Priv. Ltr. Rul. 201315031 (Jan. 15, 2013)

(taxpayer established trust for supporting religious organizations and then converted trust to private foundation; trust acquired ranch property in furtherance of charitable purposes - a retreat property and associated programs for clergy including free room and board; ranch also raised sheep and sheep studies on ranch made available for students in journals with purpose of improving U.S. sheep production; trust sold sheep to farmers and slaughterhouses; significant losses realized; IRS determined that trust not subject to I.R.C. Sec. 4942(a) penalty of 30 percent on undistributed income because ranch property held for use directly in carrying out trust's exempt purpose).