Deducting possible contributions to new 501(c)(3) entity

[FEDUKE404]

Local small business (coffeehouse) was being operated on a not-for-profit basis. The bulk of the "employees" are either volunteers or slightly handicapped individuals.

Several individuals, one a client, donated funds specifically allocated to paying an attorney/CPA to apply for Section 501(c)(3) status.

The paperwork was duly processed, and the coffeehouse is now operating as a Section 501(c)(3) entity.

Here's the issue: My client donated approximately $1k to the "business" with the express purpose of those funds being used to hire professional(s) to complete the Section 501(c)(3) application. Client received a very nice acknowledgement letter, stating gratitude for receipt of funds specifically to help them procure their tax-exempt status. The original letter received does NOT include any of the usual IRS verbiage required for a contribution receipt.

Are the (essentially "start up") expenses a valid deductible contribution for the client? Would a second acknowledgement letter, from the now existent Section 501(c)(3) concern, improve or change anything for those same "contributions"?

I've never run into a scenario such as this, and the potential deduction is fairly large. Any advice or "I've had to deal with that before!" comments would be appreciated.

Thanks in advance.

FE

[JohnH]

Not sure if this would be acceptable, but just off the top of my head:
What if the original $1,000 was a loan offered for the purpose of exploring non-profit status?
Then he makes a contribution of $1,000 (or more) after the paperwork is completed, and the original loan is repaid at that time.