This is a matter of legal interpretation, Michael. Generally speaking, gifts to student groups and clubs are NOT countable or receiptable. The exception is those groups that serve a primarily educational purpose. And this is where legal opinion comes in. At Duke University, Counsel ruled that only six of our groups qualified as serving educational purposes. the remaining 185 did not. At NC State, no gifts to student groups were processed as charitable - at least not when I was there.
I am attaching IRS material for review by your attorney. With thanks to Alan Hejnal who shared much of this previously. Also, one of the referenced IRS websites is under reconstruction so the original document is not available.
John
John H. Taylor
Principal
John H. Taylor Consulting, LLC
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