The board of directors of White Pearl, Inc., a private foundation, consists of Charlyne, Beth, and Carlos. They vote unanimously to provide a $325,000 grant to Marcus, their business associate. The grant is to be used for travel and education and does not qualify as a permitted grant to individuals (i.e., it is a taxable expenditure under § 4945). Each director knows that Marcus was selected for the grant because he is a friend of the organization and that the grant is a taxable expenditure.

a. Calculate the initial tax imposed on White Pearl.

b. Calculate the initial tax imposed on the foundation manager (i.e., board of directors).