X-Message-Number: 8977
From: Ettinger <>
Date: Wed, 7 Jan 1998 09:42:43 EST
Subject: Prometheus questions

Paul Wakfer's message #8975, intended to clarify the status and goals of the
Prometheus Project, leaves me puzzled. 

I don't fault Paul for changing his mind or plans from time to time, as
realism may dictate, and I admire his zeal and determination. But I think it
will help his efforts, in the end, if certain questions are clearly
resolved--in particular, the for-profit question and that of relations with
21st Century Medicine.

Paul says the for-profit approach has not been abandoned, yet money is being
collected for which IRS tax deductibility is expected. The money is being
collected by a "charitable trust," the Full Length Life Society (FLLS), and
will be disbursed to an unincorporated business trust, the Life On Hold Trust
(LOHT). Eventually, if distribution of assets of LOHT is ever made, the people
who support the project will receive this distribution. All of this seems to
raise the possibility that the IRS may eventually regard the FLLS merely as a
front for the LOHT. You cannot, in principle, achieve tax exemption or tax
deductibility just by shufflling paper or interposing a dummy between the
donors/investors and the profit-making entity. The money supplied must be a
genuine donation and not a disguised or indirect investment. 

Paul, has all this been cleared with a reputable tax attorney? Is his/her
opinion available?

As far as I can see, the possible eventual money profit for supporters is so
distant in time--20 years or more--that no one is going to be motivated by
money anyway. If that is the case, why not forget the for-profit approach
altogether and keep it clean and simple?

The second question concerns the relation between Paul's organizations and
21st Century Medicine (21CM) and related companies and individuals. Paul says
the research of his organizations will not be integrated with that of 21CM
"except to cooperate to make sure that results are shared and unnecessary
duplication does not occur."

What does this mean? Will LOHT share the proprietary information generated by
21CM, and keep that info confidential? Will 21CM pursue profits possibly
resulting from research results generated by LOHT? Will LOHT share results, on
a timely basis, with people or organizations outside of 21CM? Who will pursue
the most promising and potentially most profitable leads? What criteria will
be used to decide who pursues what and who pays for what and who gains title
to what? Etc. 

As I recall, Paul asks that these questions be left to the good judgment and
good will of the people involved (and presumably their successors). But it is
no reflection on these people to note that due diligence excludes that kind of
relaxed approach.

Of course the achievement of the research goals is more important than any of
the questions raised above. Any of us would rather have the research succeed
than not, regardless of who profits financially or how benefits are formally
shared. But unless the formal and legal status is clear and reasonable,
obscurity and friction will interfere with the fund raising.

Robert Ettinger  

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