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SPECIAL EVENTS AND CORPORATE SPONSORSHIPSand least profitable method of charitable fundraising. Nonetheless, they have agreat value in public relations visibility, both for the charitable organizationinvolved and for its volunteers. 21Examples of these special events include:• Annual balls• Auctions• Bake sales• Car washes• Dinners• Fairs and festivals• Games of chance (such as bingo, raffles, and sweepstakes)• Luncheons• Sports tournaments (particularly golf and tennis)• Theater outingsThere is some confusion in the law as to exactly what constitutes a specialevent in the charitable fundraising context. For instance, one court defined afundraising event as “a single occurrence that may occur on limited occasionsduring a given year and its purpose is to further the exempt activities of theorganization.” 22 These events were contrasted with activities that “are continuousor continual activities which are certainly more pervasive a part of the organizationthan a sporadic event and [that are] . . . an end in themselves.” 23 Thereis a wide variety of fundraising methods, however, other than special events,that are “continuous” and “pervasive.” Rarely, moreover, is the purpose of a specialevent to “further the exempt activities of the organization”; they are eventsthat usually have no relationship to a charitable organization’s exempt purposesand activities, and are engaged in largely to generate some funds and favorablepublicity, which in turn helps the organization advance its tax-exempt activities.Finally, a fundraising activity is rarely an end in itself, yet many charitableorganizations and institutions have major, ongoing fundraising and developmentprograms that are permanent fixtures in the totality of the organizations’functions.Special events figure prominently in a charitable organization’s annualreporting to the IRS. In determining whether an annual information return(Form 990) is required, only net receipts (not gross receipts) from special eventsare used in determining the $25,000 filing threshold. (Organizations, other thanprivate foundations, with gross receipts that are normally not in excess of$25,000 need not file annual information returns. 24 ) Part VII-A of the annual21 See Greenfield, Fundraising: Evaluating and Managing the Fund Development Process, 2d ed., 130–39 (JohnWiley & Sons, Inc., 1999).22 U.S. CB Radio Ass’n, No. 1, Inc. v. Commissioner, 42 T.C.M. (CCH) 1441, 1444 (1981).23 Id.24 IRC § 6033(a)(2)(A)(ii). 622