X-Message-Number: 9863
Date: Sat, 6 Jun 1998 14:02:03 -0400 (EDT)
From: Charles Platt <>
Subject: Trusts

Robert Ettinger expresses curiosity about CryoCare's history of
negotiations for tax-exempt status. There's no secret about this;  it was
reported a couple of years ago in CryoCare Report, and the text is readily
available on our web site at www.cryocare.org. 

CryoCare was advised by attorneys at Ernst and Young that since we are in
a "fee for service" business (i.e. offering the service of freezing people
in exchange for specific, standardized fees) it would be unwise for us to
seek tax-exempt status under section 501(c)3 of the federal tax code.
Opinions on this subject vary, but we chose to take the advice and
applied, instead, for tax-exempt status as a cemetery association under
section 501(c)13. After various hearings (conducted by IRS officials, not
in court) the application was denied on the grounds that our purpose is to
reanimate our patients and restore them to life; whereas a cemetery
association's purpose is to store human remains after (permanent) death.
In other words, the IRS disallowed the application on the grounds that
cryonics might work! 

Courtney Smith spent a considerable amount of time and money pursuing 
this issue. We have not given up on it, but there is no further progress 
to report at this time. Currently, CryoCare remains nonprofit but not 
tax-exempt.

Regarding individual trusts, CryoCare's publicly stated position has
always been that the money that belongs to you while you're alive should
still belong to you (in whatever way is legally feasible) after legal
death, and should be applied exclusively to your own reanimation, unless
the reanimation turns out to be impossible, in which case the money may be
used in other ways predetermined by its original owner. CI (and, I
believe, Alcor) prefers to pool all the money formerly owned by individual
patients. This of course is done with the full prior knowledge and 
understanding of people who sign up for cryopreservation on this basis.

--Charles Platt
CryoCare Foundation

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