In 1939 the Treasury Department refused to grant tax-exempt status to the NAACP because of a perceived conflict between the Association’s litigation and lobbying activities. In response, the NAACP created its Legal Defense and Educational Fund, Inc. as a non-profit separate arm to litigate cases and raise money exclusively for the legal program. The “Legal Defense Fund” or “Inc. Fund” as it was commonly known, shared board members and office space with the NAACP and Arthur Spingarn was president of both organizations. Thurgood Marshall served concurrently as the Fund’s director and NAACP Special Counsel. Marshall hired a new team of lawyers to work for the Fund, including Robert L. Carter, Jack Greenberg, Constance Baker Motley, and Franklin Williams. The Legal Defense Fund severed ties with the NAACP in 1957, but retained its original name.