a)(6) and 1.507-3(d).
[T.D. 7233, 37 FR 28161, Dec. 21, 1972]