[Snowball]

Hello, I am using Becker textbook and having trouble to understand two ideas. Does anyone can explain?

R4-44 B. b. Transactions between partner and partnership

Gains (directly or indirectly) between a controlling partner (over 50% interest) in capital or profits) and his controlled partnership, or between two controlled partnerships, from the sale or exchange of assets shall be treated as ordinary income if the property is depreciable in the hands of the transferee or if the property is not a capital asset in the hands of the transferee.

What does the last part “if the property is depreciable in the hands of the transferee or if the property is not a capital asset in the hands of the transferee” mean?

R3-57 Exempt Organizations

The following four distinct categories are not private foundations

a. Maximum (50% type) charitable deduction donees

b. Broadly publicly-supported organizations receiving more than 1/3 of their annual support from members and the public and less than 1/3 of their annual support from members and the public and less than 1/3 from investment income and unrelated business income.

c. Supporting organizations

d. Public safety testing organizations

What does “a” mean? It is a kind confusing explanation. Also, how is “c” different from feeder organizations?

Becker also says that to be a tax exempt organization, an entity must not be a private foundation and not participate lobbying activities. However, aren’t private foundation a type on tax exempt entities that just have fewer tax benefit than public charities?