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Question - The board of directors of BLACK Pearl, Inc., a private foundation, consists of Alice, Beth, and Carlos. They vote unanimously to provide a $250000 grant to Mark, their business associate. The grant is to be used for travel and education and does not qualify as a permitted grant to individuals (i.e., it is a taxable expenditure under 4945). Each director knows that Mark was selected for the grant because he is a friend of the organization and that the grant is a taxable expenditure.

a. Calculate the initial tax imposed on Black Pearl.

b. Calculate the initial tax imposed on the foundation manager (i.e., board of directors).

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