Sam Cherwin's* estate plan divides his estate between his son Jared, a former Children's patient, and Children's Hospital Boston. Among his assets, Mr. Cherwin has an Individual Retirement Account (IRA) worth $300,000. He named Children's the beneficiary of the IRA, leaving his other assets to his son. Jared is in the 33 percent tax bracket and if Mr. Cherwin were to pass his IRA outright to him, the amount remaining after income taxes would be reduced by one-third to $200,000. If Jared were to take the minimum distributions from the IRA, they would be subject to income taxes when he received them. However, as a tax exempt organization, Children's will not be subject to income taxes on the IRA distributions. With this gift, Mr. Cherwin: