Reg. § 1.509(c)-1 Status of organization after termination of private foundation status.
(a) In general For purposes of part II of subchapter F of this chapter, an organization whose status as a private foundation is terminated under section shall be treated as an organization created on the day after the date of such termination. An organization whose private foundation status has been terminated under the provisions of section will, if it continues to operate, be treated as a new organization and must, if it desires to be classified under section , give notification that it is applying for recognition of section status pursuant to the provisions of section .
(b) Effect upon section 507(d)(1) If the private foundation status of an organization has been terminated under section and the regulations thereunder, and:
(1) Such organization does not continue at all times thereafter to meet the requirements of section (1), (2), or (3) (and is therefore no longer excluded from the definition of a private foundation); and
(2) The status of such organization as a private foundation is thereafter terminated under section
then the tax imposed under section upon the aggregate tax benefit (described in section ) resulting from section status shall be computed only upon the aggregate tax benefit resulting after the date on which the organization again becomes a private foundation under subparagraph (1) of this paragraph.
[T.D. 7212, 37 FR 21924, Oct. 17, 1972]