After an exploration of the implications of the present tax treatment of foundations, this article turns to deficiencies in organizational structure and models of governance allowing for input by the public. These models are proposed because their operations conform more to the underlying values of society than do foundations guided by self-selected officers. These values basically dictate that the public as a whole, not a self-appointed body of governors, should play the major role in determining what constitutes and best serves the common welfare. In addition, in the process of satisfying these external values, some demonstrable internal efficiencies accrue to foundations in terms of both the development of more vibrant and representative governing structures and the encouragement of a number of administrative efficiencies.
David A. Lipton, Significant Private Foundations and the Need for Public Selection of Their Trustees, 64 VA. L. REV. 779 (1978).