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§3.3 MEANING OF CHARITABLE ORGANIZATIONFour Internal Revenue Code sections require highlighting at this point:• The one providing federal income tax exemption for charitable organizations256• The federal income tax charitable contribution deduction rules, whichclassify eligible charitable donees 257 and provide that organizations thatare charitable entities under the tax exemption rules are eligible charitabledonees for purposes of that deduction 258• The federal gift tax charitable contribution deduction rules, which classifyeligible charitable donees 259• The federal estate tax charitable contribution deduction rules, which classifyeligible charitable donees 260The gift and estate tax rules in this regard are discussed elsewhere. 261 Thisanalysis, then, is confined to the federal income tax rules.Nearly every organization that is considered a charitable organization forpurposes of the federal income tax exemption 262 is considered a charitable organizationfor purposes of the federal income tax charitable contribution deduction.263 The only exception to this rule is the organization that tests for publicsafety. Such an organization, though embraced by the tax exemption rules as acharitable entity, is omitted from charitable donee status for purposes of theincome tax charitable contribution deduction. 264There are, however, certain organizations that cannot qualify for tax exemptionpurposes as charitable organizations that can qualify, for purposes of thelaw of charitable giving, as charitable donees. Nonetheless, these entities are alltax-exempt organizations. They are:• A state, a possession of the United States, a political subdivision of a stateor U.S. possession, the United States, or the District of Columbia—butonly if the contribution is made for exclusively public purposes 265• A post or organization of war veterans, or an auxiliary unit or society of,or trust or foundation for, such a post or organization, that is organized inthe United States or any of its possessions, if no part of its earnings inuresto the benefit of any private shareholder or individual 266256 IRC § 501(c)(3).257 IRC § 170(c).258 IRC § 170(c)(1).259 IRC § 2522(a).260 IRC § 2055(a).261 See Chapter 8.262 IRC § 501(c)(3).263 IRC § 170(c)(2). The IRS issues rulings on the qualification of organizations as charitable donees. See, e.g.,Priv. Ltr. Rul. 9037021.264 The public safety testing organization is the subject of Tax-Exempt Organizations § 10.3.265 IRC § 170(c)(1). These entities are not tax-exempt in the sense that they are described in IRC § 501(c). Theyare, however, very much tax-exempt organizations in the generic sense of that term. See Tax-Exempt Organizations§ 6.9.266 IRC § 170(c)(3). Veterans’ organizations generally are tax-exempt by reason of IRC § 501(c)(19). See Tax-Exempt Organizations § 10.10. Some veterans’ organizations are tax-exempt by reason of being classified associal welfare organizations under IRC § 501(c)(4) (see Tax-Exempt Organizations ch. 12), and some are classifiedas charitable organizations under IRC § 501(c)(3) (see Tax-Exempt Organizations pt. 2). 95