Exempt organizations - Uncle Fed's Tax*Board

Exempt organizations
for the purpose of promoting a common business
interest and bettering the business conditions of
one or more lines of business is exempt as a business
league even though its principal activity is the
advocacy of legislation which is germane to such
common business interest. Rev. Rul. 54-442
modified. §1.501(c)(6)–1. (Sec. 501, ’86 Code.)
Rev. Rul. 61-177, 1961-2 C.B. 117.
218.73 Business leagues; legislative activities;
incidental. A corporation organized and operated
primarily for the purposes of promoting a common
business interest and bettering the conditions of
independent business, whose activities include the
furtherance of a legislative program, is exempt as
a business league. Modified by Rev. Rul. 61–177
to the extent that it suggests that engaging in other
than incidental legislative activities will necessarily
disqualify an organization. §39.101(7)–1.
(Sec. 101, ’39 Code; Sec. 501, ’86 Code.)
Rev. Rul. 54-442, 1954-2 C.B. 131.
218.74 Business leagues; luncheon and bar
facilities furnished members. An organization of
business and professional persons of a community,
providing luncheon and bar facilities for its
members but having no specific program directed
to the improvement of business conditions, does
not qualify for exemption. §1.501(c)(6)–1. (Sec.
501, ’86 Code.)
Rev. Rul. 70-244, 1970-1 C.B. 132.
218.75 Business leagues; luncheon meetings
to discuss industry problems. An organization
composed of businessmen may qualify for exemption
where its activities are limited to holding luncheon
meetings devoted to a discussion, review,
and consideration of the various problems in a particular
industry directed to the improvement of
business conditions as a whole. §1.501(c)(6)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 67-295, 1967-2 C.B. 197.
218.76 Business leagues; manufacturers’
organization; research for members. A nonprofit
manufacturers’ organization that conducts
research and makes the results available only to its
members rather than to the industry as a whole
does not qualify for exemption. §1.501(c)(6)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 69-106, 1969-1 C.B. 153.
218.77 Business leagues; manufacturers’
organization; testing and certification; product
standard. A nonprofit organization formed by
manufacturers of a particular product to conduct a
program of testing and certification of the product
to establish acceptable standards within the industry,
as a whole, qualifies for exemption.
§1.501(c)(6)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 70-187, 1970-1 C.B. 131.
218.78 Business leagues; motor carriers
association. A motor carriers’ association formed
to make recommendations with respect to the
establishment, revision, and change of rates, tariffs,
rules, regulations, and practices for its members
who are regulated by the Interstate Commerce
Commission and to publish the prevailing
rates may be exempt from tax. §1.501(c)(6)–1.
(Sec. 501, ’86 Code.)
Rev. Rul. 67-393, 1967-2 C.B. 200.
218.79 Business leagues; neighborhood community
association. A nonprofit organization that
is operated to promote the common business interests
of its members, a majority of whose businesses
are located in one particular shopping center,
has a voluntary membership open to all
businesses in a neighborhood community, and is
not concerned with landlord-tenant matters relating
to the shopping center qualifies for exemption.
Rev. Rul. 73-411 distinguished. §1.501(c)(6)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 78-225, 1978-1 C.B. 159.
218.80 Business leagues; nonprofit consumer
cooperatives. An association of nonprofit consumer
cooperatives which promotes the cooperative
method of doing business may qualify for
exemption. §1.501(c)(6)–1. (Sec. 501, ’86 Code.)
Rev. Rul. 67-264, 1967-2 C.B. 196.
218.81 Business leagues; packaging
manufacturers. An organization of packaging
manufacturers which includes in its industry
advertising references to brand name products
merchandised in its packaging material may be
exempt from tax. §1.501(c)(6)–1. (Sec. 501, ’86
Code.)
Rev. Rul. 67-344, 1967-2 C.B. 199.
218.82 Business leagues; promoting members’
interests. A trade organization that confines
its membership to dealers franchised by a particular
corporation and its activities to promoting the
business interests of its members does not satisfy
the “line of business” test of reg. 1.501(c)(6)–1
and is not a business league. §1.501(c)(6)–1. (Sec.
501, ’86 Code.)
National Muffler Dealers Assn., Inc., 440 U.S.,
Ct. D. 1997, 1979-1 C.B. 198.
218.83 Business leagues; promoting sale of
automobile for dealer-members. An organization
composed of dealers in a certain make of automobile
in a designated area, organized and operated
for the primary purpose of financing general
advertising campaigns to promote, with funds
contributed by dealer-members, the sale of that
make of automobile, is performing particular services
for its members instead of the automotive
industry as a whole and is not entitled to exemption.
I.T. 4053 superseded. §1.501(c)(6)–1. (Sec.
501, ’86 Code.)
Rev. Rul. 67-77, 1967–1 C.B. 138.
218.84 Business leagues; promoting single
brand or product. The Revenue Service will not
follow the Pepsi-Cola Bottlers’ Assn. decision
which held that an association, whose members
bottle and sell a single franchised soft-drink product
and whose purpose is to promote that product,
was exempt as a business league. It is the position
of the Service that organizations promoting a
single brand or product within a line of business do
not qualify for exemption. §1.501(c)(6)–1. (Sec.
501, ’86 Code.)
Rev. Rul. 68-182, 1968-1 C.B. 263.
218.85 Business leagues; public health and
welfare; professional membership. A nonprofit
organization whose membership consists of individuals
engaged in various professions organized
to promote a common business interest and to
improve professional services and techniques of
the members in the field of public health and welfare,
qualifies for exemption. §1.501(c)(6)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 70-641, 1970-2 C.B. 119.
218.86 Business leagues; publishing directory
of members; granting franchises. A nonprofit
organization of individuals in the business
of furnishing finance adjusting services, which
assigns exclusive franchise areas to its members
and publishes and distributes to their potential customers
a directory containing members’ names
and addresses, is performing particular services
for its members and does not qualify for exemption.
§1.501(c)(6)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 76-409, 1976-2 C.B. 154.
218.87 Business leagues; publishing tourist
guidebook. An organization formed to promote
the tourist industry in its area and whose principal
activity is the publication of a year book consisting
largely of paid advertisements for its members is
not entitled to exemption. §1.501(c)(6)–1. (Sec.
501, ’86 Code.)
Rev. Rul. 65-14, 1965-1 C.B. 236.
218.88 Business leagues; rewards to deter
crime against members. An organization created
to improve the business conditions of financial
institutions by offering rewards for information
leading to the arrest and conviction of individuals
committing crimes against its member institutions
qualifies for exemption. §1.501(c)(6)–1. (Sec.
501, ’86 Code.)
Rev. Rul. 69–634, 1969-2 C.B. 124.
218.89 Business leagues; scientific research
association. A nonprofit association composed of
members of a particular industry to develop new
and improved uses for existing products of the
industry does not qualify for exemption under section
501(c)(3), but may qualify for exemption
under section 501(c)(6). §§1.501(c)(3)-1,
1.501(c)(6)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 69-632, 1969–2 C.B. 120.
218.90 Business leagues; shopping center
merchants’ association. An association of merchants
whose businesses constitute a shopping
center does not qualify for exemption where the
association expends its funds and engages exclusively
in advertising the names of member merchants
and their merchandise in various newspapers
and on television and radio to attract
customers to the shopping center. Clarified by
Rev. Rul. 73-411. §1.501(c)(6)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 64-315, 1964–2 C.B. 147.
218.91 Business leagues; shopping center
merchants’ association. A shopping center merchants’
association whose membership is
restricted to and required of the tenants of a oneowner
shopping center and their common lessor,
and whose activities are directed to promoting the
general business interests of its members, does not
qualify as a business league or chamber of commerce
under section 501(c)(6). This Revenue Ruling
will not be applied to taxable years beginning
before January 1, 1974, with respect to organizations
that have been relying upon ruling or determination
letters issued under section 501(c)(6).
Distinguished by Rev. Rul. 78–225. Rev. Rul.
64-315 clarified. §§1.501(c)(6)-1, 301.7805-1.
(Secs. 501, 7805; ’86 Code.)
Rev. Rul. 73-411, 1973–2 C.B. 180.
218.92 Business leagues; small loan companies.
An organization of small loan companies,
formed in response to regulations issued by a state
department of banking to promote control of consumer
lending, maintains a file of all open loans
made by its members and furnishes this information
to them in order to prevent a borrower from
obtaining small loans in excess of a specified sum
at any one time, may qualify for exemption.
§1.501(c)(6)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 67–394, 1967–2 C.B. 201.
218.93 Business leagues; specialized reference
library. An organization whose only activity
is providing a reference library of “electric logs”,
maps, and information services used solely by its
members in their exploration businesses is not
exempt from tax. §1.501(c)(6)–1. (Sec. 501, ’86
Code.)
Rev. Rul. 67-182, 1967–1 C.B. 141.
218.94 Business leagues; students in a profession.
An organization whose membership is composed
of students studying for a degree in a particular
profession and that was formed to promote the
students’ interests as future members of that profession
may qualify for exemption.
§1.501(c)(6)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 77–112, 1977-1 C.B. 149.
218.95 Business leagues; subsidizing lawsuit;
prevention of air pollution. Subsidizing the prosecution
of a lawsuit for an injunction to prevent
air pollution of a region did not cause an organization
of growers and processors of agricultural