What is the tax status of Oakland University?

The Internal Revenue Service has ruled that Oakland University is an integral part of the State of Michigan for federal tax purposes.  As such, the university is exempt from federal income tax, except the tax on unrelated business income.  Furthermore, contributions to Oakland University are deductible by donors under section 170 (c) (1) of the Internal Revenue Code provided that such contributions are for exclusively public purposes.  In addition, bequests, legacies, devises, transfers or gifts to or for university use are deductible for federal estate and gift tax purposes under the provisions of the code provided such funds are used for exclusively public purposes.  See the attached Internal Revenue Service opinion on the Deductibility of Contributions made by Donors to Oakland University.pdf

The university has never applied for or received approval from the Internal Revenue Service to be treated as a 501 (c) (3) organization as described in the code.