Contents

§3.3 MEANING OF CHARITABLE ORGANIZATION• Advancement of science. Similarly, the scope of this category of charitableactivity is imprecise, due to the recognition of scientific activities as a separatebasis for tax-exempt status. 293 Organizations that are charitablebecause they advance science generally are those that support or otherwiseassist scientific organizations. 294• Lessening of the burdens of government. An organization that is charitable isone that lessens the burden of a government, where the governmentalunit considers the burden to be among its burdens. Organizations of thistype either provide services directly in the context of government activityor provide support to a governmental agency or department. 295• Promotion of social welfare. An organization can be charitable if it promotessocial welfare; this is one of the broadest categories of charitable organizations.This purpose includes activities such as lessening neighborhoodtensions, eliminating prejudice and discrimination, defending human andcivil rights secured by law, and combating community deterioration andjuvenile delinquency. 296• Community beautification and maintenance. An organization can be charitableby reason of the fact that its purpose is community beautification andmaintenance, and the preservation of natural beauty. 297• Promotion of health. An organization can be charitable because it engages inactivities that promote health. 298 This purpose embraces the establishmentand maintenance of hospitals, clinics, homes for the aged, and the like.• Promotion of the arts. An organization may be charitable because it engagesin one or more activities that promote the arts. This purpose includes theestablishment and maintenance of theaters, the promotion of publicappreciation of one of the arts, and the promotion and encouragement ofthe talent and ability of young artists. 299• Promotion of the public interest through law. An organization can be charitableby functioning as a public interest law firm. 300 These firms provide legalrepresentation for important citizen interests that are unrepresentedbecause the cases are not economically feasible for private law firms.• Local economic development. One of the forms of charitable organizations isthe local economic development corporation, which engages in a varietyof activities, including investment in local businesses, creation of housingopportunities, and encouragement of established businesses to openoffices and plants in economically depressed areas. 301293 See § 3.3(b)(iv).294 Reg. § 1.501(c)(3)-1(d)(2).295 Id.296 Id.297 Rev. Rul. 78-85, 1978-1 C.B. 150.298 Rev. Rul. 69-545, 1969-2 C.B. 117. In general, see Hyatt & Hopkins, The Law of Tax-Exempt Healthcare Organizations,2d ed. (Hoboken, NJ: John Wiley & Sons, 2001), particularly pt. 3.299 See, e.g., Rev. Rul. 64-175, 1964-1 (Part 1) C.B. 185; Rev. Rul. 64-174, 1964-1 (Part 1) C.B. 183.300 See, e.g., Rev. Rul. 75-74, 1975-1 C.B. 152.301 See, e.g., Rev. Rul. 81-284, 1981-2 C.B. 130. 99