private operating foundation

A private foundation described in Section 4942(j)(3), which expends its assets directly on activities and programs designed to support the foundations' specific charitable purpose. A gift to this type of foundation is generally entitled to the same income tax deduction as a gift to a public charity; for example, a donor's gift of cash to this type of foundation is deductible up to 50% of AGI. A POF is limited or constrained, however, by the prohibited transaction rules of Section 4940 et seq.