Tuition Payments To Religious School Not Deductible

Tuition Payments To Religious School Not Deductible

News story posted in Field Service Advice on 19 May 1999| comments
audience: National Publication | last updated: 18 May 2011
Print
||
Rate:

Summary

In FSA 1999-1070, the Service, quoting Hernandez v. Commissioner, 490 U.S. 680 (1989), held that tuition payments to a religious school are not deductible under section 170 of the Code because the Taxpayers received a substantial benefit on account of the payments.

In FSA 1999-1070

PGDC SUMMARY:

Taxpayers claimed a charitable contribution deduction for tuition payments made to Jewish religious schools. The Taxpayers argued that most of the day is spent on religious study and prayer rather than secular education and that the act of religious study is an observance of their religion. The Service disallowed the claimed deductions. The IRS Appeals Office later reduced the disallowances.

In Hernandez v. Commissioner, 490 U.S. 680 (1989), the Supreme Court held that "Congress has specified that a payment to an organization operated exclusively for religious...purposes is deductible only if such payment is a "contribution or gift."...The Code makes no special preference for payments made in the expectation of gaining religious benefits or access to a religious service." Relying primarily on Hernandez, the Service held that Taxpayers did receive a substantial benefit on account of the tuition payments and accordingly, such payments are not deductible. Further, in response to Taxpayers' arguments that more time is devoted in the present case to religious study than in Hernandez, the Service stated that "this is simply a question of degree, and we see no reason why this distinction supports a result different from the result in Hernandez...it would be difficult, if not impossible, to resolve cases like this on the basis of such factors as the religious or secular nature of the benefit...Fortunately under Hernandez' structural analysis, such determinations and inquiries are largely unnecessary. Instead, the question here is whether, in return for their tuition payments, the petitioners received or expected to receive an identifiable benefit, religious or secular. Clearly, they did..."

POINTS TO PONDER:

The Service reiterated that it has not published any ruling and does not have a position regarding the deductibility of payments for tithes, High Holy Day tickets, torah readings and synagogue dues. Will the IRS begin to challenge the deductibility of such payments?

FULL TEXT:

INTERNAL REVENUE SERVICE
MEMORANDUM
CC:TL-N-* * *
DOM:FS:* * *

date: * * *
to: District Counsel, * * * CC:* * *
Attn: * * *
from: Assistant Chief Counsel (Field Service) CC:DOM:FS

subject: * * *

This memorandum is in response to your request for field service advice dated * * *

This document may contain taxpayer information subject to section 6103. This document may also contain confidential information subject to the attorney-client and deliberative process privileges, and may also have been prepared in anticipation of litigation. Therefore, this document shall not be disclosed beyond the office or individual(s) to whom it is addressed and in no event shall it be disclosed to taxpayers or their representatives.

Specifically, if this memorandum is addressed to a District Counsel, then only office personnel working the specific case or subject matter may use this document. If this memorandum is addressed to a District Director, then only office personnel working the specific case or subject matter may use this document. This memorandum shall not be disclosed or circulated beyond such office personnel having the requisite "need to know."

ISSUE

Whether tuition payments to Jewish religious schools are deductible as charitable contributions under I.R.C. section 170 because most of the day is spent on religious study and prayer rather than secular education.

CONCLUSION

Tuition payments made to Jewish religious schools do not qualify as charitable contribution deductions because the payors derive a substantial benefit from the payments.

FACTS

Petitioners claimed large charitable contribution deductions on their timely filed income tax returns for taxable years * * * and * * * On examination, the Service disallowed the claimed deductions in the respective amounts of $* * * $* * * and $* * * Appeals, however, reduced the disallowances to $* * * $* * * and $* * * respectively, and determined deficiencies in tax of $* * *, $* * * and $* * * and additions to tax of $* * * $* * * and $* * * for the respective tax years. The disallowances were on account of the following:

Jewish Religious School        * * *            * * *          * * *
1. * * *                      $* * *           $* * *         $* * *
2. * * *                       * * *            * * *          * * *
3. * * *                       * * *            * * *          * * *
4. * * *                       * * *            * * *          * * *
5. * * *                       * * *            * * *          * * *
6. * * *                       * * *            * * *          * * *
7. * * *                       * * *            * * *          * * *
                              $* * *           $* * *         $* * *


*There is a $* * * discrepancy between this amount and the figure in the Statement of Income Tax Changes. The additional allowances by Appeals were as follows:

                         * * *             * * *          * * *
* * *                   $* * *           $ * * *        $ * * *
* * *                    * * * * *             -              -
* * *                    * * * * *             -              -
* * *                    * * * * *             -              -
* * *                                                   $ * * *
                        $* * *           $ * * *        $ * * *


* * * Nontuition payments.


The instant petition was filed on * * * placing the deficiencies and penalties in dispute. In her Answer, respondent generally denied the allegations of the petition and, on * * * the court granted petitioners' Motion to Continue the trial of the case from the * * * trial calendar in * * * It is anticipated that the case will be scheduled for the next trial calendar, probably in * * *

Petitioners argue that the act of religious study for Orthodox Jews is an observance of their religion. This religious study begins at an early age for each individual and continues for the individual's entire life. Petitioners claim that payments made to Jewish religious schools are, therefore, in furtherance of this religious function and are deductible as charitable contributions.

Petitioners state that the primary purpose of each of the above institutions is religious study. At the above institutions, anywhere from * * * to * * *% of the student's time is devoted to religious study. Petitioners provided an hourly analysis which lists the institutions with related percentage of time devoted to religious and secular study. For example, the * * * is listed as * * *%, while * * * an institution for helping learning disabled children study the Torah and Talmud, is listed as * * *%. In the remaining five institutions, it is asserted, * * *% to * * *% of the student's time is devoted to religious study.

In support of their position, petitioners cite a Minnesota Tax Court case as the recommended rationale to be applied to their case. The Minnesota Court found that payments to a school providing purely religious education as opposed to general education are deductible as charitable contributions. The school at issue, a Jewish religious school for the study of the Torah and Talmud, offered instruction considered by the court to be strictly a religious function, and the substance of the taxpayer's gift was charitable despite its form as tuition. Gotlieb, Minnesota Tax Court, Docket No. 1956 (1975).

In addition, petitioners rely on Davis v. Commissioner, 495 U.S. 472 (1990), where the parents of two Mormon missionary sons deducted as charitable contributions the payments made to their sons for their financial support. The Court held that such payments made to their sons were not deductible since they were not made to or for the use of the Mormon Church. Petitioners incorrectly argue that if the payments had been made to the Mormon Church with the understanding that such payments were for the support of the taxpayers' sons, such payments would have been considered charitable contributions.

Petitioners, in applying Davis to their own case, argue that payments to Jewish religious schools are placed under the unfettered control of the school to help it carry out its religious function of providing religious study and worship.

Finally, petitioners rely upon various revenue rulings and pronouncements in support of their position that payment of tuition to Jewish religious schools yields only an incidental benefit to the payor and as such does not come under the ambit of Hernandez v. Commissioner, 490 U.S. 680 (1989). In Hernandez, the Court held that payments to the Church of Scientology for auditing and training represent a quid pro quo exchange for direct benefits by the payor and as such were not deductible as charitable contributions.

The rulings hold that pew rents, building fund assessments, and periodic dues paid to a church are charitable contributions. Rev. Rul. 70-47, 1970-1 C.B. 49. Similarly, stipends made to a church to say Masses for deceased family members are deductible. Rev. Rul. 78- 366, 1978-2 C.B. 24.

Petitioners argue that the payment of tuition for religious study results in only an incidental benefit to themselves but a direct benefit to members of the Jewish religion. Tuition payments to Jewish religious schools, it is urged, afford the attendee religious observance of their religion through study of the religion, but this benefit is only incidental to the attendee and the person paying the tuition. The primary beneficiaries are all Jews who have had their religion preserved for more than 1,000 years through the careful adherence to the study of Judaism by members of the faith.

Petitioners, however, concede that most of the above institutions do render secular education in addition to religious education as part of State accreditation requirements. Petitioners supplied the original corporate charters for * * * of the above- listed Jewish religious schools. These charters refer to the corporate purpose of being either a parochial school or a school that renders both religious and general/secular education.

Petitioners agree that payments for secular education would not be deductible. However, petitioners argue that there appears to be no way to allocate rationally the cost of tuition paid to the Jewish religious schools between the value of the secular and the religious education received. The use of hours or percent of time devoted to religious versus secular education applied to the cost of tuition for any particular institution would be at best an approximation of such values. Accordingly, petitioners assert that they are entitled to a deduction for the entire payment.

DISCUSSION

Section 170(a) of the Code provides that there shall be allowed as a deduction any charitable contribution payment of which is made within the taxable year. Section 170(c) provides in relevant part that the term "charitable contribution" means a contribution or gift to or for the use of a corporation, trust, community chest, fund or foundation organized and operated exclusively for religious or educational purposes.

In Rev. Rul. 68-432, 1968-2 C.B. 104, the Service set forth the general principle that a transfer of money or property to a charity is deductible under section 170 unless the taxpayer receives a valuable return benefit by reason of the transfer. In defining what constitutes a valuable return benefit, the ruling excludes benefits which are incidental to the normal functioning of the charity.

In Rev. Rul. 71-580, 1971-2 C.B. 235, the Service published its position that a nonprofit organization formed to compile genealogical research data on its family members in order to perform religious ordinances in accordance with the precepts of the religious denomination to which the family members belong is exempt from tax under section 501(c)(3). The rationale for this conclusion is that religious observances under the tenets of a particular religion are of a spiritual benefit to all members of that faith and to the general public. Any private benefit to a given family or individual that may result is regarded as merely incidental to the general public benefit that is served. The ruling, however, does not purport to decide whether contributions made to the organization are deductible under section 170.

In Rev. Rul. 83-104, 1983-2 C.B. 46, the Service set forth factual situations to illustrate the distinction between qualified charitable contributions and tuition payments made to a qualifying donee. In Situation 1, it is posited that a private school solicits a contribution of $400X from parents of each child enrolled in the school. Parents who do not make the contribution are required to pay $400X as tuition for each child enrolled in the school. Parents who neither make the contribution nor pay the tuition cannot enroll their children in the school. The ruling concludes that under these facts, a taxpayer who pays the $400X is not entitled to a charitable contribution because the payment was not voluntary and was not made without the expectation of a commensurate benefit.

In Hernandez v. Commissioner, 490 U.S. 680 (1989), the Supreme Court held that payments made to the Church of Scientology for auditing and training were not deductible as charitable contributions or gifts within the meaning of section 170. The Court examined the underpinnings of this Code section and noted that:

The legislative history of the "contribution or gift" limitation . . . reveals that Congress intended to differentiate between unrequited payments to qualified recipients and payments made to such recipients in return for goods or services. Only the former were deemed deductible. The House and Senate Reports on the 1954 tax bill, for example, both define "gifts" as payments "made with no expectation of a financial return commensurate with the amount of the gift." (citation omitted). Using payments to hospitals as an example, both Reports state that the gift characterization should not apply to "a payment by an individual to a hospital in consideration of binding obligation to provide medical treatment for the individual's employees. It would apply only there were no expectation of any quid pro quo from the hospital." (citations omitted; footnote omitted).

In ascertaining whether a given payment was made with "the expectation of any quid pro quo," . . . the IRS has customarily examined the external features of the transaction in question. This practice has the advantage of obviating the need for the IRS to conduct imprecise inquiries into the motivations of individual taxpayers. The lower courts have generally embraced this structural analysis. (citations omitted). We likewise focused on external features in American Bar Endowment . . . , to resolve the taxpayers' claims that they were entitled to partial deductions for premiums paid to a charitable organization for insurance coverage . . . . In so doing, we stressed that "the sine qua non of a charitable contribution is a transfer of money or property without adequate consideration." (citation omitted) (emphasis in original)

490 U.S. at 679-680.

In response to the taxpayers' argument that the quid pro quo analysis was inappropriate under section 170 when the benefit the taxpayer receives is purely religious in nature, the Court stated at 490 U.S. 692-693:

We cannot accept this statutory argument for several reasons. First, it finds no support in the language of section 170. Whether or not Congress could, consistent with the Establishment Clause, provide for the automatic deductibility of a payment made to a church that either generates religious benefits or guarantees access to a religious service, that is a choice Congress has thus far declined to make. Instead, Congress has specified that a payment to an organization operated exclusively for religious (or other eleemosynary) purposes is deductible only if such a payment is a "contribution or gift." 26 U.S.C. section 170(c). The Code makes no special preference for payments made in the expectation of gaining religious benefits or access to a religious service. (citation omitted).

The House and Senate Reports on section 170, and the other legislative history of that provision, offer no indication that Congress' failure to enact such a preference was an oversight.

Second, petitioners' deductibility proposal would expand the charitable contribution deduction far beyond what Congress has provided. Numerous forms of payments to eligible donees plausibly could be categorized as providing a religious benefit or as securing access to a religious service. For example, some taxpayers might regard their tuition payments to parochial schools as generating a religious benefit or as securing access to a religious service; such payments, however, have long been held not to be charitable contributions under section 170. (citations omitted)(emphasis added).

In the instant case, petitioners clearly derive a substantial benefit on account of the payment of tuition and accordingly, such payments are not deductible.

Prior to Hernandez, federal tax decisions had uniformly disallowed payments to religious schools insofar as they represented the cost of tuition. In DeJong v. Commissioner, 309 F.2d 373 (9th Cir. 1962), aff'g 36 T.C. 86 (1961), taxpayers made a "contribution" of $1,075 to the Society for Christian Instruction which operated full time schools accredited by the state. The Society charged no tuition but raised funds from parents of enrolled students, churches and other entities. The stipulated annual cost of providing instruction for each child was $400. Although no tuition was charged, the parents who could so afford were expected to contribute to the Society at least to the extent of the cost of providing their children with an education. Notwithstanding the fact that the cost of tuition covered both secular and religious education, the courts concluded that the tuition payment ($400) was not deductible as a charitable contribution because it was not voluntary and was induced in substantial part by the benefits sought and anticipated from enrollment in the school.

In Oppewal v. Commissioner, 468 F.2d 1000 (1st Cir. 1972), aff'g T.C. Memo. 1971-273, taxpayers deducted $900 as a charitable contribution to the Whitinsville Society for Christian Instruction. Again, the courts disallowed that part of the payment which represented the cost of educating the taxpayers' children in the religiously-oriented school although by use of a different test. The Tax Court employed a subjective test, i.e., whether the payments were induced by anticipated benefits. The First Circuit preferred an objective test, i.e., whether the payment was offset by the cost of services rendered to the taxpayers. Both courts concluded however, that the school's cost of providing a service (which included religious instruction to taxpayers' children) was not deductible as a charitable contribution.

In Winters v. Commissioner, 468 F.2d 778 (2d Cir. 1972), aff'g T.C. Memo. 1971-290, taxpayers claimed a charitable contribution deduction for payments made to a church fund established to support certain Christian schools, enrollment in which did not require payment of tuition. The Second Circuit agreed with the opinions of the First and Ninth Circuits and concluded that to the extent that the taxpayers received a benefit in return, the payment constituted nondeductible tuition.

Petitioners argue that the schools in the instant case are different from those in the reported cases and revenue rulings in that most of the time is spent on religious training rather than a secular education. This difference, it is asserted, requires an opposite conclusion. The Hernandez Court disagreed with this proposition when it stated that section 170 of the Code "makes no special preference for payments made in the expectation of gaining religious benefits or access to a religious service." 490 U.S. at 693. The Scientology "training" at issue in Hernandez involved the intensive study of the writings and tenets of Scientology. This training did not involve secular education, and was a means of progressing up the Scientology "Bridge." There seems to be no relevant distinction between such training and the intensive study of Jewish writing and tenets. The taxpayers stress the amount of time spent in study by students at Orthodox Jewish schools. Even if it is true that they devote more time to the activity than students of Scientology, this is simply a question of degree, and we see no reason why this distinction supports a result different from the result in Hernandez. Thus, whether the payment involved is in consideration for training to become a good Scientologist, Christian or Jew, we conclude that, under Hernandez, such payments do not qualify as charitable contributions within the meaning of section 170.

The petitioners also attempt to distinguish the parochial school cases such as Winters on the ground that the activities in the schools attended by their children primarily constitute religious worship or observance, rather than education as such. Your memorandum also finds this distinction potentially relevant, and devotes a portion of its discussion to an examination of Orthodox Jewish belief, the relationship of prayers to study, etc.

Here again, we find Hernandez dispositive. Scientology "auditing," also at issue in Hernandez, was stipulated to have no significant educational component, and was clearly a "religious observance." The central message of Hernandez is that this fact is not relevant.

The petitioners make the point that, for the Orthodox Jew, the obligation to study the Torah and the Talmud is a matter of duty and adherence to Jewish law, a lifelong commitment ranking aside the obligation to pray. Related to this is the argument that the benefits derived from the observance of such duties primarily benefit the community, not the individual. 1 Apparently with such possible distinctions in mind, your memorandum states that litigation of the case "will necessarily involve a judicial inquiry into the tenets of one of the major world religions," and that in order to establish a litigating position, it is important to "understand fully the beliefs and practices of Judaism."

We do not find the distinctions argued by the petitioners to be relevant under Hernandez, and respectfully disagree that resolution of the issue necessarily involves a searching inquiry into the tenets and beliefs of Judaism.

In fact, one of the primary reasons underlying the Hernandez Court's neutral interpretation of section 170 -- along with the Court's adoption of a "structural" analysis, with its emphasis on "external features" -- was precisely in order to avoid the practical and constitutional difficulties inherent in drawing such distinctions and making such inquiries. 2

In our view it would be difficult, if not impossible, to resolve cases like this on the basis of such factors as the religious or secular nature of the benefit; the relative importance of a religious practice to the adherents of a particular religion; how much of an obligation the member feels to participate; whether a spiritual benefit accrues primarily to the individual participant or donor, rather than the larger community; etc. 3

Fortunately, under Hernandez' structural analysis such determinations and inquiries are largely unnecessary. Instead, the question here is whether, in return for their tuition payments, the petitioners received or expected to receive an identifiable benefit, religious or secular. Clearly, they did: an examination of the "external features" indicates that their tuition payments entitled their children to attend a facility where, in the company of others and under the supervision of a trained rabbi or instructor they could engage in regular religious study and prayer. 4 As in Hernandez, the notion of a personal quid pro quo is inherent in the structure of the transaction. The inquiry ends there; the doctrinal content and significance of the activity is not germane. 5

Petitioners' reliance on the Minnesota Tax Court opinion in Gotlieb, Dkt. No. 1956 (Feb. 28, 1975), is misplaced. In Gotlieb, the taxpayer made payments to a synagogue school in consideration of religious training provided to his children and claimed these payments as charitable contribution deductions. The tax commissioner, relying on Oppewal, supra, disallowed the deductions. The Minnesota court, however, could find no federal tax decisions which involved payments for purely religious services and concluded that the taxpayer was entitled to the claimed deductions. The decision of a state taxing authority on a federal income tax question is not controlling for federal income tax purposes. See Texas Learning Technology Group v. Commissioner, 96 T.C. 686, 693-694 (1991), and cases cited therein. Furthermore, the Supreme Court's opinion in Hernandez, which post-dates the Gotlieb opinion, is dispositive in its holding that where a taxpayer receives a benefit in return for the alleged contribution, a deduction is not allowable regardless of the nature of the benefit.

Petitioners' reliance on Davis in support of their deduction is also misplaced. In Davis, the Court addressed the deductibility of payments made directly by parents to their missionary children at the request of a church. The primary issue was whether these direct payments were "for the use of" the church as defined in section 170(c). The Court held that a gift or contribution is for the use of a qualified organization when it is held in a legally enforceable trust for the qualified organization or in a similar legal arrangement. 495 U.S. at 486. Petitioners assert that because the qualified donees in the instant case have unfettered control over the tuition payments, a deduction is allowable under the Davis test. In fact, the donees in the instant case do not have unfettered control; in exchange for the tuition payments, the donee schools must provide an education to the petitioners' children. Moreover, the issue in this case is not whether the payments were made "to or for the use of" a qualified donee; rather, the issue is whether petitioners received a substantial benefit in return, i.e., whether there existed a quid pro quo, and the Hernandez rationale is therefore the appropriate test for deductibility.

Petitioners' assertion that the tuition payments are similar to amounts paid for pew rents, building fund assessments, periodic dues, tithing, High Holy Day tickets and Mass bequests, lacks merit. In Rev. Rul. 70-47, 1970-1 C.B. 49, superseding A.R.M. 2, 1 C.B. 150 (1919), the Service published its position that pew rents, building fund assessments, and periodic dues paid to a church (an organization described in section 170(c) of the Internal Revenue Code of 1954) are all methods of making contributions to the church, and such payments are deductible as charitable contributions within the limitations set out in section 170 of the Code.

Rev. Rul. 70-47 neither states nor suggests that a quid pro quo is involved and such an assumption would be clearly contrary to the standard for deductibility postulated in Rev. Rul. 68-432. Rather, Rev. Rul. 70-47 must be read in conjunction with Rev. Rul. 68-432. In other words, the payments for pew rents, building fund assessments and periodic dues which are subject to Rev. Rul. 70-47 should be assumed not to involve the return of any significant benefit or privilege and thus were contributions toward the support of the charitable organization. See Rev. Rul. 68-432.

There is no legal warrant for a contrary conclusion. The Service's rulings should be read together as a unified statement of position. As stated in the Introduction to each Internal Revenue Bulletin:

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify or amend any of those previously published in the Bulletin.

Know, for example, whether payments for other faiths' services are truly obligatory or whether any or all of these services are generally provided whether or not the encouraged 'mandatory' payment is made.")

The Service has not published any ruling and does not have a position regarding the deductibility of payments for tithes, High Holy Day tickets, torah readings and synagogue dues. Notwithstanding, the Court in Hernandez assumed arguendo that the Service allowed a deduction for these payments and held that the proper inquiry for deductibility under section 170 would be not whether the payment secures religious benefits or access to religious services, but whether the transaction in which the payment is involved is structured as a quid pro quo exchange. 490 U.S. at 701-702. The operative facts in the instant case are that petitioners are required to make specific payments in return for which they receive a benefit, i.e., religious and secular education for their children. Under the rationale postulated in Hernandez, petitioners are not entitled to a charitable contribution deduction for tuition payments made to Jewish religious schools.

We note that the Appeals officer allowed a deduction for payments made to the * * * of * * * and we have requested that this issue be developed factually. Upon consideration of those facts, we shall provide you with a supplemental response on their deductibility.

If you have any questions or need further assistance in this matter, please contact * * * at (202) 622-* * *

Daniel J. Wiles
By: * * *
Field Service Division



  1. Thus, petitioners state: "Unlike Hernandez, where some physical, emotional, or even spiritual direct benefit was received with the erasure of 'bad memories' through the religious experience, Judaism's religious experience is an expression of devotion, of communal benefit with no quid pro quo to the donor." (The reference appears to be to Scientology auditing, not training.) The submissions also suggest the disturbing possibility that the Service would distinguish on a similar basis not only between payments for religious schools attended by Jews and religious schools attended by Scientologists or Catholics, but even between religious schools attended by Orthodox Jews and those attended by Jews in the Reform or Conservative branches.back

  2. For example, in discussing the "entanglement" prong of the Establishment Clause analysis, the Court observed: To be sure, ascertaining whether a payment to a religious institution is part of a quid pro quo transaction may require the IRS to ascertain from the institution the prices of its services and commodities, the regularity with which payments for such services and commodities are waived, and other pertinent information about the transaction. But routine regulatory interaction which involves no inquiries into religious doctrine . . . does not of itself violate the nonentanglement command. 490 U.S. at 696-97 (emphasis added). See also id. at 690-91, 694.back

  3. For example, Scientologists believe that Scientology services have a potential beneficial effect on not only the individual, but also the family, larger groups, the physical and spiritual universes, and the Supreme Being; they also believe that the widespread practice of Scientology will help lead to a saner, more peaceful, more spiritually advanced world. Whether these beliefs somehow give rise to a lesser sense of duty or obligation than those of Judaism clearly is not an appropriate subject for administrative determination.back

  4. Under Hernandez, the extent to which the tuition payments also entitled them to secular education is not a determinative factor.back

  5. There is a suggestion in some of the petitioners' arguments that the "communal" nature of the activities in this case may distinguish it from Hernandez. Hernandez, in our view, does not rest on a distinction between group and individual worship or study; while Scientology "auditing" is generally practiced in one-on-one sessions, "training" generally involves group instruction and study. The Service has disavowed any reliance on a group-vs. - individual distinction in Hernandez and post-Hernandez litigation.back

Add comment

Login or register to post comments

Comments

Group details

Follow

RSS

This group offers an RSS feed.
 
7520 Rates: November 2.4% October 2.2% September 2.4%

Already a member?

Learn, Share, Gain Insight, Connect, Advance

Join Today For Free!

Join the PGDC community and…

  • Learn through thousands of pages of content, newsletters and forums
  • Share by commenting on and rating content, answering questions in the forums, and writing
  • Gain insight into other disciplines in the field
  • Connect – Interact – Grow
  • Opt-in to Include your profile in our searchable national directory. By default, your identity is protected

…Market yourself to a growing industry