Exempt organizations - Uncle Fed's Tax*Board

218.654 University alumni association. An
alumni association controlled by a university and
operated as an integral part thereof qualifies for
exemption as an educational organization.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 56-486, 1956-2 C.B. 309.
218.655 University alumni association. Social
and recreational activities carried on by an alumni
association of a university, which are merely incidental
to its basic purpose and objective of
advancing the interests of the university, do not of
themselves preclude such organization from tax
exemption as a charitable and educational association.
Contributions, exclusive of membership
dues, to such association are deductible. G.C.M.
22116 revoked. §§1.170-1, 1.501(c)(3)-1. (Secs.
170, 501; ’86 Code.)
Rev. Rul. 60-143, 1960-1 C.B. 192.
218.656 University campus newspaper; political
and legislative comments. A university that
provides facilities and faculty advisors for a campus
newspaper that publishes the student’s editorial
opinions on political and legislative matters
has not attempted to influence legislation or participate
in political campaigns. §1.501(c)(3)-1.
(Sec. 501, ’86 Code.)
Rev. Rul. 72-513, 1972-2 C.B. 246.
218.657 University housing and food service.
A nonprofit organization may qualify for exemption
where it is formed to provide housing and
food service exclusively for students and faculty
of a university in accordance with the rules and
regulations of the university and offers the university
an option to acquire the property at any time
upon payment of an amount equal to the outstanding
indebtedness. §1.501(c)(3)-1. (Sec. 501, ’86
Code.)
Rev. Rul. 67-217, 1967-2 C.B. 181.
218.658 University housing for students. A
nonprofit organization formed to provide housing
for students of a college unable to provide adequate
student housing and located in a community
in which suitable housing is not otherwise available
is operated exclusively for charitable purposes
and qualifies for exemption.
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 76-336, 1976-2 C.B. 143.
218.659 University political science course;
political campaign participation. A university is
not participating in political campaigns on behalf
of candidates for public office by providing a
political science credit course that requires students’
participation in political campaigns of candidates
of their choice. §1.501(c)(3)-1. (Sec. 501,
’86 Code.)
Rev. Rul. 72-512, 1972-2 C.B. 246.
218.660 Unrelated business activity; rental of
office building; income to charity. A corporation
organized exclusively for charitable purposes
which derives its income principally from the
rental space in a large commercial office building
which it owns, maintains, and operates and uses
such income to aid other charitable organizations
through contributions and grants is deemed to
meet the primary purpose test of the income tax
regulations and is, therefore, entitled to exemption
where it is shown to be carrying on through such
contributions and grants a charitable program
commensurate in scope with its financial
resources. §1.501(c)(3)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 64-182, 1964-1 (Part 1) C.B. 186.
218.661 Veterans; membership requirements;
“period of war”. The dates of “a period
of war,” for purposes of the definition of war veterans
in reg. 1.501(c)(19)-1(b)(1), will be the
dates of periods of war set forth in 38 U.S.C. section
101 relating to veterans’ benefits.
§1.501(c)(19)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 78–239, 1978–1 C.B. 162.
218.662 Voluntary employees’ beneficiary
association; one employee member. A trust
created to provide life, sick, accident, and other
benefits to only one employee does not qualify for
exemption under section 501(c)(9).
§1.501(c)(9)-1. (Sec. 501, ’86 Code.)
Rev. Rul. 85-199, 1985-2 C.B. 163.
218.663 Volunteer fire company. A nonprofit
organization that was organized and operated as a
volunteer fire company to provide fire protection
and ambulance and rescue services to a community
qualifies for exemption as a charitable organization
and contributions made to the organization
are deductible. The organization may also
qualify for exemption as a social welfare organization.
Further, under section 513(a)(1), conducting
the weekly public dances does not constitute an
unrelated trade or business. Rev. Rul. 66-221
superseded and Rev. Rul. 71-47 clarified.
§§1.170A-1, 1.501(c)(3)-1, 1.501(c)(4)-1,
1.513-1. (Secs. 170, 501, 513; ’86 Code.)
Rev. Rul. 74-361, 1974–2 C.B. 159.
Unrelated income
220.1 $1,000 deduction. An exempt organization
is entitled to only one $1,000 deduction in
computing its unrelated business taxable income
regardless of the number of unrelated businesses
in which it is engaged. §1.512(b)-1. (Sec. 512, ’86
Code.)
Rev. Rul. 68-536, 1968-2 C.B. 244.
220.2 Advertising revenues of monthly medical
journals. The publication of paid advertising
in a monthly medical journal is not substantially
related to the educational purposes of the journal
and the profits from advertising are unrelated business
taxable income. §1.513-1. (Sec. 513, ’86
Code.)
American College of Physicians, U.S., Ct. D,
2035, 1986-2 C.B. 76.
220.3 Agricultural organization; club facilities.
The operation of extensive club facilities,
consisting of a restaurant, a bar, and a cocktail
lounge for members and guests, by an exempt
agricultural organization constitutes the carrying
on of an unrelated trade or business and the organization
is subject to the tax on the unrelated business
income resulting from the operation of such
facilities. §1.501(c)(5)-1, 1.511-1, 1.513-1.
(Secs. 501, 511, 513; ’86 Code.)
Rev. Rul. 60-86, 1960-1 C.B. 198.
220.4 Agricultural organization; insurance
company services. An exempt agricultural organization
is subject to tax on the unrelated business
income resulting from services rendered to certain
insurance companies and from the performance of
property management services. §§1.511-1,
1.513-1. (Secs. 511, 513; ’86 Code.)
Rev. Rul. 60-228, 1960-1 C.B. 200.
220.5 Agricultural organization; marketing
livestock for members. The sale of cattle for its
members on a commission basis by a section
501(c)(5) agricultural organization constitutes
unrelated trade or business. §§1.511–1, 1.513–1.
(Secs. 511, 513; ’86 Code.)
Rev. Rul. 69-51, 1969-1 C.B. 159.
220.6 Allocation of membership receipts. The
proper method of allocating membership receipts
to circulation income under the formula in reg.
1.512(a)-1(f)(4)(iii) is illustrated. §1.512(a)-1.
(Sec. 512, ’86 Code.)
Rev. Rul. 81-101, 1981-1 C.B. 352.
220.7 Art museum; book and souvenir sales.
The sale of scientific books and city souvenirs by
an exempt museum constitutes unrelated trade or
business even though other items sold in the same
Exempt organizations
museum shop are related to its exempt function.
§1.513-1. (Sec. 513, ’86 Code.)
Rev. Rul. 73-105, 1973-1 C.B. 264.
220.8 Art museum; dining room, cafeteria,
and snack bar. The operation of a dining room,
cafeteria, and snack bar by an exempt art museum
for use by the museum staff, employees, and members
of the public visiting the museum does not
constitute an unrelated trade or business.
§§1.501(c)(3)-1, 1.513-1. (Secs. 501, 513; ’86
Code.)
Rev. Rul. 74-399, 1974-2 C.B. 172.
220.9 Art museum; greeting card sales. The
sale of greeting card reproductions of art works by
an exempt art museum does not constitute unrelated
trade or business activity. §1.513-1. (Sec.
513, ’86 Code.)
Rev. Rul. 73-104, 1973-1 C.B. 263.
220.10 Bar association; sale of legal forms.
The sale at a profit of standard legal forms to its
members by a local bar association that is exempt
under section 501(c)(6) is an unrelated trade or
business. §§1.501(c)(6)-1, 1.513-1. (Secs. 501,
513; ’86 Code.)
Rev. Rul. 78-51, 1978-1 C.B. 165.
220.11 Bar association journal; commercial
advertising; legal notices. The publication of
ordinary commercial advertising for products and
services used by the legal profession in a bar
association’ s journal is unrelated trade or business
under section 513. However, the publication of
legal notices is not unrelated trade or business.
§§1.501(c)(6)-1, 1.513-1. (Secs. 501, 513; ’86
Code.)
Rev. Rul. 82-139, 1982-2 C.B. 108.
220.12 Bingo games. The holding of semiweekly
bingo games by an exempt labor organization
is a profit-making enterprise not related to the
exempt purposes of the organization and, therefore,
constitutes unrelated trade or business. The
income derived therefrom is subject to the tax
imposed on unrelated business taxable income.
§§1.501(c)(5)-1, 1.511-1, 1.512(a)-1, 1.513-1.
(Secs. 501, 511, 512, 513; ’86 Code.)
Rev. Rul. 59-330, 1959-2 C.B. 153.
220.13 Blood bank. A blood bank organized
and operated to provide a community with permanent
facilities for the collection and storage of
human blood and blood products and to provide
for the public distribution thereof may be exempt
from tax. Modified by Rev. Rul. 78-145.
§§1.501(c)(3)-1, 1.511-2, 1.513-1. (Secs. 501,
511, 513; ’86 Code.)
Rev. Rul. 66-323, 1966-2 C.B. 216.
220.14 Blood bank. Sale of plasma to commercial
laboratories by an exempt blood bank,
engaged in collecting and maintaining blood products
for use by hospitals, is not unrelated trade or
business where the blood bank sells either byproduct
plasma from which red blood cells have
been removed for use by hospitals or plasma salvaged
from whole blood nearing the end of its
shelf life. However, sale of plasma derived from
donors through plasmapheresis or purchased from
other blood banks is unrelated trade or business.
Rev. Rul. 66-323 modified. §1.513-1. (Sec. 513,
’86 Code.)
Rev. Rul. 78-145, 1978-1 C.B. 169.
220.15 Broadcasting rights; amateur athletic
events. The sale of television and radio broadcasting
rights to an independent producer by an
exempt organization created as a national governing
body for amateur athletics is not unrelated
trade or business. §1.513-1. (Sec. 513, ’86 Code.)
Rev. Rul. 80-295, 1980-2 C.B. 194.
220.16 Broadcasting rights; tournaments.
The sale of broadcasting rights to a national radio
and television network by an organization created