The Court of Appeals for the District of Columbia Circuit has adopted a new position of the Internal Revenue Service that the governing instruments of an organization seeking to qualify as a Type II supporting organization must list a class of public charities that are “readily identifiable.” It has affirmed a District Court decision that denied supporting organization status to an applicant but on entirely different grounds. The Polm Family Foundation was established under Maryland law to “conduct and support activities for the benefit of, to perform the functions of, and/or to carry out the purposes of” public charities that “support, promote and or perform public health and/or Christian...