Exempt organizations - Uncle Fed's Tax*Board

Exempt
organizations
nonprofit organization that supervises the preparation
and inspection of food products prepared
commercially in a particular locality to insure that
they satisfy the dietary roles of a particular
religion, thereby assisting the individual members
of the religion to comply with its tenets and dictates,
qualifies for exemption. §1.501(c)(3)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 74-575, 1974-2 C.B. 161.
218.555 Religious; weekend retreat center.
An otherwise qualifying nonprofit organization
that conducts weekend religious retreats, open to
individuals of diverse Christian denominations, at
a rural lakeshore site at which the participants may
enjoy the recreational facilities in their limited
amount of free time and that charges no fees qualifies
for exemption as operated exclusively for
religious purposes. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 77-430, 1977-2 C.B. 194.
218.556 Religious and educational broadcasting
station. An otherwise qualifying nonprofit
organization broadcasts religious and
educational programs from a commercially
licensed television station it owns and operates.
An “insubstantial” amount of total air time is
devoted to nonreligious, noneducational, commercially
sponsored programs, the income from
which is put toward the organization’s exempt
purpose. The organization is considered to be
operated exclusively for charitable purposes and
is exempt from tax under section 501(c)(3). Rev.
Rul. 68-563 amplified. §§1.501(c)(3)-1, 1.511-2,
1.513-1. (Secs. 501, 511, 513; ’86 Code.)
Rev. Rul. 78–385, 1978–2 C.B. 174.
218.557 Religious organization dependent on
wages of members. An organization that is substantially
dependent on wages earned by some of
its members from outside employment, rather than
on an internally operated business, does not qualify
for exemption under section 501(d); Rev. Rul.
77–290 amplified. §1.61–2, 1.501(d)-1. (Secs.
61, 501, 3121, 3401; ’86 Code.)
Rev. Rul. 80-332, 1980-2 C.B. 34.
218.558 Rescue and emergency services. A
nonprofit organization formed to provide free rescue
and emergency services to distressed persons
may qualify for exemption. §1.501(c)(3)-1. (Sec.
501, ’86 Code.)
Rev. Rul. 69-174, 1969-1 C.B. 149.
218.559 Research in anthropology. An organization
formed to support research in
anthropology by manufacturing quality cast
reproductions of anthropological specimens
which are sold to scholars and educational institutions
in a noncommercial manner qualifies for
exemption. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 70-129, 1970-1 C.B. 128.
218.560 Rest home for elderly poor. A nonprofit
publicly-supported organization that operates
a rural rest home to provide, at a nominal
charge, two-week vacations for elderly poor
people from nearby metropolitan areas qualifies
for exemption as a charitable organization under
section 501(c)(3). §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 75-385, 1975-2 C.B. 205.
218.561 Scholarship awarded for scholastic
ability. A nonprofit organization awarding scholarships
to students based on scholastic ability,
without regard to financiaI need, may qualify for
exemption. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 69–257, 1969–1 C.B. 151.
218.562 Scholarship plan for pre-selected
individuals. A nonprofit organization whose sole
activity is the operation of a “scholarship fund”
plan for making payments to pre-selected, specifically
named individuals does not qualify for
exemption. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 67-367, 1967-2 C.B. 188.
218.563 Securities fund for student management.
A fund set up as an adjunct to an exempt
school of business administration for the sole purpose
of providing business students with instruction
and experience in managing securities may be
exempt from tax. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 68-16, 1968-1 C.B. 246.
218.564 Security services. A nonprofit organization
that provides security services for residents
and property owners of a particular community,
who agree to voluntarily donate money at a
specified hourly rate to defray the cost of the services,
is carrying on a business with the general
public in a manner similar to organizations operated
for profit and does not qualify for exemption.
§1.501(c)(4)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 77-273, 1977-2 C.B. 195.
218.565 Senior citizen center. An organization
that establishes a service center providing
information, referral, counseling services relating
to health, housing, finances, education, and
employment, as well as a facility for specialized
recreation for a particular community’s senior citizens,
who need not become members to obtain the
services or participate in the activities, may qualify
for exemption. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 75-198, 1975-1 C.B. 157.
218.566 Social clubs; automobile club. An
automobile club whose principal activity is rendering
automobile services to its members and
there is no commingling of its members does not
qualify for exemption. G.C.M. 23688 superseded.
§1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 69-635, 1969-2 C.B. 126.
218.567 Social clubs; aviation clubhouse
leased; rent based on clubhouse profits. An aviation
club, otherwise qualifying for exemption as
a private social club, rented a facility for use as a
clubhouse under a lease which provided for a
facility partner, who was in no way related to the
club, to manage the clubhouse and for rent to be a
percentage of the clubhouse profits. Held, the aviation
club qualified as an exempt social club. (Sec.
101(9), ’39 Code; Sec. 501, ’86 Code.)
Aviation Country Club, Inc., 21 T.C. 807, Acq.,
1954-2 C.B. 3.
218.568 Social clubs; bowling tournaments.
A nonprofit organization that conducts regular
bowling tournaments for its members qualifies for
exemption where its overall program is designed
to effect a commingling of members for their pleasure
and recreation. The awarding of cash prizes
to tournament winners from tournament entry fees
is not an inurement of net income to members.
§1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 74-148, 1974-1 C.B. 138.
218.569 Social clubs; business endeavors;
assistance to members. A social club formed to
assist its members in their business endeavors
through study and discussion of problems and
other activities at weekly luncheon meetings does
not qualify for exemption. §1.501(c)(7)-1. (Sec.
501, ’86 Code.)
Rev. Rul. 69–527, 1969–2 C.B. 125.
218.570 Social clubs; business with public;
taxable subsidiary. The activities of a taxable
subsidiary of an exempt social club are considered
to be those of the parent club for the purpose of
determining whether the parent is engaging in
business with the general public for profit.
§1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 68-74, 1968-1 C.B. 267.
218.571 Social clubs; college fraternity. A college
fraternity organized on a nonprofit basis that
maintains a chapter house for active members who
are students of the school, is exempt from tax as a
social club under section 501(c)(7) but is not
exempt under section 501(c)(3). Contributions to
the fraternity are not deductible. I.T. 1427 and
G.C.M. 5952 superseded. §§1.170-1,
1.501(c)(3)-1, 1.501(c)(7)-1. (Secs. 170, 501; ’86
Code.)
Rev. Rul. 69-573, 1969-2 C.B. 125.
218.572 Social clubs; corporate members. A
country club, exempt as a social club under
501(c)(7), that issues corporate memberships is
dealing with the general public in the form of the
corporations’ employees. Gross receipts from
such “members” will be a factor in determining
whether the club continues to qualify as a social
club. §1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 74-489, 1974–2 C.B. 169.
218.573 Social clubs; corporation sponsored
membership. An exempt social club does not
jeopardize its status by admitting corporation
sponsored individuals who have the same rights
and privileges as regular individual members, who
must be approved by the membership committee
as provided in the club’s bylaws, and whose corporate
sponsor is not entitled to vote, has no control
over the club management, and enjoys no ownership
rights. §1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 74-168, 1974–1 C.B. 139.
218.574 Social clubs; distribution of condemnation
proceeds. A distribution of cash to the
members of a club formed for the purpose of providing
hunting and fishing facilities for its members
through the propagation and stocking of fish
and game on the club property does not adversely
affect its exemption where such distribution represents
an amount received from the state highway
department in payment of land condemned for
road building purposes. §1.501(c)(7)-1. (Sec.
501, ’86 Code.)
Rev. Rul. 65-64, 1965-1 C.B. 241.
218.575 Social clubs; dues inequity; associate
membership. A social club whose active members
pay substantially lower dues and initiation
fees than associate members although both classes
enjoy the rights and privileges in the club’s facilities
does not qualify for exemption.
§1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 70-48, 1970- 1 C.B. 133.
218.576 Social clubs; equestrian sports;
annual steeplechase. A social club organized to
promote the enjoyment of equestrian sports does
not, under certain conditions, jeopardize its
exemption by charging the public admission to its
annual steeplechase. §1.501(c)(7)-1. (Sec. 501,
’86 Code.)
Rev. Rul. 68–119, 1968–1 C.B. 268.
218.577 Social clubs; facilities available for
charitable fund-raising activities. The exempt
status of a country club will not be adversely
affected if it makes its facilities available to an
exempt organization for charitable fund-raising
activities at a charge equal to or less than direct
cost. §1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 69-636 .1969-2 C.B. 126.
218.578 Social clubs; family; historical and
social activities. A nonprofit membership corporation
which was formed to bring the members of
a particular family into closer association through
social and historical activities is exempt.
§1.501(c)(7)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 67–8, 1967–1 C.B. 142.
218.579 Social clubs; federation of sporting
clubs. A federation of sporting clubs formed for
the purpose of governing and developing an amateur
sport in the U.S. does not qualify for exemp-