Ethics Scenario #78: Summer Dreams Foundation

78. Bella is the chief financial officer (CFO) for the Summer Dreams Foundation, a 501(c)(3) whose mission is to send inner-city kids to summer camp in a bucolic, rural setting, who might otherwise not be able to afford this experience. The camp receives substantial revenue from a tree harvester who cuts down trees on the camp property and processes them into furniture products. Bella is wrestling with whether she should file a 990-T with the IRS, disclosing unrelated business income and paying a tax on it. Bella knows that the enforcement of UBIT laws is quite spotty, and the money that the organization would pay in taxes would be better spent on providing more kids with camp. Bella decides not to file the 990-T.

a. Is Bella’s behavior ethical?