Exempt organizations - Uncle Fed's Tax*Board

supplies to the sorority and its member chapters,
neither the sorority nor its chapters can qualify for
exemption as a social club or a civic or social welfare
organization. §§1.501(c)(4)-1,
1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 66-360, 1966-2 C.B. 228.
218.506 Nurses’ association; maintaining
employment registry. A nurses’ association
which maintains an employment registry primarily
for the employment of members is not entitled
to exemption as a charitable organization or as a
business league since its primary purpose is the
operation of a regular business of a kind ordinarily
carried on for profit and it is engaged in rendering
particular services for individual persons rather
than promoting the general business conditions of
the nursing profession. Rev. Rul. 55-656 distinguished.
Distinguished by Rev. Rul. 80-287.
§§1.501(c)(3)-1, 1.501(c)(6)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 61-170, 1961-2 C.B. 112.
218.507 Nursing bureau. A community nursing
bureau operated as a community project,
which maintains a nonprofit register of qualified
nursing personnel, including graduate nurses,
unregistered nursing school graduates, licensed
attendants and practical nurses, for the benefit of
hospitals, health agencies, doctors and individuals,
which receives its primary financial support
from various community organizations and public
contributions, qualifies for exemption. Distinguished
by Rev. Rul. 61-170. §1.501(c)(3)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 55-656, 1955-2 C.B. 262.
218.508 Oil production payments acquired
with borrowed funds. A nonprofit organization
may qualify for exemption from tax where it
obtains funds for charitable grants and contributions
through acquisition, with borrowed money,
of oil and gas production payments.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 66-296, 1966-2 C.B. 215.
218.509 Pension to retired employees. An
organization created pursuant to the will of a
stockholder of a company to pay pensions to all
retired employees of that company does not qualify
for exemption. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 68-422, 1968-2 C.B. 207.
218.510 Police-firemen’s benefit association.
A corporation organized and operated exclusively
for the benefit of dependent widows and children
of policemen or firemen killed in the line of duty
may, under certain circumstances, qualify for
exemption as a charitable organization.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 55-406, 1955-1 C.B. 73.
218.511 Political; separate bank account. A
separate bank account used by a candidate for state
public office to receive deposits of political campaign
funds that are disbursed only for bona fide
political campaign expenses qualifies as a political
organization under section 527. (Sec. 527, ’86
Code.)
Rev. Rul. 79-11, 1979-1 C.B. 207.
218.512 Political activities; assisting in transition
of office of Governor. A nonprofit organization
formed to implement an orderly change
of administration of the office of Governor of a
State by assisting the Governor-elect, during the
period between his election and inauguration in
screening and selecting applicants for State
appointive offices and preparing a legislative message
and program reflecting the party’s platform
and budget, is an “action” organization, and does
not qualify for exemption. §1.501(c)(3)-1. (Sec.
501, ’86 Code.)
Rev. Rul. 74-117, 1974-1 C.B. 128.
218.513 Political activities; newsletter publication;
congressional voting records. Certain
publications in a nonpartisan newsletter of congressional
incumbents’ voting records on selected
issues do not constitute participation or intervention
in any political campaign. Rev. Rul. 78–248
amplified. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 80-282, 1980-2 C.B. 178.
218.514 Political campaign practices. An
organization formed to elevate the standards of
ethics and morality in the conduct of political campaigns
that disseminates information concerning
general campaign practices, furnishes teaching
aids to political science and civics teachers, and
publicizes its proposed code of fair campaign
practices without soliciting the signing or
endorsement of the code by candidates qualifies as
an educational organization. Rev. Ruls. 60-193
modified and 66-258 superseded. §1.501(c)(3)–1.
(Sec. 501, ’86 Code.)
Rev. Rul. 76-456, 1976-2 C.B. 151.
218.515 Political education organization. A
corporation created to encourage greater participation
in government and political affairs through
the use of seminars, non-partisan workshops, and
through the distribution of educational materials
does not qualify for exemption as an educational
organization but may qualify as a social welfare
organization. Modified by Rev. Rul. 76-456.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 60-193, 1960-1 C.B. 195.
218.516 Political education organization. An
organization which, as its primary objective,
advocates the adoption of a doctrine or theory
which can become effective only by the enactment
of legislation is not entitled to exemption since it
is an “action” organization and thus is not operated
exclusively for educational purposes.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 62-71, 1962-1 C.B. 85.
218.517 Premiums paid on assigned life
insurance policy. A section 501(c)(3) organization
will not lose its exempt status if it accepts, and
pays premiums on an assigned life insurance
policy in which the assignor retains the right to
select the method of payment of the proceeds due
upon his death. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 67-381, 1967-2 C.B. 189.
218.518 Preservation of buildings having historical
or architectural significance. A nonprofit
organization formed to promote an appreciation
of history through the acquisition,
restoration, and preservation of homes, churches,
and public buildings having special historical or
architectural significance and to open the structures
for viewing by the general public qualifies
for exemption. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 75-470, 1975-2 C.B. 207.
218.519 Preservation of properties having
historical or architectural significance. An
organization formed for the purposes of preserving
the historic or architectural character of a community
through the acquisition and occasional restoration
of historically or architecturally
significant properties, and subsequent disposition
of these properties qualifies for exemption under
section 501(c)(3). §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 86-49, 1986-1 C.B. 243.
218.520 Prevention of cruelty to animals;
birth control. A nonprofit organization formed to
prevent the overbreeding of cats and dogs by providing
funds to pet owners who wish to have their
pets spayed or neutered but cannot afford the cost
of such operations qualifies for exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 74-194, 1974-1 C.B. 129.
Exempt organizations
218.521 Prevention of cruelty to animals; legislative
activities. An organization operated for
the prevention of cruelty to animals, exempt under
section 501(c)(4), is not exempt under section
501(c)(3) if it substantially engages in promoting
legislation for the humane treatment of animals,
even though the legislation it advocates may be
beneficial to the community, and even though
most of its attempts to influence legislation may be
indirect. Contributions to it are not deductible.
§§1.170-2, 1.501(c)(3)-1, 1.501(c)(4)-1. (Secs.
170, 501; ’86 Code.)
Rev. Rul. 67–293, 1967–2 C.B. 185.
218.522 Prevention of cruelty to children. An
organization formed and operated for the purpose
of preventing children from working in hazardous
trades or occupations in violation of state laws, to
protect children, and eliminate conditions detrimental
to them, the income of which is derived
from contributions solicited from the public
through various agencies, is exempt from tax. I.T.
2143 superseded. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 67-151, 1967-1 C.B. 134.
218.523 Private club operated by motel. A
private club, controlled by the owners of an
adjoining motel, which provides entertainment
and operates a cocktail lounge as an integral part
of the motel business does not qualify for exemption
as a social club. §1.501(c)(7)-1. (Sec. 501,
’86 Code.)
Rev. Rul. 66-225, 1966–2 C.B. 227.
218.524 Private foundation; governing
instrument provision; dissolution requirements.
Provisions in an organization’s governing
instrument that satisfy the requirements of section
508(e), for purposes of qualification for exemption
under section 501(a) as a private foundation,
are not in themselves sufficient to meet the
requirement of reg. 1.501(c)(3)-1(b)(4), that upon
dissolution, the organization’s assets be dedicated
to an exempt purpose. §§1.501(c)(3)-1, 1.508-3,
53.4947-1. (Secs. 501, 508, 4947; ’86 Code.)
Rev. Rul. 85-160, 1985-2 C.B. 162.
218.525 Private hospital rooms. An otherwise
qualifying organization that makes a private hospital
room available to patients who can benefit
medically from a private room but who cannot
afford the expense of such a room is operated
exclusively for charitable purposes and is exempt
from tax. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 79-358, 1979-2 C.B. 225.
218.526 Private school; racially discriminatory.
Private schools that practice racial discrimination
do not qualify as tax-exempt organizations
under section 501(c)(3). Contributions to such
schools are not deductible under section 170.
(Secs. 170, 501; ’86 Code.)
Bob Jones University, 461 U. S., Ct. D. 2018,
1983–28 I.R.B. 8.
218.527 Private schools; racially discriminatory.
Respondents lack standing to bring suit
charging the federal tax exemption granted to
racially discriminatory private schools in their
communities impairs their ability to have their
public schools desecrated. (Sec. 501, ’86 Code.)
Allen v. Wright, 468 U. S., Ct. D. 2027, 1984-2
C.B. 106.
218.528 Private school; racially nondiscriminatory
policy. A private school that does not have
a racially nondiscriminatory policy as to students
does not qualify for exemption. §§1.501(c)(3)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 71-447, 1971-2 C.B. 230.
218.529 Professional standards review. An
organization was established to perform the services
of a professional standards review organization
(PSRO) pursuant to section 249F of the Social
Security Amendments of 1972, and was desig-