Notebook: March 19, 1997
Eating Clubs' Fund-Raising in Jeopardy
Princeton Prospect Foundation is appealing IRS ruling that revokes its tax-exempt status
The tax-exempt status of the Princeton Prospect Foundation (PPF), created to encourage academic pursuits at the 12 clubs, is being challenged by the Internal Revenue Service.
The foundation accepts tax-deductible donations for clubs' educational expenses. According to Howard Helms '56, the chairman of the foundation, the PPF annually contributes to each club a median $30,000 to defray expenses, with some clubs receiving more if they are undergoing major capital improvements. A recent IRS audit recommended revocation of the foundation's 501(c)3 status because not all expenditures were considered educational in nature. The foundation is appealing. A final ruling is expected in the fall.
In the eyes of the auditor, Helms said, the clubs are considered social institutions, like fraternities. The foundation is arguing that the clubs are educational institutions because they provide food service for more than half the university's juniors and seniors; the university would have to do this if the clubs did not exist.
The dispute also focuses on money used for such expenses as kitchen remodeling. The foundation has included food-service and building safety improvements as educational expenses. Social expenses, such as alcohol or painting tap rooms, do not qualify for foundation funding, Helms added.
There is a basic guideline of what can be done to the physical plant and be considered "educational," thereby qualifying for foundation funding, said foundation treasurer Gordon Harrison '68. "The clubs have learned over the years how to successfully apply" for foundation funds, he added.
At a recent meeting with the foundation's attorney, an IRS representative deemed that building safety, such as the installation of fire sprinklers, could be construed as educational, but items relating to food service could not.
The IRS must consider all expenditures educational for the foundation to retain its tax-exempt status, Helms explained. To prove its case, the foundation is citing previous cases the IRS has heard, as well as educational activities such as precepts and seminars held in the clubs. The foundation also is giving examples of links between the clubs and the university, such as the foundation's recent funding to extend Internet and phone connections between the university and some of the clubs.
The IRS also is looking into how the foundation monitors the way its money is spent. Currently, clubs submit a receipt or invoice to Harrison for approval. Harrison will provide the IRS with a statement of his procedures to answer this concern.
The foundation will keep its tax-exempt status while the case is decided. If the IRS rules against it, a letter will be issued requiring the foundation to immediately stop accepting tax-deductible contributions unless an appeal is filed in Tax Court.
The IRS also may decide the foundation is liable for back taxes. "The IRS case manager assured the Prospect Foundation that the IRS would not retroactively claim that any contributions were nondeductible. Persons can still make tax-deductible contributions to the Prospect Foundation as they have done in the past until such time as the IRS rules against us, if they do. The earliest that this could occur is September," Helms said.
Additionally, the IRS may require the foundation to restrict its projects to ones specifically related to education or to create a more formal process to review educational projects.
If current discussions regarding the appeal appear to be headed against the foundation, it most likely will submit its case to the national IRS office for "technical advice," said Helms. If the appeal is denied, the foundation will have to decide whether to schedule its day in tax court. But at this point, Helms said he remained "modestly optimistic" that an agreement between the IRS and the foundation will be reached.
The Many Sides of Edward Lear
Edward Lear was one of the most paradoxical personalities of Victorian England. As an artist and lifelong traveler, he painted beautiful landscape watercolors of the Mediterranean and Middle East. But he was also a master poet of nonsense rhymes, and it is for his limericks that he is best remembered. Rare and unusual examples of the limerick genre as well as original artwork and early editions of Lear's work are on display until April 20 at the Leonard L. Milberg ['53] Gallery for the Graphic Arts, in Firestone Library. Art and Nonsense: The Work and Play of Edward Lear (1812-1888) includes original drawings, watercolors, and illustrated books in the Limerick Collection recently presented to the library by Richard E. Buenger '44. The story behind the self-portrait shown here is that the artist overheard a fellow train passenger tell his children there was no such person as Edward Lear. The artist proved his existence by showing them the name tag in his hat.
In Memoriam
Frederick J. Almgren, Jr. '55, the Henry Burchard Professor of Mathematics, died February 5 in Boston of pneumonia as a complication of a bone-marrow transplant for myelodysplasia.
A major figure in the fields of geometry, geometric measure theory, and the calculus of variations, Almgren did research on the geometry of surfaces of least area, including those modeling soap films and soap-bubble clusters. He also worked on geometric evolution processes, such as those modeling the growth of snowflakes. Many of today's experts in these fields were taught by Almgren. He was the author of one book, Plateau's Problem, numerous research and expository articles, and a computer-generated mathematics video.
Born in Birmingham, Alabama, in 1933, Almgren studied engineering at Princeton, served as a naval aviator, and joined the Princeton faculty in 1962, the year he received his Ph.D. in mathematics from Brown University. He was a founder of the National Science and Technology Research Center for Computation and Visualization of Geometric Structures, in Minneapolis, and a member of its Minimal Surface Team.
The recipient of both Alfred P. Sloan and the John Simon Guggenheim fellowships, Almgren was a fellow of the American Association for the Advancement of Science. The Class of 1955 presented him its public-service award, and Brown's graduate school awarded him a medallion "for contributions to society." Survivors include his wife and coworker, Jean Taylor, of Rutgers, three children, and his mother.
Faculty File: Westergaard Composes with Inspiration and Perspiration
"I can't remember not wanting to write music," says Peter T. Westergaard *56, the William Shubael Conant Professor of Music and a composer of chamber music, opera, and orchestral works. "Happily, I don't experience the conflict between composing and teaching that some people complain of, because the thought processes are very similar. In both, you are puzzling about how to work out musical problems, how to clarify them, how to understand them. Rather than draining creative energy, teaching gives me all sorts of adrenaline. I love being taken off base by a student who asks a totally reasonable question that, somehow, I've never even thought about."
As for composing, he says, "We are brought up in a culture that believes in inspiration. I don't think that's a good model for creativity. Anyone can have an idea; the hard part is to develop the idea."
Westergaard teaches Music 205 and 206 (Species Counterpoint and Tonal Syntax), his two-part, sophomore-level course in music theory. Required of music majors, 205-206 uses Westergaard's text, An Introduction to Tonal Theory, first published in 1975 by W. W. Norton.
A slender man of medium height, with a shock of white hair and the slight stoop common to those who habitually carry briefcases, Westergaard in class is patient, encouraging, and unfailingly good humored. Leading an analysis of Mozart's A-major piano sonata, he darts about the room, scribbling notes on the board, popping up and down at the piano to play excerpts. "To understand this part you need a little arcane knowledge of dissonance and consonance-which of course, you have," he says. Playing another passage, he exclaims with obvious satisfaction, "That is pretty nifty counterpoint."
Westergaard teaches undergraduates to analyze, compose, and perform tonal music, which is based on the familiar, ordered hierarchy of seven pitches. But the music Westergaard himself composes is atonal, relying on the "12-tone" technique introduced by Arnold Schoenberg early in this century and associated more recently with Westergaard's Princeton colleague Milton Babbitt *42. Although his work is atonal, Westergaard sees himself as "a very traditional composer, addressing the same concerns that have occupied Western composers for the last eight centuries." Of his published works, probably "Variations for Six Players" (1963) and the chamber opera Mr. and Mrs. Discobbolos (after Edward Lear, 1966) are most widely performed. Mr. and Mrs. Discobbolos can be heard on his recent compact disc of that name (CRI, 1995). The Tempest (1990), an opera produced in 1994 at the Opera Festival of New Jersey, is Westergaard's most ambitious score to date; one reviewer declared it "brimming with magical imagination."
Westergaard composes at his home in Princeton, where he lives with his wife, Barbara, a writer and editor, and two basset hounds. He composes at the piano, using "a lot of paper." His pieces come together "very slowly," he says. "I work with a lump of musical material, squeeze it this way, pull it that, turn it over and over until I finally say, 'Aha! That's how it goes! My God, there is a simple way all these elements can fit together.' For me, there's always a high ratio of perspiration to inspiration."
When a piece is complete, Westergaard puts it on a computer using notation software, then prints out a score, which he revises several more times. It took him 20 years-and a lot of paper-to compose The Tempest. He remained committed to the project "because I'm crazy. Anyone who composes opera has to be, because it's so impractical." A good deal of the paper sacrificed was covered with words rather than music; because singing takes longer than speaking, Westergaard had to trim Shakespeare's play to about 40 percent of its original length.
But , he says, "The text was always beautiful, always fresh. I could never get tired of it."
He has, in fact, spent much of his professional life wrestling with words, whether German, French, Italian, or English. Westergaard has done English translations of several Mozart operas, as well as Weber's Der Freischütz, Beethoven's Fidelio, and Rossini's La Cenerentola. Most of these translations were performed by the Princeton University Opera Theatre. The Mozart and Rossini translations were also sung at the Opera Festival of New Jersey, cofounded by Westergaard and Michael Pratt, the conductor of the University Orchestra.
Westergaard, who grew up in Belmont, Massachusetts, began his musical career as a boy soprano in a choir in nearby Cambridge. Later, as an undergraduate at Harvard studying composition, he played the flute in various Boston orchestras, did some conducting, and "composed chamber music for friends." After graduating in 1953, he studied with Roger Sessions at Princeton, earning his M.F.A.; in 1956, and later with Wolfgang Fortner in Freiburg, Germany. Westergaard joined the faculty of Columbia in 1958, visited for a year at Princeton, taught at Amherst, and returned to Princeton permanently in 1968.
Academic life comes naturally to this fourth-generation professor. His great-grandfather and grandfather taught at the University of Copenhagen; his father, Harald Malcolm Westergaard, who emigrated from Denmark just before World War I, taught at the University of Illinois and then at Harvard.
Last March, the university community heard Westergaard's most recent composition, "Ringing Changes," composed in honor of the 250th Anniversary and performed by the University Orchestra in Richardson Auditorium. He describes it as "a celebratory piece, which includes dance music-waltzes, and some up-tempo swing-and plenty of bells." The title refers to the old English practice of "change ringing," in which a set of church bells is rung repeatedly, but in a different order each time. The piece, says Westergaard, celebrates "the changes that brought us from the institution we were in 1746 to where we are now, and to the institution we will be in the future."
In progress is "a piece for the New Jersey Percussion Ensemble, and I'm thinking about several operatic projects. . . . I will go on composing forever."
-Caroline Moseley