105. Shirley is the executive director of a nonprofit, 501(c)(4) advocacy organization, the Coalition to Suppress Gun Violence. As a c(4), she recognizes that donors to her organization may not take a charitable deduction on their federal income taxes for donations made to the Coalition. With board approval, she decides to incorporate the Coalition to Suppress Gun Violence Foundation, and apply for c(3) federal tax-exempt status, solely for the purpose of having a conduit for her stakeholders to make tax-deductible donations, with the understanding that all donations made to the c(3) will be funneled directly into the c(4) dollar for dollar.
a. Is the behavior of Shirley ethical?