Register of Wills for Baltimore City v. Cook 241 Md. 264, 216 A.2d 542 (1966) Cook had a will that created three trusts: The first was to use $10k to lobby for the passage of the Equal Rights Amendment. The second was to use $25k to aid women in Maryland. The third was to use the rest of the estate to further the cause of women's equality. All three trusts were held by trustees named Zetzer and Brown. Cook died. Her brother challenged the validity of the bequests. The resulting settlement gave $380k total to the trusts. The Maryland Department of Taxation stepped in and ordered the trusts to pay estate taxes on the $380k. Zetzer and Brown objected on the basis that these were charitable trusts and therefore exempt from taxes. The Tax Court found that the trusts were tax-exempt charitable trusts. Maryland appealed. Maryland argued that the bequests are not to a trust, "organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes." Instead they are intended for lobbying efforts, which are not tax-exempt. The Appellate Court affirmed. The Appellate Court found that the primary purpose of all the trusts was the elimination of discrimination against women. The Appellate Court found that if a trust is essentially charitable in nature, it is still charitable even though one of its purposes is to endeavor to effectuate a change in existing law. Basically, in order to be a charitable trust you have to be primarily organized for a charitable purpose. You don't have to have 100% of the trust money going to charitable purposes. At the time, the Federal Government did not consider lobbying efforts to change laws to be a charitable purpose. Eventually lobbyists convinced them to change their minds...