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Revenue Ruling

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 Rev. Rul. 78-77

1978-1 C.B. 378

Sec. 4941

Full Text

Rev. Rul. 78-77

Advice has been requested whether the transaction described below is an act of self-dealing under section 4941(d)(1)(A) of the Internal Revenue Code of 1954.

A private foundation purchased property from a testamentary trust. A banking institution is the trustee of both the private foundation and the trust.

Held, the purchase is not an act of self-dealing under section 4941(d)(1)(A) of the Code merely because the banking institution is the trustee of both the private foundation and the testamentary trust because the trust is not a disqualified person within the meaning of section 4946(a) of the Code with respect to the foundation.