Exempt organizations - Uncle Fed's Tax*Board

Exempt organizations
intangible assets, determined by the capitalization
of excess earnings formula, does not result in the
inurement of the hospital’s net earnings to the
benefit of any private shareholder or individual or
serve a private interest precluding exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 76-91, 1976-1 C.B. 149.
218.432 Hospitals; radiologist compensated
on percentage of departmental income. The
exempt status of a hospital will not be jeopardized
where, after arm’s length negotiations, it enters
into an agreement with a hospital-based radiologist
to compensate him on the basis of a fixed percentage
of the departmental income.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 69-383, 1969–2 C.B. 113.
218.433 Housing; community chest agencies.
A nonprofit organization, created to construct and
maintain a building for the exclusive purpose of
housing and serving exempt member agencies of
a community chest, may be exempt. Rev. Rul.
58-547 distinguished. §1.501(c)(3)-1. (Sec. 501,
’86 Code.)
Rev. Rul. 69-572, 1969-2 C.B. 119.
218.434 Housing; elderly. A nonprofit organization
that provides specially designed housing
to elderly persons at the lowest feasible cost and
maintains in residence those tenants who subsequently
become unable to pay its monthly fees is
an organization operated exclusively for charitable
purposes within the meaning of section
501(c)(3). §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 79-18, 1979–1 C.B. 194.
218.435 Housing; employees of farm proprietorship.
An organization formed to provide low
income housing to families but giving preference
for housing to employees of a farm proprietorship
operated by the individual who created and controls
the organization does not qualify for exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 72-147, 1972–1 C.B. 147.
218.436 Housing; guidance to low-income
families. A nonprofit organization created to provide
instruction and guidance to low-income families
in need of adequate housing and interested in
building their own homes is exempt from tax.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 67–138, 1967–1 C.B. 129.
218.437 Housing; integrated. A nonprofit
organization formed to promote racial integration
in housing, to lessen neighborhood tension, and to
prevent deterioration of neighborhoods may qualify
for exemption. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 68-655, 1968-2 C.B. 213.
218.438 Housing; leased to city for tire victims.
A nonprofit organization that provides rental
housing and related services at cost to a city for its
use as free temporary housing for families whose
homes have been destroyed by fire is not an
exempt charitable organization. §1.501(c)(3)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 77-3, 1977-1 C.B. 140.
218.439 Housing; low income homeowners;
home repair loans. A nonprofit organization that
provides interest-free home repair loans in a badly
deteriorated urban residential area to low-income
homeowners who are unable to obtain loans elsewhere
qualifies for exemption as operated exclusively
for charitable purposes. §1.501(c)(3)-1.
(Sec. 501, ’86 Code.)
Rev. Ru1. 76-408, 1976–2 C.B. 145.
218.440 Housing; low or moderate income
families. Nonprofit organizations created to provide
housing for low and moderate income families
thereby lessening neighborhood tensions,
eliminating prejudice and discrimination, and
combating deterioration qualify for exemption,
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 70-585, 1970-2 C.B. 115.
218.441 Housing; missionary families. An
organization established to provide temporary
low-cost housing and related services for missionary
families on furlough for recuperation or training
in the U.S. from their assignments abroad is
operated exclusively for charitable purposes and
qualifies for exemption. §1.501(c)(3)-1. (Sec.
501, ’86 Code.)
Rev. Rul. 75-434, 1975–2 C.B. 205.
218.442 Housing; municipal instrumentality.
A public housing authority incorporated under a
State statute conferring upon it the power to conduct
examinations and investigations, to administer
oaths, issue subpoenas, and make its findings
and recommendations available to appropriate
agencies does not qualify for exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 74-14, 1974–1 C.B. 125.
218.443 Housing; nondiscriminatory. An
organization formed to educate the public about
the need for making housing available to members
of the public on a nondiscriminatory basis and to
encourage investment in such housing may be
exempt from tax. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 67-250, 1967-2 C.B. 182.
218.444 Housing; physically handicapped. A
nonprofit organization that provides specially
designed housing to physically handicapped persons
at the lowest feasible cost and maintains in
residence those tenants who subsequently become
unable to pay its monthly fees is operated exclusively
for charitable purposes within the meaning
of section 501(c)(3). §1.501(c)(3)-1. (Sec. 501,
’86 Code.)
Rev. Rul. 79-19, 1979-1 C.B. 195.
218.445 Housing, transportation and counseling
for relatives of hospital patients. A nonprofit
organization that provides housing, transportation,
and counseling to hospital patients’
relatives and friends who travel to the locality to
assist and comfort the patients qualifies for
exemption under section 501(c)(3).
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 81-28, 1981-1 C.B. 328.
218.446 Housing; tenant groups. An organization
comprised of public housing tenant groups in
a state and formed to promote the rights and welfare
of public housing tenants by providing them
with information and technical assistance regarding
regulations and laws concerning public housing
and acting as the state recognized agent for
public housing tenant organizations qualifies for
exemption as operated exclusively for charitable
purposes. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Ru1. 75–283, 1975-2 C.B. 201.
218.447 Income-producing asset subject to
life estate and annuity. The exempt status of an
organization is not affected by the acceptance of
an income-producing asset subject to a reserved
life estate in the transferor or in exchange for an
annuity specifically charged against the asset.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 69-176, 1969-1 C.B. 150.
218.448 Income-producing property; predicated
foundations purpose. A foundation was
established under the decedent’s will providing
primarily for the continuance of the pyrometric
cone manufacturing business and secondarily for
the advancement of the ceramic arts and industries.
Under the will, approximately 80 percent of
the business gross income would be required to
meet manufacturing costs and other expenses and
the remaining 20 percent would be spent in
research in the field of ceramics through fellowships
granted to selected graduate students. Held,
the foundation is an exempt organization under
section 501(c)(3) and did not receive unrelated
business income under section 511 or 513; the purpose
of the business was not merely to provide a
source of income but to predicate the foundation’s
scientific and educational purposes. (Secs. 501,
502, 511, 513; ’86 Code.)
Edward Orton, Jr. Ceramic Foundation, 56 T.C.
147, Nonacq., 1972-1 C.B. 4.
218.449 International exposition. An organization
that conducts an international exposition
commemorating certain historical events and cultural
achievements, and exhibiting products of
various nations, qualifies for exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 71-545, 1971-2 C.B. 235.
218.450 Investment clubs. An association of
investment clubs formed to enable members and
prospective investors to make sound investments
by the mutual exchange of investment information,
that carries on not only educational activities
but other activities directed to the support and
promotion of the economic interests of its members,
does not qualify for exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 76-366, 1976-2 C.B. 144.
218.451 Investment management services.
An organization regularly carrying on an investment
service that would be unrelated trade or business
if carried on by any of the exempt organizations
on whose behalf it operates is not exempt.
Distinguished by Rev. Rul. 71-529. §1.502-1.
(Sec. 502, ’86 Code.)
Rev. Rul. 69-528, 1969-2 C.B. 127.
218.452 Investment management services;
colleges and universities. A nonprofit organization
that provides assistance in the management of
participating colleges’ and universities’ endowment
or investment funds for a fee substantially
below the cost of providing such service, qualifies
for exemption. Rev. Rul. 69–528 distinguished.
Distinguished by Rev. Rul. 72-369.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 71-529, 1971-2 C.B. 234.
218.453 Jazz music appreciation. A nonprofit
organization created to develop and promote an
appreciation of jazz music as an American art
form through the presentation of public jazz festivals
or concerts is exempt from tax.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 65-271, 1965-2 C.B. 161.
218.454 Journal on physical and mental disorders.
An organization formed to encourage
basic research in specific types of physical and
mental disorders, improve educational procedures
for teaching those afflicted with those disorders,
and disseminate educational information about
such disorders, by the publication of a journal containing
current technical literature relating to these
disorders may qualify for exemption. Rev. Rul.
60-351 distinguished. §1.501(c)(3)-1. (Sec. 501,
’86 Code.)
Rev. Rul. 67-4, 1967-1 C.B. 121.
218.455 Labor; apprenticeship and training
committee. A nonprofit apprenticeship and training
committee formed by a union and an employers’
association of a particular industry in connection
with a collective bargaining agreement,
which conducts educational courses and programs
in various aspects of the trade for local members,
employees, or associates of the industry to ensure
that local standards on the quality of work conform
with national codes for the industry, and, also
selects and supervises the training of apprentices,
is exempt. §1.501(c)(5)–1. (Sec. 501, ’86 Code.)
Rev. Rul. 78-42, 1978-1 C.B. 158.
218.456 Labor; apprenticeship committee.
An apprenticeship committee organized primarily