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Business Activities and Social Welfare

An organization does not operate primarily to promote social welfare if its primary activity is carrying on a business with the general public in a manner similar to organizations operated for profit. Thus, for example, a nonprofit corporation that operates a semiprofessional baseball club as its principal activity is not entitled to exemption under section 501(c)(4).

Gaming Activities and Social Welfare: A nonprofit organization that conducts weekly drawings among members of the general public as its principal activity and uses the profits primarily to pay its general expenses is not exempt. Revenue Ruling 61-158, 1961-2 C.B. 115 .  On the other hand, that an organization's principal source of income is from gaming activities does not preclude exemption.  In reaching this conclusion, Revenue Ruling 68-45, 1968-1 C.B. 259  reasoned:

The fact that the organization's principal source of income is from the conduct of bingo games with the general public does not mean that the games are also its primary activity.  All the facts and circumstances are taken into account in determining an organization's primary activity and the facts in this case clearly establish that the organization's social welfare activities are its primary activities.


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Page Last Reviewed or Updated: 30-Apr-2013